Food scares and FDA actions: What has happened since 2007?
By Gina Spadafori
July 31, 2010
When I checked in this morning at the conference of the American Veterinary Medical Association here in Atlanta, the press office folks cheerfully handed me a list of highlights for the media, covering the less-technical offerings from the companion animal track of seminars.
Thus was highlighted yet another broadside against home feeders, “Do raw food diets make you want to BARF?,” that promised to counter all the claptrap on Teh Webs and get pet-owners safely back in the commercial pet-food fold. I passed on that one, having pretty much heard it at every veterinary conference in the last 10 years and, yo, see Christie’s response to “The horror of raw diets” blah blah at an earlier veterinary conference.
Before I go further, let me say, once again, that I am not trying to push anyone towards a home-prepared diet, and frankly, your pet — most pets — will do just fine on commercial. But I have so completely had it with veterinarians packing a room to hear how to talk their clients out of home-prepared diets without looking at the fact that processed foods aren’t exactly safe, either, reference the thousands of pets killed by commercial diets in 2007…not to mention so many recalls of human foods I’ve lost count.
So let’s just stipulate: Whether you combine the ingredients or a company does it for you, food is a perishable item that can never, ever be made risk-free, only risk-minimized. That’s why government needs to be able to oversee the production (and raw feeders, that included the slaughterhouses), manufacturing and distribution, and be able to force companies to be responsible, whether they want to be or not. Most are, but that’s besides the point. We need to be protected from those that aren’t.
In any case, I passed on the obligatory and well-attended “raw feeders are cultish whackjobs” lecture/pep talk and scanned the program of all seminars. And lo, after three pages of companion animal seminars, in the third of a page of “Food Animal/Equine” columns, there was this little gem: “Melamine Contamination,” followed by “Pet Food Surveillance/Notification.”
I hiked the entire length of the Georgia World Congress Center, away from the crowds packing the seminars on child-directed aggression in dogs and causes of pruritus, past the seminars for veterinary technicians, past the practice-management seminars, walking, walking, walking and finally into a small room at the end of the hall, long past any open food stands or crowds, where less than 20 chairs had butts in them and the scanner to give CE credit hadn’t yet arrived.
There stood the FDA’s Dr. Christopher Melluso of the Center for Veterinary Medicine, and if he looked disappointed in the poor showing for a talk on regulatory matters with regards to pet foods, he was polite enough not to show it.
After an hour of listening to him talk and a couple of follow-up questions (one mine on Salmonella, and more on that in a later post), three points are pretty clear:
– The FDA has improved and will continue to improve its monitoring of pet-food companies, with a series of initiatives directly related to the 2007 pet-food deaths;
– The pet-food companies will continue to have the upper hand, since the federal government still has no legal authority to force a recall; and
– Better surveillance, reporting and arm-twisting mean the FDA is more likely to know there’s a problem, and more able to push pet food companies into “voluntary” recalls. (I gathered the FDA’s “suggestion” of the necessity of a “voluntary” recall can be pretty strong)
Key to the process, of course, is the system for getting information on a sick animal to the FDA, and that’s why the turn-out in the little room is so, well, depressing. Dr. Melluso noted that an animal who gets sick is often treated for symptoms, and if the symptoms abate, there’s no diagnosis. Even if there is a suspicion, without a direct link to the food and a veterinarian’s assistance, a consumer complaint can be easily dismissed by a company — “the pet ate something else outside when the owner wasn’t looking,” etc.
But when a veterinarian is able to establish a link, with laboratory results, then it’s relatively easy for the FDA to take that to a company and get the food pulled. That happened earlier this year, when a veterinarian made a diagnosis pointing to a thiamine deficiency in a cat food that ended up being recalled.
Immediately, of course, the problem becomes apparent: Who pays for the diagnostics? Pet-owners are generally happy to have a pet restored to health, and unless the treatment doesn’t relieve those symptoms, they’re unlikely to pay for additional diagnostics that may or may not point to a pet-food as a culprit. They just want their pet better, and that’s reasonable. And should the pet die, they’re unlikely to pay for a post-mortem that might establish a link. It’s not fair for the veterinarian to bear the cost burden, either, of course, and while it makes sense to argue that such testing should be part of the public health system — since, as we’ve so often pointed out, there’s just one food supply system, and pets and people share it — you can just imagine the fun some anti-government crusader can make out of a government-funded system to pinpoint problems pet foods.
If at this point you’re a little gloomy, well, so am I.
