Pet owners have been turning to CBD to promote calm and relaxation in the presence of chronic pain, anxiety, and inflammation. We are frequently asked about CBD, so we wanted to create this quick primer to answer some of your most pressing questions.
Have you ever cuddled up next to your dog and noticed a distinct smell coming from their feet? It’s not uncommon to notice a distinct odor, often referred to as “Frito feet,” emanating from their paws or ears. This smell is typically associated with yeast overgrowth, a common issue in dogs. In this blog post, we’ll explore the causes of yeast overgrowth, its connection to diet, and effective remedies to alleviate discomfort. By prioritizing a healthy diet and making informed choices, we can promote our dogs’ well-being from the inside out. Let’s dive in!
Introducing fresh, whole foods to their diet can promote a healthy gut and aid the immune system in resolving yeast issues.
Yeast, a naturally occurring fungus in dogs and humans, can become problematic when it proliferates excessively. It thrives in warm, moist environments, commonly leading to the noticeable smell in our dogs’ feet and ears. Therefore, addressing yeast overgrowth involves understanding the factors contributing to its occurrence.
Yeast overgrowth can be triggered by various environmental and dietary factors. Moisture, warmth, and certain ingredients in dog food can create an ideal breeding ground for yeast. For example, dry kibble foods contain a significant amount of starchy carbohydrates that feed bad bacteria. It’s essential to identify these factors to effectively manage and prevent further issues.
A balanced diet plays a crucial role in maintaining a healthy dog. By prioritizing high-quality ingredients and avoiding ultra-processed foods, we can support our dog’s overall well-being. A nutritious diet strengthens the immune system and helps combat yeast overgrowth. Minimally processed foods and those lower in starchy carbohydrates can help promote the growth of healthy bacteria, boosting your dog’s immune system for long-term health.
If you suspect your dog has yeast overgrowth, dietary adjustments may be necessary. Introducing fresh, whole foods to their diet can promote a healthy gut and aid the immune system in resolving yeast issues. Supplements such as probiotics and digestive enzymes can be beneficial in restoring and maintaining optimal gut health. These supplements support a healthy balance of beneficial bacteria, aiding in the elimination of yeast overgrowth. Consult with our knowledgeable staff to find the right options for your dog.
Unpleasant odors emanating from our canine companions can be a cause of concern for dog owners. While a certain degree of odor is natural, persistent and pungent smells may indicate underlying issues that need attention. In this article, we will delve into the top five reasons behind unpleasant dog odors and provide practical remedies to address them. Let’s explore these reasons and discover effective solutions to tackle them head-on.
Yeast overgrowth is a common cause of unpleasant odors in dogs. The musty, pungent scent associated with yeast is often likened to moldy bread or cheese popcorn. Yeast infections typically affect the ear canals or paws of dogs, with the latter sometimes referred to as “Frito feet” due to the similarity to corn
chips. Common signs of yeast overgrowth include smelly paws, a musty odor, excessive scratching, itchy paws, and butt scooting.
To address a yeast infection in your dog, it’s crucial to assess their diet. Ultra-processed, starch-heavy foods like dry kibble can encourage the growth of bad bacteria, allowing yeast to thrive in your pet’s body. While topical remedies such as medicated shampoos and sprays can provide temporary relief, a lasting solution requires a dietary change to prevent the recurrence of yeast overgrowth.
While it’s natural for dogs to pass gas, excessive or foul-smelling gas may indicate an underlying issue. Simply keeping your dog away from the trash might not be enough to control their gas. An unhealthy diet can be a significant contributor to your dog’s stinky gas. We can assist you in finding the best diet tailored to your dog’s health needs, helping alleviate the problem.
Puppy breath can be endearing, but when bad breath sets in, it can be quite overpowering. Typically, bad breath in dogs is the result of bacterial buildup in
Poor dental health, tartar accumulation, infections, or periodontal disease can contribute to foul-smelling breath.
their mouths. Additionally, poor dental health, tartar accumulation, infections, or periodontal disease can contribute to foul-smelling breath.
Dog owners often find it challenging to maintain their dog’s dental health, but it doesn’t have to be a hassle. Check out our blog post on various methods to keep your dog’s dental hygiene in check, ensuring fresh breath and overall oral health. Check out our blog post on different ways to keep your dog’s dental hygiene in check.
