Unusual (But Typical) FDA Warning Letter To A Raw Pet Food – Truth about Pet Food

The FDA issued a Warning Letter to OC Raw Pet Food on February 23, 2022. Some very strange things were included and not included in the FDA warning. And…the warning itself appears to be minor issues that don’t seem to warrant an official Warning Letter.

Transparency notice: OC Raw pet food is a brand that is included on the 2022 List. This FDA Warning Letter does not change my personal opinion on the brand, it remains a brand I would trust to give my own pets. I have spoken with OC Raw, and learned a few other things not mentioned in the FDA letter.

The first strange issue of the Warning Letter was FDA stating they inspected this very small pet food plant “from April 16, 2021 through May 26, 2021“. If the FDA was not working on weekends, this means the FDA was inspecting this raw pet food manufacturer for 29 days. But…OC Raw told me the FDA was at their plant from “March 31, 2021 through May 26, 2021” – a total of 41 business days.

OC Raw is a very small manufacturer. By comparison – below are Google Earth images of the OC Raw plant next to the Hill’s plant that was responsible for manufacturing the excess vitamin D pet foods recalled in early 2019.

And as comparison, the FDA performed an inspection at the above Hill’s manufacturing facility after their deadly excess vitamin D recall from “February 1 through February 19, 2019 and March 25 through 27, 2019” – only 16 days in total.

Why did FDA spend so much time – almost triple the days at a raw pet food plant than it did at a feed grade pet food plant responsible for serious illnesses and deaths of pets?

The next very strange thing in this Warning Letter is this quote:

“This inspection was conducted in response to a Class I recall initiated on (b)(4) of (b)(4), lot number (b)(4), due to the presence of Salmonella and Listeria monocytogenes (L. mono) detected by the (b)(4).”

FDA redacted the recall dates in this warning. Why? Recall notices are required to be public information. Typically only private company information is redacted by FDA.

To compare to typical FDA Warning Letters, the agency included the recall date in the Hill’s Warning Letter linked above and FDA included the recall date in the Midwestern Pet Food Warning Letter.

So why did the FDA redact the recall date in the OC Raw Warning Letter? The reason could be the recall from OC Raw FDA referenced in the Warning Letter occurred almost four years ago – April 2018.

The next issue is: this warning letter also points out that FDA performed “one hundred (100)” swabs in the manufacturing area for “environmental pathogens“. OC Raw told me the FDA took “180 swabs“.

The FDA warning stated they found “Listeria innocua” in multiple samples and “Listeria grayii” in multiple samples. Even though the FDA made a big deal of these two “environmental pathogens” – they are actually non-pathogenic bacteria. Research found on ScienceDirect.com states “Listeria innocua, the most commonly isolated specie is non-pathogenic as is also generally true for L. welshimeri, L. grayi, L. marthii, and L. rocourtiae.”

Why did the FDA take issue with a non-pathogenic bacteria? Was it necessary for FDA to even mention non-pathogenic bacteria or was FDA trying to make another raw pet food look bad knowing that most pet owners wouldn’t know these were non-pathogenic bacteria? Was their intent to scare pet owners?

Personal opinion: Perhaps it is my bad attitude towards FDA’s selective enforcement of law talking, but this warning letter appeared to be FDA grasping at straws – trying to find something…anything they could to draw negative attention to this pet food manufacturer. To perform a 41 day inspection at a tiny manufacturing plant that is responsible for no pet deaths, while only spending 16 days at a large Hill’s plant that was responsible for hundreds of pet deaths is blatantly biased. To classify non-pathogenic bacteria as “environmental pathogens“, to redact recall dates confirms FDA bias against raw pet food.

I encourage all pet owners – regardless to what style of pet food you provide your pet – to demand FDA stop their selective enforcement of law. Pet food should be regulated uniformly across all styles. FDA’s bias against raw pet food and FDA’s free pass to many feed grade pet products must stop. Please email the agency at: AskCVM@fda.hhs.gov.

Wishing you and your pet the best –

Susan Thixton
Pet Food Safety Advocate
TruthaboutPetFood.com
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