But Dr. Melluso pointed out that in one area of regulatory law, there has been a shift that helps a great deal: After the 2007 recalls, the FDA regulations were changed to mandate that companies with a problem report it to the FDA. That wasn’t the case previously, he said, noting that Menu Foods was under no legal obligation to tell the FDA of the problems it knew it had in 2007, and that “until they ‘fessed up,” according the FDA veterinarian, the FDA was struggling to figure out what was killing pets. (And no, they still don’t really know how many pets died, and it’s likely that the Veterinary Information Network’s survey of veterinarians, coupled with the Pet Connection’s self-reporting dabatabase and extrapolations of reports from state veterinarians still suggest thousands of pets died and tens of thousands were made ill. From the FDA, all you can say for sure is that complaints about pet food went from less than 200 ‘in the two years prior to the recall, jumped to more than 12,000 in 2007 and have run about 600 a year since.)
Because pet food companies are much more likely to take action based on clinical data coordinated by a veterinarian, the FDA has put an emphasis on improving the ability of individual veterinarians to report suspicious illness and death, and expanded the ability of the FDA to coordinate information with such organizations as the AVMA, the Veterinary Information Network and state veterinarians. That last one is particularly important, notes Dr. Melluso.
“If you’re a state veterinarian and you have one dog sick, that doesn’t mean much, he said. “But if you see that there are 30 dogs sick in other states, you’d know there was a problem.” The other benefit: Some states have given their regulatory agencies powers the federal government doesn’t have in the area of food safety, and those states can do more to get food off the shelf.
Still, the basic problems remain as they were in 2007: The U.S. Food and Drug Administration regulates, well, food and drugs. The U.S. Department of Agriculture is concerned with animal health only in regards to the economic impact of illness and death on industry. The deaths of animals fall into a black hole that in human medicine is handled by the U.S. Centers for Disease Control, and there’s nothing in sight to correct the situation.
As it stands, the reporting of problems is as voluntary as the recalls those reports might trigger, and although with increased surveillance, mandatory reporting of problems by companies and faster response by the FDA to start the arm-twisting means food gets pulled faster than before. there are no doubt going the continue to be problems with a regulatory system that’s still demonstrably and, literally, fatally flawed.
Considering the human health ramifications of contaminated pet-food — Dr. Melluso noted that some of the Salmonella recalls have been triggered by reports of human illness — it’s not a stretch to suggest the CDC should be expanded to do for food-borne illness in animals what it already does for people in the same area. But in the current economic situation, it’s also unlikely that’s going to happen.
That means the onus for safety still falls on the consumer, and comes back to: wash your hands, dishes and countertops after handling food, human or pet, homemade or commercial.
The fact remains that despite the desire shown at veterinary conferences by major pet food players to push all pet-owners back to commercial products, food — all food — should all be handled with safety first and foremost in mind, and the risks, which remain relatively small, kept in perspective.
And if you suspect a problem with a food, get your pet to the veterinarian and report that illness to the FDA. If you and your veterinarian can establish a link, you may be saving lives, human and animal both. And even if you can’t, the FDA can investigate and possible make that link itself.
Appears as though there’s still work to be done. After all this time, pets continue to remain as bellwethers.
Comment by Nadine L. — July 31, 2010 @ 11:39 am
Thanks for the in-depth report from Dr. Melluso’s presentation. (You must have an amazing typing speed to get all that). However, at the beginning of this post, you spoke about a presentation about raw food diets and you said that you had had it with veterinarians packing a room to hear how to talk their clients out of home-prepared diets. I wanted to mention that a raw food diet and a home prepared diet aren’t the same thing. It is kind of like comparing apples to oranges—they are both fruit and not Cheerios, but not the same thing. There can be commercially made raw food diets, there can be home-made raw diets and there can be home made diets that are cooked (and probably a few other combinations I haven’t thought of). There are different things to consider with feeding a raw food than what there would be with a home-made food that is cooked. I’m mostly in agreement with the rest of what you said—there is a certain amount of assumption that commercial diets are better, and I am not sure that the data is there to support that conclusion.
Comment by Jan — July 31, 2010 @ 2:57 pm
Unlike Christie and Kim, I just can’t live-blog. My mind works differently, and my fingers don’t work that quickly. I need to listen, take notes and quotes, thinking about the issues in a non-linear way and then collect my thoughts for 10 minutes or so and write an on-the-spot analysis in context of what we already know about the subject.
And that’s what this was. Not a real-time transcription, but still, a story filed PDQ after.
As to the distinction between raw and cooked home-prepared diets, my personal view — and it frankly is just that, for what it’s worth — is that a home prepared diet is only as good as the ingredients you put into it, and the safety is only as good as the effort you put into very basic handling techniques. I actually feed my dogs a combination of commercial and home-prepared, and the home-prepared is both raw and cooked.
But I source my ingredients regionally, and buy from local family farms that are NOT concentrated animal feeding operations — a/k/a factory farms — but that use instead a sustainable, humane model that’s respectful of the land and the animals. There’s a long issue of why I do this that’s beyond the scope of this discussion, except to say that ONE of the reasons I do it is because I personally do not trust the meat coming from the corporate agriculture industry.
