Ed. Note: This is the first in a continuing series looking at concerns regarding the regulation of household pet foods and concerns about what we’re feeding our pets.

In interviews with a local veterinarian, FDA experts and animal care professionals, KHTS discussed pet food regulations, KHTS discusses how pet owners can purchase safe food for their animals.

What are the ways that pet-owners can know what they’re buying?

There are ways that pet-owners can identify what exactly is in the food they purchase for their pets.

The product name can be a key factor in the consumer’s decision to buy the product. For these reasons, the Association of American Feed Control Officials (AAFCO) has a set of guidelines for how companies display and market their product.

One of these rules to look out for is the “95 percent” rule which applies to food with few ingredients. For instance, if a pet food is labeled “Beef for Dogs” then the product must consist of 95 percent beef. A good way to ensure that your product is as advertised, check that the ingredient lists are declared in the proper order of predominance by weight. Therefore in “Beef for Dogs,” the “beef” should be the first ingredient listed.

Are there ways for pet owners to know if the food they’ve purchased is safe before they give it to their animal?

Unfortunately, chemicals such as pentobarbital, a chemical which has been studied by the FDA in the 90’s and yet still causes harm to animals,  are hard to detect when you’re pouring the food for your dog. However, there are multiple practices a pet-owner can do to better ensure that pet food is safe.

“It’s really a matter of it smells normal, or if it smells rancid. Also, make sure to check the expiration date,” said Dr. Jeanette Yamamoto, a Santa Clarita general practice veterinarian and owner of Peaceful Pets. “A good rule of thumb is to do the typical things we would do to check freshness of [human] food.”

Dr. Yamamoto also stated that the AAFCO certification should not only be checked for when buying food, but should also be double-checked when you are about to feed your animal.

“There are so many jo-shmos putting out food and they can say is healthy. But the AAFCO certification [on the food container] is a good way to make sure that the food has been properly tested.”

Is the AAFCO certification always reliable? Are there safe brands that people should stick to?

The AAFCO certification is not always reliable.

“AAFCO certification food has had contamination in the past.  The reality is that there is always a chance of there being something in the food,” said Dr. Yamamoto.

However, there are brands out there that have a good track record in terms of catching adulterated food.

“I recommend food brands such as California Natural, Wellness, and Iams. The key when I am to talking to clients is that I don’t care how good you think your food is, if it doesn’t work well with your pet then it’s not great for your animal,” said Yamamoto.

Our next story in a continuing series will look at the regulation that allows pentobarbital into pet food, and how pet owners can keep their pets safe.

Here was the first story in the series: Update: Lacking Regulation, Poisoned Dog Food Prompts Alarm From Pet Owners

In response to questions posed by KHTS regarding this series, the FDA gave responses to inquiries regarding their policies and regulations regarding the pet-food industry.

Q: How does the FDA believe pentobarbital has surfaced not only this time, but in February of this year with Evanger’s Dog Food?

A: This is an ongoing investigation and we are actively working with FDA field offices as well as other state, local, and federal partners to look at every angle, but do not have information to share at this time.  In general, this kind of investigation may take time because of the significant amount of information that needs to be both collected and carefully reviewed and often a follow-up inspection or investigation may take place often involving several FDA field and headquarters offices, and other federal or state agencies.

Q: The FDA released a statement in 2002 saying that you were aware that “the most likely way it could get into dog food would be in rendered animal products.” Is this still true?
(https://www.fda.gov/aboutfda/centersoffices/officeoffoods/cvm/cvmfoiaelectronicreadingroom/ucm129131.htm)

A: The FDA found in its 1998 study that there appeared at that time to be associations between rendered or hydrolyzed ingredients and the presence of pentobarbital in the dog food tested. It is the responsibility of the salvage facility collecting livestock to determine how they died and to separate animals suitable for animal food use from animals that are not.

Pentobarbital residues are not affected by rendering or canning temperatures and pressures (such as heat treatments capable of killing pathogenic organisms), and therefore animals euthanized with pentobarbital cannot be used in the manufacture of animal food, including pet foods. There is currently no set tolerance (maximum allowed level) for pentobarbital in animal food and detection of its presence would render an animal food product adulterated.

Pet food manufacturers must ensure that the food they produce is safe for consumption and properly labeled. One way that a manufacturer can do this is by taking steps to verify the identity and safety of the ingredients they receive from their suppliers.

Q: Why does this problem persist if the FDA knew about it nearly 15 years ago?

A: There is currently no set tolerance for pentobarbital in animal food and its detection would render an animal food product adulterated. It is the responsibility of the company manufacturing the pet food to ensure that the product is not adulterated.

Nineteen years ago, the FDA collected certain dry dog food samples to determine whether the products contained pentobarbital. The sampling was not representative of the entire pet food market because the sample collectors specifically sought out dry dog foods with certain animal-derived ingredients. The sampling method and the age of the data generated by the survey means that the data cannot be used to draw inferences about dog food being produced and sold in the U.S. today.

