Over the last few months, there have been a significant number of voluntary recalls in the raw pet food market, involving some of the best known and largest brands (Nature’s Variety, Bravo and Stella and Chewy’s to name but a few). According to http://www.dogfoodadvisor.com there were in fact eight such recalls in the month of July 2015 alone – nearly the same as for the whole of 2014. The reasons for the recalls were the suspected or actual contamination of raw pet food by pathogens such as Listeria and Salmonella.
Those who are familiar with this blog will know that pathogens are all around us, and not limited to just raw meat. Fruit and vegetables, soil, and dairy products can all contain potentially harmful bacteria – but we never see any recalls for any of these products. So why all of a sudden does there appear to be a concentration of recalls in the pet food market?
The answer to this question is largely due to a change in policy by the FDA – the Food and Drug Administration. The FDA in its wisdom has announced that it will begin considering any pet food contaminated with pathogens to be “adulterated” and therefore illegal to sell. This policy is regardless of the type of pet food or pathogen. For those unclear, the dictionary definition of “pathogen” is as follows: ‘A pathogen (or infectious agent) is a biological agent that causes disease or illness to its host.’ So whilst some strains of bacteria such as E.coli are potentially harmful to humans, some strains are not – indeed, some are positively beneficial and are used every day to create cheese, yoghurt and so on.
The problem with the introduction of this policy is that is clashes considerably with that of the FSIS – the Food Safety Inspection Service. According to the current FSIS policy, raw animal products such as beef or poultry are not deemed adulterated (that is, contaminated with harmful bacteria) even if they contain Listeria, E.coli or Salmonella. That position, however, changes once the meat has been processed. Therefore whilst beef containing E.coli is not considered adulterated, and can be legally sold, once it has been ground up, the status of that beef changes and it becomes illegal to sell.
The new FDA policy will apply to all raw pet food, processed and unprocessed. This has some major implications for not only those who produce or buy raw pet foods but also the non-pet owning consumer in the average grocery store.
For example, under the FSIS, it is perfectly legal to sell a joint of meat contaminated with E.coli, Listeria or Salmonella, if that meat is to be cooked and fed to your family. However, as soon as that same piece of meat is labelled as “Pet Food”, according to the FDA it becomes illegal to sell it.
Consider the following examples:
- you are sold a beef steak which is contaminated with naturally occurring pathogens, and feed it to your family. If you cooked it before serving it up, you will have destroyed any harmful bacteria and it will be perfectly safe to eat. In accordance with FSIS policy, nothing illegal will have taken place.
- if you give a piece of that same contaminated steak, uncooked, to your dog, according to the FDA this means the original seller has committed an offense – even if your dog has no adverse reaction.
As a direct consequence of the conflicting nature of the FDA and FSIS’s policies, this will presumably lead to the somewhat absurd situation where your local butcher is now under an obligation to enquire whether the meat he sells you is for you to eat, or for your pet. If you tell him that the steak in your hand will be used to make your own raw dog food, he will commit an offense, according to the FDA, if he proceeds to sell it you.
The FDA’s policy will either turn all raw feeders in to liars, or will give rise to some sort of rebel black market where meat destined for our pets will have to be purchased in dark alleys or slipped in to our grocery bags with a nod and a wink from an understanding butcher.
The full, ludicrous, nature of such a policy is revealed when one considers other posts elsewhere in this blog which deal in detail with the fact that dogs are different to humans, and have built in defenses which allow them to ingest bacteria which would be harmful to us. Humans have evolved over centuries to the stage where we cannot safely ingest most raw meats due to the naturally occurring pathogens they contain, which can at best be merely unpleasant and at worst down right deadly. Our pets may be domesticated, but they are still animals – and evolution is a wonderful thing, but excruciatingly slow. A change in our dog’s digestive system and physiology rendering him or her unable to cope with raw meat and the bacteria it contains would take many, many centuries – far more time in fact than has passed since the invention of processed commercial pet foods in the late nineteenth century. Many scientists and governmental bodies such as the FDA and AVMA seem to forget this simple fact: dogs and cats were fed raw meat and table scraps and wild game and anything else they could find before Mr Spratt invented the dog biscuit in London around 1860. The passage of 155 years is not sufficient for Mother Nature to have made the fundamental changes required to the design of our pets in order for them to need processed foods!
The very real problem we are all now facing is the possibility of the FSIS deciding to change its policy to bring it in line with that of the FDA. What is likely to happen if the current state of the rules by both bodies is shown to make pet food safer than human food?
Many bloggers and pet food activists have already come out and denounced the FDA’s policy as scaremongering and illogical, based on irrational fears and without regard to science or indeed common sense. The FDA has admitted that dogs rarely suffer from ingesting pathogens which are admittedly harmful to humans – they even report that in the space of nearly fifty years, only six cases have ever been reported of a dog becoming ill from Listeria.
What is equally disturbing is the amount of money being spent to implement the Food Safety Modernization Act, under which the FDA obtained the power to proactively test food for bacteria. It is estimated that the present budget is nearly one billion dollars, and even then more money is being requested. When you are informed that out of the total American population of some 320,000,000 people only 380 annual deaths have been reported as a result of Salmonella poisoning, it really does appear that the government in its infinite wisdom is using a sledgehammer to squash a microbe. In my belief that money would be far better spent in two ways:
- People need to be properly educated about food safety and hygiene. There are a huge number of myths about the handling of raw meat and these need to be identified and eradicated, which can only be done by proper education. Scaremongering and recalling raw pet foods is NOT going to achieve this.
- Rather than publicly shaming raw pet food companies whose products have been found to contain naturally occurring pathogens, which can be safely digested by our pets, money should be spent on tracing the source of these pathogens to the suppling farms. Dirty farms lead to dirty products, and to call out the end seller of those products is truly barricading the barn door after the cow has been led to market, slaughtered, processed and placed on the grocery shelf.
So why have the FDA suddenly decided to pick at your dog’s bowl? There is, after all, no greater risk from handling raw meat destined for your family’s dining table than there is from feeding it to your dog. If the FDA’s policy prevails, you will no longer be able to buy raw meat at the grocery store, whether it be for your family or your dog, and the apparent denial of the existence of pathogens all around us seems to indicate that the FDA has no interest in fact or science, but is merely jumping in to action without fully appreciating the consequences. It is impossible to eradicate all potentially harmful bacteria from the world – and I submit that even if it were possible, the chances are that it would be catastrophic, leading to a general overall weakening of the immune systems of both humans and pets, which cannot be a good thing. Bacteria are a necessary element of day to day living, and without them it is not possible to build up necessary, life saving, immunities.
So, out of the FDA and the FSIS, who do you think is likely to blink first and change their policy in this very real game of “Chicken”? We should all be very concerned indeed.