Dealing with malodorous anal glands can be unpleasant. These glands are located on the sides of a dog’s rectum. Normally, healthy anal glands should not emit any odor. However, if you detect a fishy smell, it could indicate a problem with your dog’s anal glands. Symptoms such as leaking, a pungent odor, butt scooting, or signs of pain may indicate the need for expressing the anal glands, which requires a visit to your vet.
Regular brushing of your dog between baths is vital for removing dirt, dead skin, and other debris trapped in their coat, effectively reducing unpleasant smells. Thorough brushing goes a long way in keeping your dog stink-free.
Grooming wipes and deodorizing sprays can also help your pet to smell fresh in between baths. Another simple trick to keeping your dog clean is to keep their bedding and toys clean. It keeps both your dog and house smelling fresh.
Your pet’s dental health is an important piece of their overall health and wellness. Oral disease can be caused by diet, genetics, or poor oral care. Poor dental health can lead to other ailments, which is why pet owners should learn how to care for their pet’s teeth early. As with most ailments, prevention of oral disease is key. Taking preventative steps saves you the time, stress, and money it takes to treat oral disease down the road.
Good preventative care should:
Without routine dental care at home, veterinary dental cleanings may be necessary.
What it is: A very fine, tasteless, and odorless prebiotic-based powder you add to your dog’s water.
How it works: Teef! promotes healthy teeth, gums, and fresh breath by encouraging the growth of healthy bacteria in the mouth.
How to use: Add Teef! powder into your pet’s water bowl.
What it is: A powdered cheese enzymatic meal topper for cats and dogs.
How it works: The first four ingredients are actually dried cheeses, which aside from being super tasty, makes your pet salivate. The saliva activates the enzymes that help to break down some of the sugary starches left in your pet’s mouth after eating and helps flush out some of the bad bacteria.
How to use: Sprinkle it over your pet’s meal or spread across your pet’s teeth and gums with your finger.
*Pro Tip: Picky eaters (and kitties) LOVE the smell and taste of DentaTreat. After all, who doesn’t love cheese!?
What they are: Small round medicated wipes formulated to clean your dog’s teeth and gums.
How they work: Dental wipes remove and prevent dangerous plaque, tartar, and bacteria for optimal oral health and hygiene.
How to use: Working from back to front, wipe medicated pad on the inner and outer teeth and gums. For best results, use twice daily after each meal.
NPP Pick: Nootie dental wipes
What they are: Natural and/or synthetic chews designed to scrape plaque off your dog’s teeth and massage the gums. Synthetic chews (Nylabone and Benebone) have unique shapes and textures infused with flavors.
How they Work: These physically scrape off plaque and tartar and massage the gums while your dog chews on them. They will naturally wear down gradually as your dog chews.
What it is: A digestible chew that targets plaque and freshens breath.
How it works: Dental chews are soft enough to bend but tough enough to pull plaque and tartar as your dog chews on them. They typically contain non-toxic oils (such as rosemary, peppermint, or lemongrass) to freshen breath.
How to use: Give these to your dog once daily. They will be chewed and digested in one sitting.
NPP Pick: Merrick Fresh Kisses
What they are: Meaty bones (such as chicken, duck, or turkey necks) are mostly meat and cartilage and will be consumed entirely. Recreational bones (beef marrow bones) have small amounts of meat/cartilage attached and will be chewed but not consumed entirely.
How they work: These physically scrape off plaque and tartar and massage the gums while your pet chews on them.
How to use them: Introduce raw bones into your pet’s diet slowly. Start with short chewing sessions that are 5-10 minutes in duration and gradually increase chewing time. Learn more about how to safely feed raw bones here.
What it is: A fresh food diet rich in minimally processed protein and fat from animal sources, with little to no starchy carbohydrates.
How it works: While diet will not necessarily clean your pet’s teeth, the minimal carbohydrate percentage in a raw food diet means less bacteria that cause oral disease – which is the best step you can take to prevent the growth of plaque and tartar. Raw food diets also contain natural dietary enzymes that protect the teeth and gums. Lastly, these diets do not contain harmful aflatoxins and skip the chemical compounds that put stress on your pet’s immune system.
How to use: We recommend using commercially prepared raw food items as a compliment to your pet’s diet or as a complete meal.
This is the gold standard in preventative oral care for your pet. Leftover food particles stuck between teeth and gums are swept away with brushing motion. For maximum benefits, brush your pet’s teeth daily after meals.