In any case, I feel every bit as safe with MY sources of meat fed raw as with the commercial food I feed as well as the home-prepared cooked meals, and I make no distinction between any of the products when it comes through the door: I assume that all food carries a degree of risk, and I practice good sanitation, whether I’m putting something together for a dog, a cat or my own plate.
As for the regular veterinary conference freak-out over raw, well, I say again, I’m damn tired of them. We are not going away, and in fact we’re growing in tandem with human “Slow Food” movement.
A companion animal veterinarian can lecture me about the risks of raw meat sourced from a farmer or rancher I can get on the phone tomorrow morning when that veterinarian’s food animal colleagues stop signing off on CAFOs with all their inherent problems.
Until then, talk to the hand.
Comment by Gina Spadafori — July 31, 2010 @ 9:16 pm
One of the vets at the practice I sometimes use was fussing about raw meat and salmonella and how you would contaminate all your mixing bowls, etc., feeding raw. I asked the question (I think I heard it here first) “how does the bowl know I’m making food for my dog and not, oh say egg salad or cookies for my family?” The sputtering was intense and amusing.
I use a mixture of commercially prepared raw and quality leftovers and my dogs are doing great. They even prompt me to eat more healthfully. “Oh that corned beef won’t make good leftovers for the dogs.” Hmmm.
Comment by schnauzer — July 31, 2010 @ 10:11 pm
Gina, I really liked this and being someone who lost a pet in 2007, I appreciate that you hiked the distance you did to attend this seminar. It sounds like a huge place. Why were there only 20 people at this particular seminar, do you think? Why the lack of interest? You had mentioned FDA will continue to improve its monitoring of pet food companies with a series of initiatives….if you get time, can you share what those initiatives are? You had mentioned Dr Melluso looked disappointed that there were so few people there, I hope he realizes that many pet owners are interested. It concerns me when I hear there is such a low turn-out and I hope it doesnt translate to FDA to turn away from the improvements they have begun.
Comment by Sandi K — July 31, 2010 @ 11:41 pm
I dont suppose there are any seminars on FIP and any news in advancements made in diagnosing or treating this awful virus?
Comment by Sandi K — July 31, 2010 @ 11:47 pm
I don’t see anything directly related to this on the seminar list, but I do know the people in academia to ask, and will see what I can find out after I get home from the back to back road trips … a week from Monday.
Comment by Gina Spadafori — August 1, 2010 @ 7:31 am
Sandy … a few things in play that would describe the poor attendance/lack of interest in an update on regulatory matters:
1) Priorities. This seminar was in competition with at least a dozen others in the same time slot. It was tagged in the “large animal” columns, so some may not even have noticed it there.
Like any conference related to the work someone does, people tend to be looking for two things: 1) How they can do their job better (new techniques, better knowledge); and 2) How they can increase their income (mortgages, college to save for). Veterinarians are no different, and when you’re looking at a schedule that promises new insight to problems you see in practice EVERY DAY (inappropriate elimination, better, earlier cancer diagnosis) vs. something that was a pressing issue three years ago and is not common now (pets dying from tainted pet food) … well, you’re going to opt for a lot of column 1, a little of column 2 and figure you’ll read about the regulatory update in the journals.
2) Ancient history. As a person who worked for a public agency, I was actually pretty impressed with how much the FDA has accomplished in three years within their legal constraints, with countless stakeholders and high-powered players and through a change at the top of the pyramid, a change from one president to another.
But in a 24-hour news cycle, the response, however good, to something that happened three years ago just isn’t interesting anymore. We all crave the “new” and this is the “old.”
3) Sexiness. I spent a good chunk of my life covering public meetings. Meetings where decisions were made that affects people’s neighborhoods, their safety and certainly their tax dollars. These were open public meetings, with good public notification well in advance. Members of the public were rarely in attendance.
Regulatory matters are boring to most people, so most people figure everything is getting handled. Or that they’ll worry about it when they need to, because there are more pressing things to think about now.
You know, if I weren’t so wonky about regulatory issues and so personally knowledgeable about the 2007 pet-food recall, I myself would have chosen something from the companion-animal columns. But I was delighted to see the FDA there, and pretty darn happy with the progress on this issue so far.
But frankly, we need Congressional action to: 1) Give the FDA mandatory recall authority; and 2) Expand and fund the CDA’s public health role to include food-borne illness in animals. Until that happen — and don’t hold your breath — it’s clear the FDA is trying its best with the hand it was dealt.
