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FDA Shuts Down Bravo Packing (not Bravo Pet Food) – Truth about Pet Food

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FDA issued a statement today (March 28, 2022) that Bravo Packing pet food (not affiliated with Bravo Pet Food) will no longer sell or distribute pet food – at least until the company comes “into compliance with the Federal Food, Drug, and Cosmetic Act (FD&C Act).”

Bravo Packing had been issued a Warning Letter by FDA in 2020, citing dangerous conditions including “heavy buildup of dried, dark, crusty meat-like material” on pet food processing equipment.

Bravo Packing recalled pet foods in September 2018 and again in March 2021.

This pet food company is also a dead animal hauler, for years they have been questioned about animal cruelty issues.

The FDA press release stated: “The FDA has taken this action to protect public health because, despite multiple inspections, notifications of violations, and recalls, this firm continued to operate under insanitary conditions and produce pet food contaminated with harmful bacteria. We will not tolerate firms that put people or animals at risk and will take enforcement actions when needed.”

The FDA’s concern with Bravo Packing was insanitary manufacturing conditions and pathogenic bacteria in the pet food. We agree that these issues are serious and FDA took appropriate action with Bravo Packing. However…

…the FDA took no action against another pet food manufacturer that was also found to produce pet food under insanitary conditions. In 2016 and in 2017 the FDA inspected the Mars Petcare facility in Columbus, Ohio. This Mars pet food plant had a significant problem with “German cockroach infestation” that was present in the 2016 inspection AND the 2017 inspection. The 2017 FDA inspection report of this Mars Petcare facility cited “millions of roaches” stating: “The failure to take adequate measure to exclude and prevent pests from the manufacturing and related areas of the firm poses a significant public health safety concern while also being a regulatory violation.” Unlike the action FDA took with Bravo Packing, FDA did absolutely nothing with Mars Petcare. No consent decree was issued to stop production of pet food, no Warning Letter was issued. In the case of Mars Petcare, FDA just looked the other way.

Dr. Steven Solomon (director FDA CVM) stated in the press release regarding Bravo Packing: “The food we give our pets should be safe for them to eat and safe for people to handle”.

The very same Dr. Steven Solomon stated this to TruthaboutPetFood.com in response to our Citizen Petition: “we do not believe that the use of diseased animals or animals that died otherwise than by slaughter to make animal food poses a safety concern and we intend to continue to exercise enforcement discretion where appropriate.”

It’s very difficult to understand how these words can come from the same person. How can the veterinarian director of FDA Center for Veterinary Medicine have concern for safe pet food in one moment, while in another moment state diseased animals as pet food ingredients are safe?

The FDA told Bravo Packing they cannot manufacture or distribute pet food until they come “into compliance with the Federal Food, Drug, and Cosmetic Act (FD&C Act)“. This is good news. But…

…what about all the other pet food companies that use ingredients that violate the Federal Food Drug and Cosmetic Act? FDA allowing pet food to source ingredients from “diseased animals or animals that died otherwise than by slaughter” is a direct violation of the Federal Food Drug and Cosmetic Act. How can FDA allow law to be violated by some pet food manufacturers while enforcing the VERY SAME LAWS on others?

Definition of hypocrisy: “a pretense of having a virtuous character, moral or religious beliefs or principles, etc., that one does not really possess; a pretense of having some desirable or publicly approved attitude.”

My letter to Dr. Steven Solomon sent 3/28/22…

FDA’s Anne Norris sent me notice of the consent decree action FDA took against Bravo Packing. I would like to thank FDA for taking action against this pet food manufacturer.