How to do it: It’s best to introduce teeth brushing as a regular occurrence for your pet, so it becomes part of your daily routine. Start by using your finger to massage the teeth and gums. Once they have adjusted to your finger in their mouth, you can start using a finger brush, and then graduate to using a pet toothbrush.
Pets are unique and there is no “one-size-fits-all” when it comes to dental hygiene. Take time to find what your pet likes and what works best for your pet’s dietary needs, genetics, and lifestyle.
What’s Nicci up to these days? Nicci was recently featured in a Facebook live with Drs Nick Thompson, Brendan Clarke, and Conor Brady discussing her research on the safety of raw feeding, Dilated Cardiomyopathy (DCM) and grain-free food.
We know fruits and vegetables are essential for our diets, but they are also beneficial for our pets. Fruits and vegetables are nutrient-dense, and the benefits your pets obtain from the fiber, antioxidants, phytonutrients, and vitamins can do wonders for their health.
We all want the best for our pets, and one crucial aspect of their well-being is a nutritious diet. While dry kibble forms the foundation of many pets’ meals, there are simple yet effective ways to enhance its nutritional value. In this blog, we’ll explore three easy ways to improve a bowl of dry kibble. These enhancements not only enhance the taste but also provide numerous health benefits for your beloved companion.
Goat milk is another fantastic way to add hydration.
Add a Splash of Water: Dry kibble can be dehydrating for our pets, making it essential to increase their moisture intake. By adding a splash of water to your pet’s food, you’re not only improving its palatability but also aiding digestion and promoting hydration. Adequate hydration supports optimal organ function, aids in nutrient absorption, and helps maintain healthy skin and coat. Goat milk and bone broth are also fantastic ways to boost hydration. It’s a simple yet effective way to ensure your cat or dog stays well-hydrated throughout the day.
By incorporating these simple improvements, you can transform your pet’s dry kibble into a more enticing and nutritious meal. Remember, consult with your veterinarian to ensure any dietary changes align with your pet’s specific needs and health conditions. With these easy enhancements, you’re taking proactive steps towards providing your pet with a well-rounded and satisfying diet that promotes their health, happiness, and longevity.
Ever wonder how Nicci & our team at NorthPoint Pets (NPP) evaluates brands to determine what foods end up on our shelves? It’s actually a lot of work and involves a lot of tough conversations. We thought it would be fun to show you a little behind the scenes of what questions we ask and why, so you know how choosy we are when it comes to the food that ends up in your (and our) pets’ bowls! These questions we ask prospective brands ensures the quality and safety of our products.
Recently a pet food company reached out to us in an attempt to earn a spot on our shelves. In response, Nicci asked a series of questions regarding the quality and safety surrounding the food. The following is a dialogue between her and a Prospective Pet Food Company. (Please note that additional information is provided for context.)
Prospective Brand: We consult with a number of veterinarians and animal nutritionists who provide input on formulations as well as ongoing data from health and lab results for generations of dogs and cats on our food. We feel this is more objective than having a small team of nutritionists or veterinarians on our payroll and gives us access to a broader group of experts and studies. We formulate blends that meet (and often exceed) AAFCO Nutrient Profiles for dogs & cats and use only ingredients that have been proven through independent studies to have long-term health benefits and are the most digestible for the intended species.
NorthPoint Pets: This didn’t answer the question: who, and what are their qualifications? The veterinary nutritionist or Ph.D. nutritionists do not have to be employed by you, but their experience and qualifications are important to know considering there are so few of them in practice. Further, there is a big difference between a veterinarian and a veterinary nutritionist or board-certified nutritionist because veterinarians alone generally do not have the expertise or experience in formulating pet foods, so a veterinarian and/or Ph.D. with nutrition qualifications is important.
Prospective Pet Food Brand: (Did not further respond to this question)
Prospective Brand: All our ingredients are USDA/FDA certified to meet USDA nutrient profiles and FDA quality and potency standards. A Certificate of Analysis (COA) is provided for every ingredient which includes test results for a variety of standards including heavy metals.
NorthPoint Pets: The FDA doesn’t certify ingredients. Do you conduct any independent testing outside of the COA that you receive to ensure the ingredient levels are accurate? (Example, Hill’s wasn’t testing their vitamin D which led to their recall)
Prospective Pet Food Brand: (Did not respond)
Prospective Brand: Yes, we trace every ingredient and every supplement back to its origin.
