FDA’s Raw Pet Food Phobia – Truth about Pet Food

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A not so clinical (but evidenced) diagnosis: the FDA suffers from raw pet food phobia.

In the late afternoon on Friday February 14, 2020 the FDA issued another warning to pet owners about a raw pet food.

These FDA consumer warnings on raw pet food have become quite common. Since May 16, 2016 the FDA has issued 18 consumer alerts regarding pet products. Nine of those alerts – or 50% – were regarding raw pet food. Another vital statistic that needs to be considered is that raw pet food only consists of “about 1.3 percent of all sales” (all pet food sales).

So…why would 50% of all FDA pet product consumer warnings be specific to ONLY 1.3% of the pet food market?

The FDA’s attitude is that raw pet food is dangerous; the Agency’s main concern with raw pet food is pathogenic bacteria such as Salmonella. The FDA’s opinion is that these consumer warnings validate their concern of raw pet food (‘see, we told you it’s dangerous’). But, do the warnings and FDA scrutiny of raw pet food validate a legitimate concern or instead, does the action of FDA confirm the Agency’s deep, irrational fear (phobia) of raw pet food?

There is no evidence that confirms FDA’s belief raw pet food is more dangerous than other styles of pet food. In fact, the evidence indicates that overall – raw pet food is LESS of a risk than meat purchased in your grocery.

The USDA (regulatory authority over raw meat) allows 25% of all ground poultry products sold in your grocery to be contaminated with Salmonella. An FDA study of raw pet food found only 8% of samples were positive for Salmonella. In other words, millions of human food consumers that shop for meat are 3 times more likely to be exposed to Salmonella than 1.3% of pet owning consumers that purchase raw pet food.

The FDA attempts to validate their raw pet food fear by stating “animals can shed the bacteria in the feces when they have bowel movements“; this statement was included in several of the raw pet food warnings including the most recent. However, the study FDA bases this raw fed dog poop irrational fear on found that ONLY 2.5% of dogs and LESS THAN 1% of cats shed Salmonella in their poop. This means that every day – millions of human food consumers shopping for meat in your grocery are 10 times more likely to be exposed to Salmonella than dog owners picking up their pet’s poop, and 25 times more likely to be exposed to Salmonella than a cat owner cleaning the litter box.

To further validate the FDA suffers from raw pet food phobia, is the statistical evidence of pet food recalls since 2012. Taken from FDA Enforcement Report records:

Based on historical recall records, kibble is 75 times more likely to be contaminated with Salmonella than raw pet food, kibble is three times more likely to be contaminated with Salmonella than raw meat purchased in your grocery.

As further evidence that FDA suffers from an irrational fear of raw pet food: the Agency has repeatedly manipulated inspections and testing procedures to validate their phobia. Multiple raw pet food companies – which recalled their products or FDA issued a warning about – were denied access to required documents and split samples (including the most recent pet food FDA issued a warning about).

From the FDA document Food/Feed Testing Laboratories Best Practices Manual, under Chapter 4 Sampling, Best Practices it states:

“Sampling often begins with routine collections for surveillance purposes, food safety inspections, monitoring studies or as a response to a complaint. Samples collected may include investigative, documentary, emergency response, law enforcement, research or convenience samples. If there is any possibility of future regulatory action, official samples should be collected in a manner that will assure legal defensibility. The essential characteristics of a valid, official sample include ensuring that the sample contains a representative portion of the lot, sampled in a manner that assures it is not changed in its physical, chemical or biological nature from the whole. In addition, the sample should be collected, preserved and handled in a manner consistent with the intended testing. Also, any required sample reserve portions should be collected and the sample should be accompanied by accurate records that legally establish its identity, responsible individuals and chain of custody.”

In MANY cases – including the raw pet food FDA just issued a warning about – the above sampling procedures were not followed. Chain of custody documents – required by regulation to be provided to the pet food manufacturer – have been denied time and time again. Split samples (“sample reserve portions“) have been refused to be provided to the raw pet food manufacturer. And in at least one case (Rad Cat), we know that the sample was NOT preserved or handled to assure sample integrity (the raw pet food was transported to the lab on the seat of a car in July).

The unfortunate consequences of FDA’s irrational fear of raw pet food is an unknown number of other issues in pet food are being ignored. The FDA spent three quarters of a million dollars ($758,000.00) just to test raw pet food in 2015. Yet the Agency tells the public they don’t have the funding to properly enforce law in pet food; “Why doesn’t FDA enforce every violation of the law? Due to competing priorities and resource limitations, government agencies cannot act against every violation of the law.” While FDA spends three quarters of a million dollars to test 1.3% of the pet food market, they ignore the risks of illegal ingredients sourced from diseased animals and animals that died other than by slaughter used in perhaps 80% or more pet products.

Let’s hope the FDA seeks treatment for their raw pet food phobia.

Wishing you and your pet(s) the best,

Susan Thixton
Pet Food Safety Advocate
Author Buyer Beware, Co-Author Dinner PAWsible
TruthaboutPetFood.com
Association for Truth in Pet Food

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