[AIB A Recovering Industry] Making Progress After Recalls

Doug and Beth noticed that their dog Lela had been acting out of character for the past week or so. They thought she was just experiencing the same “winter blues” as the rest of the family. But then they began noticing that Lela switched between periods of agitation and lethargy. She also tended to vomit occasionally, became a very picky eater and exuded an unpleasant smell they hadn’t noticed before. Finally, Doug took Lela to her veterinarian for an examination.

After seeing the results of blood tests and considering physical symptoms, the vet determined that Lela was suffering from kidney failure. A treatment program was implemented, but Lela could not be saved and died about two weeks later. Follow-up blood tests revealed a measurable level of an industrial chemical in her blood. Lela was one of many victims of a pet food contamination issue that was about to have a significant impact on the pet food industry.

On March 15, 2007, the U.S. Food and Drug Administration (FDA) announced it was beginning an investigation into possible pet food contamination based on a number of consumer complaints that had lead to a pet food products recall by one major manufacturer. Several additional pet food manufactures initiated recalls within the next few days.

Scientists at Cornell University found melamine in the urine and kidneys of deceased cats that were part of a taste-testing study conducted by the pet food manufacturer who initiated this recall. During the investigation, it was discovered that products labeled as wheat gluten and rice protein concentrate (both imported from China) were contaminated with melamine and melamine-related compounds (e.g., cyanuric acid).

FDA concluded two Chinese suppliers had added the melamine compounds to the wheat gluten and rice protein concentrate “to increase the apparent protein content in those products.”

Melamine is an industrial chemical used to make binding agents, flame-retardants and cooking utensils. It is also used as a fertilizer in some parts of the world, but is not registered for use as a fertilizer in the United States. Melamine and its related compounds also are not approved for use as ingredients in animal or human foods. (1)

FDA does regulate pet foods and other animal feeds. (“The Federal Food, Drug, and Cosmetic Act requires that pet foods be safe to eat, produced under sanitary conditions, contain no harmful substances, and be truthfully labeled” (1).) While very little scientific study had been done to determine the toxicity of melamine in dogs and cats, studies done with rats did show it was not highly toxic by itself. However, later research by FDA revealed the combination of melamine and cyanuric acid (a melamine-related compound that also was determined to be present in the tainted pet food) appeared to be more toxic than either compound alone. When these two substances are mixed, they form crystals in urine and kidney tissue. These crystals can lead to kidney failure. The American College of Veterinary Internal Medicine (ACVIM) reported that FDA received about 17,000 consumer complaints by the end of April 2007 and nearly 50 percent of these reported deaths (2). Unfortunately, this information was gathered anecdotally and is unconfirmed.

Unlike with human foods, a surveillance network to confirm cases of pet illness or death does not exist. In addition, pet deaths frequently go unreported since no legal requirement exists. Post-mortem examinations to determine the cause of pet deaths are costly and usually not performed. A vet may feel confident that a pet died from renal failure, but may not be able to accurately determine the cause of this failure due to a limited amount of clinical data. The death toll from the 2007 contamination incident will probably never be fully calculated.

The citizens of the United States have a widespread love affair with pets, especially dogs and cats. According to the Pet Food Institute (PFI), the trade association that represents the makers of 98 percent of the pet foods sold in the United States, people in this country owned about 63 million dogs and 81.4 million cats in 2005. These numbers show that more than half of all American households have at least one dog or cat sharing the home. Increasingly, psychologists support the theory that many people need pets to help maintain a healthy emotional state.

Based on the depth of human involvement with dogs and cats, it should be no surprise that last year’s pet food contamination incident attracted significant media attention.

However, effects on the pet-owning public appear to have been short-term. According to the results of a study conducted by PFI during April and May of 2007 and published on May 29, 2007 (3), “seventy-three percent of consumers say they are confident or very confident in the safety of their pet food and are staying with their preferred brand.”

