Sunday, August 8, 2010

FDA Focus On Pet Products Stimulates Rash of Recalls

National targeted sampling program uncovers Salmonella-contaminated pet products

There have been an unusual number of Salmonella-related pet product recalls this year – so many, that one of my readers asked me whether leftover hydrolyzed vegetable protein (recalled earlier this year by Basic Food Flavors) might be behind the spate of pet food, pet treat and pet supplement recalls.

The theory is seductive. Hydrolyzed vegetable protein (HVP) is used as a flavoring agent, and likely would be sprayed over the kibble at the last stage of manufacture – after the cooking steps. Any Salmonella that was present in the HVP would be transferred to the kibble.

In fact, Response Products, the manufacturer of Advanced Cetyl M Joint Action Formula for Dogs, recalled two production batches of their joint supplement in April 2010 for exactly this reason. According to their recall notice, the beef vegetable flavoring used in lot numbers 1210903 and 0128010 contained a "... hydrolyzed vegetable protein component provided by Basic Foods of Las Vegas, NV" and was at risk of being contaminated with Salmonella.

In addition to Response Products, the following pet product manufacturers have announced Salmonella-related recalls since October 1, 2009:
  • Pet Carousel (Sanger, CA), December 9th: All Pig Ears and all varieties of Beef Hoof pet treats
  • Natural Balance Pet Foods, Inc. (Pacoima, CA), June 18th: Natural Balance Sweet Potato & Chicken Dry Dog Food with the "Best By" date of June 17, 2011, in 5-lb. and 28-lb. bags
  • United Pet Group (Cincinnati, OH), June 22th: All unexpired lots of its PRO-PET Adult Daily Vitamin Supplement tablets for Dogs
  • Feline's Pride (Buffalo, NY), July 1st: Feline’s Pride Raw food with ground bone for cats and kittens, Natural Chicken Formula, Net Wt. 2.5 lbs. (1.13 kg., 40 oz.) produced on 6/10/10.
  • Merrick Pet Care, Inc. (Amarillo, TX), July 2nd: Beef Filet Squares for Dogs pet treats (10 oz., Item #60016; Lot #10084TL7; Best by March 24, 2012)
  • United Pet Group (Cincinnati, OH), July 2nd: Earlier recall expanded to include additional pet nutritional supplement products for dogs and cats.
  • Feline's Pride (Buffalo, NY), July 15th: Earlier recall expanded to include the product produced on 6/21/10.
  • The Procter & Gamble Company (Cincinnati, OH), July 25th: Two specific lots of Iams Veterinary Formulas Feline Renal, 5.5 lbs, sold in veterinary clinics.
  • The Procter & Gamble Company (Cincinnati, OH), July 30th: Earlier recall expanded to include additional veterinary foods and some specialized dry pet food sold by retailers.
  • Merrick Pet Care, Inc. (Amarillo, TX), August 3rd: Earlier recall expanded to include Texas Hold'ems (Item #60016; Lot #10127; Best by May 6, 2012)

Last week, in an effort to find out the reason behind this unusual number of pet product recalls, I emailed FDA, Procter & Gamble, Natural Balance, United Pet Group, and Merrick Pet Care. I asked each of the pet product manufacturers whether they had used HVP, whether the Salmonella was detected due to their own internal sampling or as a result of FDA activity, and what specific Salmonella serotype was found in their product and/or manufacturing environment. I asked FDA whether the agency had any special pet product surveillance or sampling program in force this year, and whether the Salmonella found in the pet products matched the genetic profile of any of the Salmonella strains found during the Basic Food Flavors (HVP) investigation. Here's what happened.
  1. Procter & Gamble: "In conjunction with the FDA, we are still investigating and therefore cannot provide further information at this time," replied Jason Taylor, of P&G Pet Care External Relations.
  2. Natural Balance: "Please know that all information regarding the voluntary recall is available on our website," wrote Kristi Choy, Customer Service Manager, Animal Nutrition.
  3. United Pet Group: No reply.
  4. Merrick Pet Care: No reply.

The Natural Balance website makes it clear that its recall was triggered by FDA random sampling. Merrick's recall notice also refers to FDA surveillance sampling. The United Pet Group notice simply mentions laboratory testing.

As for FDA, Shannon Cameron, an FDA Health Communications Specialist, pointed me to a current surveillance program, FY 2010 Nationwide Assignment to Collect and Analyze Samples of Direct-Human-Contact Feeds for Salmonella. This program, which began in October 2009, has four objectives:
  1. To determine the prevalence of Salmonella in samples collected from a limited number of direct-human-contact feeds nationwide.
  2. To determine the serotype, genetic fingerprint, and/or antimicrobial susceptibilities of each Salmonella found in samples collected from direct-human-contact feeds under this assignment.
  3. To ensure that direct-human-contact feeds contaminated with Salmonella are removed from interstate commerce.
  4. To collect investigational samples for research purposes and for providing surveillance information on microbes other than Salmonella in animal feeds.