NorthPoint Pets: Ok – but are you able to provide that information? And, do you source from China?
Prospective Pet Food Brand: (Did not respond)
Prospective Pet Food Brand: Our nutrient profiles are all substantiated and include all AAFCO essential nutrients, plus others that we feel are relevant, in both AS FED and DRY MATTER values. Our profiles are published on our website:
NorthPoint Pets: The information provided on your website is incomplete and unclear. For example, are these typical or targeted analyses? A typical analysis would provide the actual analyzed values of the formulas while a targeted analysis is just a prediction. Using predictions is not something that NorthPoint believes is safe or accurate. Additionally, how often are your formulas tested? These links don’t say.
Prospective Pet Food Brand: Did not respond.
Prospective Brand: We use ingredients that have published results for these tests, to the extent they are available for human consumable ingredients. As a company, we do not perform caged trials. We have 14 years of proven history with multiple generations of pets on our exclusive diets.
NorthPoint Pets: Using the individual values for each of these ingredients is not the same as a full digestibility trial for each formula because individual values do not count for processing losses, ingredient/nutrient interactions, or even how fiber impacts the bioavailability of various nutrients. Further, utilizing data available from human databases is not always accurate or translatable to pets as these also do not account for ingredient interactions and processing losses.
Caged trials are not necessary for digestibility values. For example, many companies feed the food to the employee’s pets and collect stools from them to determine digestibility values. That said, caged trials in my opinion are better than no digestibility values because without digestibility trials you are essentially experimenting on your client’s pets. It is also important to note that longevity in the marketplace does not prove adequacy. A great example of this would be Midwestern Pet Foods who has nearly 100 years and was recently the subject of multiple recalls due to significant ingredient sourcing and food safety gaps.
Prospective Pet Food Brand: Our facility is licensed for human food manufacturing and we are under continual USDA inspection at human food standards. In our 14 years, we have never had a recall or a single quality issue or failed an inspection/audit.
NorthPoint Pets: USDA inspection or human grade products/ingredients provide no guarantees. The most recent example is the Tyson chicken recall (8.5M lbs over 4 months) which has now impacted NomNom. Another example would be the Listeria recall for Just Food For Dogs which stemmed from ‘human grade’ green beans. These USDA designations are also not 3rd party verifications or food safety programs.
Prospective Pet Food Brand: Because we use real food the values for our ingredients are substantiated and published by USDA. We can provide actual USDA substantiated values upon request for all our food ingredients.
NorthPoint Pets: I defer back to my response to your answer to question 5, this is not an adequate response because without digestibility values you really don’t know where your calories are coming from or how they are assimilated. Additionally, USDA values provide caloric values based on Atwater – and modified Atwater is used for pet foods. It is also not a secret that Modified Atwater (or Atwater) has never been validated in dogs or cats which means this is a highly inaccurate way to estimate the calorie content or digestibility of your food or individual ingredients in your food.
Prospective Pet Food Brand: Did not respond.
Prospective Pet Food Brand: We adhere to all USDA HACCP and testing standards for human food manufacturing. This includes continual testing of all food surfaces throughout the manufacturing process as well as ingredients and finished products. Our meats are gently but fully cooked to minimum temperatures recommended by FDA for food safety, and we are required to keep detailed baking and testing logs for every tray. We follow similar logging and testing for raw ingredients. The disparity between feed standards and food standards is impossible to detail in a 2-page response, and we operate at or above the human food safety standards for manufacturing and finished goods.
NorthPoint Pets Comments: This is a fair response, but not great. This is because it does not indicate that their facility is indeed human-grade, shows they do NOT have a 3rd party safety program, or directly answer that they hold their products until testing to ensure that pathogens are not being released into the marketplace. Simply cooking products does not negate any risk of pathogen contamination as evidenced through pathogen contamination of cooked diets like kibble.
Overall, you can see that the responses by this company SEEM good, however, once we break down the terminology and provide some industry insight it is easy to see that this company is less than transparent. The problem is unfortunately not isolated to this pet food company. In fact, it is a pervasive issue in the pet food industry. Pet food companies have become increasingly savvy marketing companies providing carefully crafted answers and terminology that make pet parents and retailers feel good about food when in fact they are no different than some of the others that have caused issues in the past.