The FDA published its 1998 study partially to improve industry awareness of the potential for pentobarbital to be an adulterant in pet food. We believe that the industry as a whole has acted to improve oversight of their suppliers and ingredients and ensure that they are marketing products that are in compliance with FDA regulations.

Q: What has the FDA done to curb the presence of pentobarbital in dog food?

A: Pet food manufacturers must ensure that the food they produce is safe for consumption and properly labeled. One way that a manufacturer can do this is by taking steps to verify the identity and safety of the ingredients they receive from their suppliers. Pet food manufacturers that source ingredients from a salvage facility should use a facility that is able to determine how the salvaged livestock died and that appropriately segregates the resulting materials.
Specific regulations governing the production of safe animal food exist: most animal food manufacturers are subject to the Preventive Controls for Animal Food final rule, which resulted from the FDA Food Safety Modernization Act. This rule established Current Good Manufacturing Practice (CGMP) requirements that apply to the manufacturing, processing, packing, and holding of animal food. It also requires facilities to develop and implement a food safety plan, including performing an analysis of hazards and determining if there are hazards requiring a preventive control. A facility would implement preventive controls to significantly minimize or prevent those hazards. If a preventive control is in place, it must be monitored by the firm and corrective action would have to be taken in the event of a problem with the preventive control.

Preventive Controls for Animal Food rule compliance dates for food facilities vary according to business size. The first set of facilities are required to comply with the food safety plan provisions by September 2017. Facilities that are considered a “small business” must comply with the food safety plan provisions by September 2018. Facilities that are considered a “very small business” must comply with certain limited food safety provisions by September 2019. In addition, in August 2016, the FDA released draft guidance on Current Good Manufacturing Practice requirements for food for animals. This draft guidance is intended to help manufacturers comply with the Current Good Manufacturing Practice requirements of the  Preventive Controls for Animal Food final rule published on September 17, 2015. Large companies were required to comply with these new CGMP requirements by Sept. 19, 2016. Companies that are considered small businesses must comply by September 18, 2017, and very small businesses must comply by September 17, 2018.

With regard to the two manufacturers that found pentobarbital in their products, the FDA worked with Evanger’s to conduct two voluntary recalls on Feb. 13 and 20. (More information can be found here: https://www.fda.gov/animalveterinary/newsevents/cvmupdates/ucm542265.htm). Here is the FDA Form 483 (inspection report): https://www.fda.gov/downloads/aboutfda/centersoffices/officeofglobalregulatoryoperationsandpolicy/ora/oraelectronicreadingroom/ucm542050.pdf.

In addition, the FDA is aware of Party Animal’s voluntary recall for these products (see link here: https://www.fda.gov/Safety/Recalls/ucm554771.htm). The agency has received test results for the products at issue and is following up.

Q: I have it on background that pentobarbital levels would be far too low to have registered on a lab test if the only pentobarbital that was present was what was left after being turned into “feed product”. To register that high of a level, the animals would have to be used directly in the pet food itself. Meaning that there is euthanized animal meat directly within the food. Can you confirm or deny this?

A: Due to the nature of “chunk beef” products, meat from various animals can be irregularly distributed throughout the lot of food. This means that some cans could contain meat from only one animal, while others can might contain some meat from that animal, and others none at all. If meat from a euthanized animal is used, it could end up in some cans, but not others, and in varying amounts.

Q: According to a study the FDA did after a food survey in 2000, they stated that dog and cat meat was not present in dog foods. Is this still true? When was the most recent study?

A: During the 1990s, FDA’s Center for Veterinary Medicine (CVM) received reports from veterinarians that pentobarbital, an anesthetizing agent used for dogs and other animals, seemed to be losing its effectiveness in dogs. Based on these reports, CVM officials decided to investigate a plausible theory that the dogs were exposed to pentobarbital through dog food, and that this exposure was making them less responsive to pentobarbital when it was used as a drug.

The investigation consisted of two parts. First, CVM had to determine if dog food could contain residues of the drug. Second, if residues were found, CVM had to determine what risk, if any, the residues posed to dogs.
In conjunction with this investigation, CVM wanted to determine if pet food contained rendered remains of dogs and cats. CVM scientists, as part of their investigation, developed a test to detect dog and cat DNA in the protein of dog food and incorporated this test into the 1998 study. All samples from the most recent dog food survey (2000) that tested positive for pentobarbital, as well as a subset of samples that tested negative, were examined for the presence of remains derived from dogs or cats. The results demonstrated a complete absence of material that would have been derived from euthanized dogs or cats. It was assumed that the pentobarbital residues were entering pet foods from euthanized, rendered cattle or even horses.

As part of the investigation into Evanger’s, the FDA asked USDA’s Food Safety and Inspection Service (FSIS) to test samples of Evanger’s Hunk of Beef to determine whether the meat in the product was beef. Testing by USDA-FSIS of Evanger’s Hunk of Beef confirmed that the meat used in the product was bovine (beef). Trace amounts of pork and equine were also found, but both were less than 2% and therefore considered by FSIS as ‘not reportable.’