Comment by Gina Spadafori — August 1, 2010 @ 7:59 am
I understand Gina, I also wonder sometimes what employees of FDA think or feel when they read negative statements beng made about them or the agency they work for. In some cases it seems they get blamed by the pet food companies as well as pet owners for lots of things, they-can-do-nothing-right catch 22. I have talked and written with the FDA rep for our state. It started with me writing to him none too happy after the 2007 pet food recalls and changed over time as I realized that he too, didnt like the situation but was close to powerless to change anything based on current laws and regs. Its like he said, he also has pets & they are members of his family. Dont get me wrong, I have seen behavior by a couple of FDA employees where they werent as, shall we say receptive, to inquiries as they should have been and their behavior was less than professional but I have seen that in commercial businesses as well as Fed or State agencies. I also wonder what they think when they read claims by pet food companies that certain things are FDA’s fault when that might not be quite accurate. I guess my point is, they are human too, with pets that they love like the rest of us, so I just wonder what they think and feel when they read or hear statements and claims that arent necessarily accurate but they cant really say anything to defend themselves. They are employees that have to deal with the regs/rules that are in place and may not agree with how things are but still have to uphold the way things are as part of their jobs.
Comment by Sandi K — August 1, 2010 @ 8:41 am
Gina, some time when you have more time, I would like to discuss the food safety/small farms/big farms issue with you in more detail. However, let me at least say this from my perspective: My dogs and cats get some commercial pet food supplemented with grass-fed lamb and goat’s milk that I raise here on my small, sustainable farm, where I have raised sheep and goats on pasture since 1983. I can see my flock out grazing in the pasture as I write this. They are moved to new grazing paddocks every couple days. They get green growing pasture most of the summer and a tiny bit of grain added as the nutritional content of the grass starts to wane in late summer. I mostly sell locally and usually take my lambs and kids to a butcher that is only 4 miles from my farm. I am about as far from a CAFO as you are going to find. You are welcome to come and visit and scratch the backs of my friendly goats anytime and I think you would like what you see on my farm. But, while I’m not saying others have to,I also cook any meat I give to my dogs and heat treat the milk —up to 145f, because this is the temp that will kill E.coli and salmonella. Why? Because I have been in slaughter houses, including the custom one where I have known the butcher for years and know that he is exceedingly careful. I have even done it myself when I have had to. Now, don’t get me wrong— I LOVE that you are encouraging folks to buy from your local small farmers. (LoveLoveLoveit!!!) But that won’t solve the problem of these highly adapted bacteria getting around and occasionally getting where they shouldn’t—including, sometimes, our food supply. All the oversight and regulations in the world won’t change that. The CAFOs and our current food systems intensify the problem, for sure. The FDA needs to improve, for sure. But these buggers were here long before the first CAFO and will be around after the last one is bulldozed into the dust. Small farmers have to wear a lot of hats these days—animal nurse, engineer, hydrologist, marketer, tour guide, entrepreneur…..I just can’t be a magician too. Try as hard as we might, we can’t make these bacteria, that have been around for centuries and live where our animals live, just “poof” disappear. As you said in your blog, the onus for safety still lies on the consumer.
Loved the comment by schnauzer that feeding her dogs quality leftovers helped her make healthier food choices. See…dogs are good for us!
Comment by Jan — August 1, 2010 @ 5:15 pm
Maybe some of us would like to submit comments to the FDA about the issue of salmonella in pet food…
FDA Announces Draft Compliance Policy Guide: Salmonella in Animal Feed
August 2, 2010
The Food and Drug Administration has published the Notice of Availability of Draft Compliance Policy Guide Section 690.800 Salmonella in Animal Feed in the Federal Register today. The draft CPG, when finalized, will help guide FDA staff’s regulatory policy relating to animal feed or feed ingredients that are contaminated with Salmonella and that come in direct contact with humans, such as pet food and pet treats.
Interested persons may submit written comments on or before November 1, 2010, to the Division of Dockets Management (HFA-305), FDA, 5630 Fishers Lane, Rm. 1061, Rockville, MD 20852. Electronic comments may be submitted to http://www.regulations.gov. Identify all submissions to the docket with the following docket number: Docket No. FDA-2010-D-0378.
I’m not sure if i know how to insert links here but I’ll try: http://www.fda.gov/AnimalVeter.....220829.htm
Comment by Joy — August 3, 2010 @ 4:14 pm
Joy, nothing would surprise me, I remember being a little surprised that there were no announcements of pet food recalls during the HVP recall.
Comment by Sandi K — August 4, 2010 @ 8:30 am
Late to the post, but thank you, Gina, for going to that seminar. It’s still a very important issue to me.
Can we get an all encompassing consumer protection czar, not just a financial one? ;)
Comment by cb — August 5, 2010 @ 6:56 pm
It’s sad to say but I woke up this morning thinking, it’s Friday…I wonder what recall will be announced this afternoon.
Comment by Joy — August 6, 2010 @ 4:09 am
Personally, I hope they take the week off. Christie’s dealing with a personal issue, and I have an early flight Saturday morning. :(
Comment by Gina Spadafori — August 6, 2010 @ 6:34 am