However, FDA’s action with Bravo Packing brings up serious inconsistencies with your agency’s enforcement of law. Such as, how can FDA demand Bravo Packing to come “into compliance with the Federal Food, Drug, and Cosmetic Act (FD&C Act)” while at the same time allowing other pet food manufacturers to violate the very same federal laws with no warning or disclosure to pet owners. I remind you of your response to our Citizen Petition: “we do not believe that the use of diseased animals or animals that died otherwise than by slaughter to make animal food poses a safety concern and we intend to continue to exercise enforcement discretion where appropriate.” As you are aware, The Federal Food, Drug, and Cosmetic Act prohibits the use of diseased animals or animals that have died otherwise than by slaughter in any food – including pet food. The FDA stated “we do not believe…” these illegal ingredients pose a safety concern, however the agency has not provided any scientific evidence to validate their belief.

The FDA’s press release regarding the consent decree action against Bravo Packing stated “this firm continued to operate under insanitary conditions“. We are aware of at least one other firm that continued to operate under insanitary conditions that the FDA took no action on – the Mars Petcare facility in Columbus, Ohio. For two years in a row, FDA inspection of the plant found insanitary conditions that posed a significant risk. The FDA inspection report from 2017 stated: “Failure to take effective measures to exclude pests from your plant and protect against contamination of animal food by pests (Discussion Item from 10/27/2016 EI).” The FDA inspection report of this Mars Petcare facility also stated: “The failure to take adequate measure to exclude and prevent pests from the manufacturing and related areas of the firm poses a significant public health safety concern while also being a regulatory violation.” Even though repeated inspections found violations at this pet food plant, the FDA did not seek a consent decree to force Mars Petcare to abide by the FD&C Act – the FDA did not even issue a Warning Letter to this manufacturer.

With all due respect Dr. Solomon, isn’t this hypocritical? Pet food consumers have a very valid concern that FDA’s selective enforcement of law could be directly linked to the largest manufacturers of pet food and the largest ingredient suppliers. What else can pet owners believe based on FDA’s actions?

There is no question, Bravo Packing should come into compliance with the FD&C Act. But so should every other pet food manufacturer.

Pet food consumers are requesting via this email for the FDA to explain why the agency continues to allow diseased animals and animals that have died other than by slaughter in pet food with no disclosure on the label in order for consumers to make informed purchasing decisions. We request FDA to publicly provide the science they based their belief this illegal material is safe in pet food. We request a public discussion on the issue, for consumers to provide FDA their input. As FDA regularly meets with industry, we request the same discussion opportunity for pet owners. We also request an explanation to FDA rationale of when and why law is enforced in some instances or not enforced in other instances.

We await your response to our questions, and await further instructions on scheduling for a public meeting with pet owners.

Representing pet food consumers,

Susan Thixton

Should pet owners wish to email FDA – feel free to use any part of my letter to Dr. Solomon. If you agree, please ask them to hold a public meeting where pet owners can provide FDA input. Also please ask them to explain why illegal ingredients are allowed in pet food with no disclosure to consumers. Emails can be sent to AskCVM@fda.hhs.gov.

If Dr. Solomon responds to my questions, it will be shared on this website.

In no uncertain terms, the FDA took proper action against Bravo Packing. Where they fail miserably is uniform enforcement of law across all pet food brands.

Wishing you and your pet the best –

Susan Thixton
Pet Food Safety Advocate
TruthaboutPetFood.com
Association for Truth in Pet Food

Become a member of our pet food consumer Association. Association for Truth in Pet Food is a a stakeholder organization representing the voice of pet food consumers at AAFCO and with FDA. Your membership helps representatives attend meetings and voice consumer concerns with regulatory authorities. Click Here to learn more.

What’s in Your Pet’s Food?
Is your dog or cat eating risk ingredients?  Chinese imports? Petsumer Report tells the ‘rest of the story’ on over 5,000 cat foods, dog foods, and pet treats. 30 Day Satisfaction Guarantee. Click Here to preview Petsumer Report. www.PetsumerReport.com

Find Healthy Pet Foods in Your Area Click Here

The 2022 List
Susan’s List of trusted pet foods. Click Here to learn more.

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