This example should serve as a good example of why it is so important to ask your pet food company really important questions and KNOW what the right answers are and what a deceiving set of answers looks like. Unfortunately, it does take a little bit of work, and the above answers can even fool even the best veterinarians. Nutrition and pet food really is a complicated industry – but we’re here to help you navigate it! If you have any questions please do not hesitate to stop in and engage our talented and passionate team.
At NPP, we’re passionate about the health and wellness of all your pets. Just for fun, we sat down with each team member individually and asked the same 3 questions, without sharing their answers with the rest of the team. Here are their answers!
Jenna: Add some fresh food to the bowl.
Beth: Hydrate it.
Savannah: At least hydrate it, always. Kibble is so dehydrating.
Tina: Add SOMETHING fresh.
Nikki: Feed the BEST you can afford, and always add moisture with fresh fruits and veggies.
Nicci: Add SOME fresh food to the bowl.
Caitlyn: Kibble should always be hydrated.
Adriana: Always hydrate your kibble even if it’s just something as simple as water.
Morgan: Hydrate it.
Mercedes: Hydrate it.
Jenna: A little bit of fresh food in the bowl goes a long way!
Beth: You’re overfeeding.
Savannah: At least consider the benefits of a raw diet.
Tina: You’re feeding too much.
Nikki: You’re feeding too much.
Nicci: Your dog isn’t allergic to chicken.
Cailtyn: Rotation of flavors/proteins is highly recommended.
Adriana: You’re overfeeding.
Morgan: You’re overfeeding.
Mercedes: Wash your food and water bowls!
Jenna: Your pet’s health will improve ten-fold by replacing any processed kibble with fresh food.
Beth: It’s the cleanest way to feed your pet.
Savannah: Because it’s so much better for them – it improves EVERYTHING for your pet.
Tina: For the same reason WE need fresh food in our diet.
Nikki: It’s healthier, for a fuller enriched life.
Nicci: Decreased inflammation.
Caitlyn: A fresh/raw diet is more biologically appropriate for dogs and cats.
Adriana: For their pet’s overall wellbeing and to tackle common health conditions.
Morgan: Fresh food benefits your pet’s whole body – starting with their organs.
Mercedes: It’s super low in carbohydrates.
….and other lessons courtesy of Midwestern Pet Foods
If you’re just catching up, Midwestern Pet Foods (manufacturer of Earthborn, ProPac, SportMix, CanineX, Venture, Unrefined and Wholesomes) rounded out 2020 with an expansive ‘voluntary’ recall’ secondary to aflatoxin contamination among a variety of their products. As 2021 began, the ‘voluntary’ recall became larger, as retailers and consumers we were assured that this incident was isolated to one of their four US plants. If you are wondering why I put ‘voluntary’ in quotes, it’s because voluntary recalls are actually not voluntary – they are forced by the FDA (For more on that, see my other article ‘Voluntary Recalls Are Not Voluntary’ here). In short, when a company is subject to a voluntary recall it appears to imply that either the company did not have to recall the product, or that they may have found the issue themselves and thus recalled the product ‘out of an abundance of caution,’ when in fact that is usually pretty far from the truth.
In the case of the aflatoxin recall with Midwestern Pet Foods, the recall was initiated by the Missouri Department of Agriculture as a result of pet illness reports and not Midwestern Pet Foods identifying the issue. Looking at the timeline of how things progressed, the initial recall was announced on December 30, 2020, expanded on January 11, 2021 (to include over 1,000 lots of pet food) and was followed up by an updated outbreak and advisory on January 26, 2021. The timeline and expansion of the number of lots and amount of pet food impacted shows just how important it is for pet owners and retailers to ask proper questions of their manufacturers to ensure the products they stock or feed their pets is safe – and to protect their businesses and livelihoods. In other words, the recall started out small and seemingly to be a self-caught issue, however the fairly quick expansion tells a different story. If Midwestern Pet Foods was properly testing inbound ingredients (i.e. aflatoxins in grains), testing foods after production and prior to leaving the facility (positive release) this would have never happened.