And, here is how FDA handles positive results – whether in pet foods or other forms of animal feeds – under this surveillance program:
"For each direct-human-contact feed sample found to contain Salmonella, districts should initiate procedures to remove the contaminated feed from interstate commerce, inform the responsible firm of the need to initiate corrective action to prevent future contamination, and recommend the issuance of a Warning Letter. In addition, within 90 days of being informed by the laboratory of the finding of Salmonella in a feed sample, districts should conduct follow-up investigations of the facility or facilities where the violative sample was manufactured to review manufacturing and handling procedures, document what corrections, if any, were made, and collect follow-up samples."

As for the possible connection between Salmonella strains recovered from HVP and those found in the pet product samples, Ms. Cameron wrote, "We do not have that data readily available, so a FOIA request would need to be submitted." FOIA stands for Freedom of Information Act.

The Bottom Line?
Most pet foods contain ingredients such as poultry meal – ingredients that have a high probability of being contaminated with Salmonella. Unless a manufacturer is paying careful attention to air flow in its plant environment, fine powders can be spread throughout the manufacturing plant, carrying the Salmonella along with it.

This problem is not specific to pet products. Any company that deals with finely powdered ingredients must deal with airborne dust. The problem is especially critical when the powdered ingredients are at high risk of containing Salmonella.

I'm not surprised that FDA is finding Salmonella in the occasional pet product sample. I hope that the agency continues this program into the future.

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  1. Thanks Phyllis for keeping on top of this issue. I'm trying to get pet food companies to have a "recalls & alerts" sign-up on their websites and to notify all their customers within 24 hrs of knowing they have a problem. It ain't working that way at the present time.

  2. @Sandi

    It ain't working that way for human food either!


  3. Isn't that "surveillance program" referring to FDA Program # 7371.003 (Feed Contaminants Program) which, was implemented in December 2005 with an expected completion date of 9/30/2010?

  4. @Anonymous

    For those who are interested, here is a link to FDA Program #7371.003 (Feed Contaminants Program):

    This year's surveillance of "direct human contact" animal feeds might very well fall under that multi-year compliance program. It's notable, though, that the focus of this year's program is very specifically on Salmonella in pet food/treat/supplements, as opposed to the multi-year program, which covers the entire range of animal feeds and looks for mycotoxins and various chemical contaminants in addition to Salmonella and E. coli O157:H7.


  5. In case you can't find the info, I just meant to point out that the FDA/FCP had this exact assignment for 2006-2007 as well. So, they've been testing for salmonella in this manner for at least the past 4 years.

  6. Hi Phyllis. True, the 2006-2007 assignment is different but only in that it included E. Coli as well as Salmonella. The assignment was called "Nationwide Assignment to Collect Samples of Direct-Human-Contact Feeds and Analyze Them for Salmonella and E. coli" and focused specifically on direct-human-contact feeds (pet food, treats, pre-mixes, ingredients, etc).

  7. @JoyD

    Hi Joy. I found the previous years' assignments and have sent a message to my FDA contact asking if she can provide a summary of the results of these surveillance actions.

    I'll report back the outcome of that query.

    Thanks for your research.

  8. Thanks Phyllis. It would be great if those results were available.

    Also, I've been posting on other forums for a while now about my HVP theory; more so than all the other possibilities, I really do think HVP is the culprit with these latest pet product recalls. I could be wrong but it just seems to me it has to be a very common and shared ingredient rather than a sudden increase in dirty manufacturing facilities or even the reporting of those.

    I started to wonder about this when I noticed that several of the recalling manufacturers for human foods that purchased HVP from Basic Food Flavors, Inc. are also involved in the manufacture of the same or similar products for the pet food industry. One in particular manufactures soy products for both human and pet foods within the same facility. Since they are essentially the same product, it's hard to imagine this salmonella-tainted HVP could have affected their human food products but not the products they sold to pet food makers.

    Then today, reading the news, it looks like the CDC is in fact saying that the salmonella in pet food responsible for the 2006-2008 outbreak was likely from a contaminated palatant.

    The article says the salmonella was found in the flavoring room of the pet food manufacturing plant and that contamination likely occurred "when food pellets were sprayed with flavor enhancers."

  9. @JoyD

    You make an interesting point. I have requested a full copy of the article from CDC.


  10. Check out what Fox News aired:

    Dog Food Could Be Making Kids Sick, Report Says,2933,598842,00.html

  11. @Sandi

    The Fox story relates to the Mars Petcare recalls and Salmonella outbreak from a couple of years ago. I have requested a full copy of the report from CDC.



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