LONG-TERM IMPACT ON THE INDUSTRY. But what about the long-term impacts on the pet food industry? In the May 2008 issue of Petfood Industry, a marketing executive from a large pet products retail chain states that sales of wet (i.e., canned) foods has decreased by about 25 percent while consumer demand for dry natural and/or organic foods has more than replaced this market (for additional information, go to www.petfoodindustry.com). One major U.S. pet foods manufacturer I spoke with recently increased its dry manufacturing capacity significantly due to customer demand and said its canned food business is declining at a rate of about 5 percent per year. I also spoke to one manager involved in the logistics end of the pet food business. He said his experience supports the trend toward dry foods for both dogs and cats. Since the 2007 recall was focused mainly on wet food products, it would appear consumers have more confidence in dry foods going forward.

Paul Johnson, vice president of operations for Dad’s Pet Care, said his company typically received about 1,000 consumer calls per year before the recall. Although none of Dad’s products were involved in the pet food recall, its call volume rose dramatically during the four weeks following the announcement — nearly eight times their annual call volume in just those four weeks.

More than a year later, call volume is still up (this trend was repeated by some other industry representatives I spoke with). With heightened consumer concern about pet nutrition, callers are asking more questions about ingredients and safety. He also said this further shows the depth of consumers’ concern for their pets.

Johnson said his company felt great about its ingredient screening protocols prior to the event and were pleased none of their products were involved in the recall. However, it further emphasized the importance of getting to know your suppliers, requiring and routinely examining certificates of analysis and letters of guarantee, and upgrading your supplier selection and monitoring procedures.

Johnson also said that Dad’s Pet Care has reviewed and upgraded food safety protocols such as raw materials screening, inspection and documentation, supplier audits, internal audits, personnel training and crisis management. “The event was very unfortunate and everybody in the industry has learned from it,” he said.

APPLICATIONS FOR HUMAN FOOD. When AIB performs a food safety audit at a pet food manufacturing plant or distribution center, we use the same AIB Consolidated Standards used for human food. Some exceptions do come into play. Many of the raw materials used to make pet foods are not acceptable for human food. This would include red meat, poultry and fish materials that, while not harmful, have been determined as unfit for human consumption. We also are not concerned about the “Big 8” allergens, as no substantial evidence exists to imply that dogs and cats are sensitive to these substances. However, we follow the other guidelines that define acceptable food safety initiatives for human food plants. This holds pet food manufacturers to some very high food safety and quality expectations and many plants have met this challenge quite successfully.

When FDA released its Food Protection Plan in 2007, pet food and animal feed were included in the details. Articles published by FDA in July 2008 about the progress of the Food Protection Plan after its first six months indicate some significant advances (4) (5).

FDA held its first bilateral meeting in March in Beijing. Verbal agreements were made to focus the agency’s present efforts in fulfilling the China Memoranda of Agreement (MOA) regarding aquaculture and ingredients (wheat gluten, corn gluten and rice protein). With cooperation from the Chinese government, the agency is moving forward to establish a physical FDA presence in that country.

FDA also is developing ingredient, processing and labeling standards for pet food. In addition, the agency is exploring the use of third-party inspectors and reliance on certificates for increased import safety. FDA also has begun food protection initiatives in other countries such as Canada, New Zealand, Australia, Vietnam, Mexico and India as part of its “FDA Beyond our Borders” program.

AVOIDING A REPEAT. Based on my interactions with the pet food industry, I feel confident that they have learned some hard lessons and are striving to avoid a possible repeat of this tragic event. As an owner of some very well-loved dogs, I find myself feeling comfortable about the products I buy and feed to them.

The author is a Food Safety Auditor with AIB International.

References:
1. Pet Food Recall/Contaminated Feed – Frequently Asked Questions (Updated Aug. 1, 2007) 
 http://www.fda.gov/cvm/MenuFoodRecallFAQ.htm
2. 2007 ACVIM FORUM PET FOOD RECALL June 9, 2007 Seattle, Washington
 http://www.acvim.org/uploadedFiles/pet_food_Transcript_final.pdf
3. “Consumer Confidence in Pet Food Remains Strong…”
 http://www.perfoodreport.com/release_5-29-2007.htm
4. FDA Food Protection Plan Shows Significant Progress
 http://www.fda.gov/bbs/topics/NEWS/2008/NEW01856.html
5. FDA Food Protection Plan Six-Month Progress Summary
 http://www.fda.gov/oc/initiatives/advance/food/progressreport.html