The outbreak and advisory notice outlines how the FDA was working with 10 different states to determine the impact of the aflatoxin contamination of Midwestern’s portfolio of brands. This advisory also provided an update that included at least 35 additional countries where the foods were likely distributed to and thus impacted by this recall in the United States. For example, The Food and Drugs Authority in Ghana issued a directive for all foods manufactured by Midwestern Pet Foods to be returned to the importer due to dangerously high levels of aflatoxin. For context, some of the products tested contained aflatoxin at levels as high as 558 ppb. FDA considers that aflatoxin levels in dog and cat food above 20 ppb will support a charge of adulteration because it is fatal or injurious to the health of pets.
Soon, the general public, retailers and veterinarians alike realized that this was not an isolated incident and in fact was a result of widespread food-safety issues and problems across all four plants owned and operated by Midwestern Pet Foods. The worldwide aflatoxin recall was almost immediately followed by a second recall due to Salmonella contamination of several other lots of products in March of 2021 made in a second Midwestern Pet Foods facility. If you read the recall notice on the FDA website, you’ll note that this recall is also quite expansive involving several recipes and brands. When recalls are this large, several questions should be raised which include but are not limited to:
Although the company claims that Salmonella-contaminated product never made it into the marketplace, and they caught the recall prior to it leaving their facility, the FDA letter states that it did indeed get distributed into interstate commerce. If none of the contaminated product left their facility and they were able to provide documentation to prove that no other product was impacted, then a recall would not have been triggered. This fact tells us again that food safety was an issue, and that again we see a large transparency problem with another manufacturer in the pet food industry.
The FDA Warning Letter issued to Midwestern Pet Foods on August 9, 2021, included five FDA Form 483’s. An FDA Form 483 is issued to firm management at the conclusion of an inspection when an investigator(s) has observed any conditions that in their judgment may constitute violations of the Food Drug and Cosmetic (FD&C) Act and related Acts. I’ve heard a variety of comments after this warning letter was issued from pet owners and retailers – the largest, and most concerning is that many believe that because no new recall was issued that the Warning Letter is not really a cause for concern. Nothing is further from the truth and in fact, I would argue that the Warning Letter – impacting all 4 locations – is worse than a recall. Why do I say that?
This Warning Letter was issued as a Corporate Warning Letter because at the conclusion of inspections at all four facilities the FDA issued these FDA Form 483’s due to documented issues at each of their facilities:
“At the close of each inspection, you or your plant manager was issued a Form FDA 483, Inspectional Observations. We acknowledge you1 have provided written Form FDA 483 responses dated February 25, 2021 (OK), March 12, 2021 (NY), March 19, 2021 (IN), March 30, 2021 (IL), and May 6, 2021 (IL) describing corrective actions you have taken or plan to take to address the observations at each of your facilities.”
This shows that OK, IN and NY each received one, and IL received two FDA Form 483’s for a total of five. The problem is that most people have never read? past the initial FDA in Brief that was released on August 17th, 2021. This letter detailed numerous apparent violations of the Federal Food, Drug, and Cosmetic Act that were shared across the four sites. The FDA states that these violations are likely to have contributed to the illness or death of hundreds of dogs resulting from high levels of aflatoxin secondary to violations of Current Good Manufacturing Practice, Hazard Analysis, and Risk-Based Preventive Controls for Food for Animals regulation.
Per the FDA/CVM: The last of the four inspections concluded on April 16, 2021, and FDA immediately began the process of examining and compiling evidence from the multiple inspections into a corporate-wide warning letter.
Because the firm had voluntarily recalled the pet foods that had the potential to be contaminated with Salmonella or aflatoxin, because investigators provided initial feedback to the firm about their inspectional observations (FDA Form 483s), and because the Agency did not have evidence that violative Midwestern-manufactured product was currently in the marketplace, the FDA did not initiate a product seizure or injunction case.
However, because the conditions observed during the inspections indicated significant problems, the Agency took the step of issuing a corporate-wide warning letter.
This Warning Letter is far more than the FDA saying ‘Hey, clean up your act’ – this is a warning to ‘do better next time’. Instead, a warning letter is typically issued after an inspection of a plant or manufacturing facility that finds quality control issues and/or after consumer-related complaints as a result of injury or death. In this case, the warning letter started with consumer complaints, which triggered inspections at all four sites which then found further issues. These issues are outlined in this letter in which the FDA requests corrective action by Midwestern Pet Foods:
“During the IL inspection, you recalled approximately 104 products of dry dog and cat diets made in your IL facility from October 26, 2020 – November 12, 2020, February 1, 2021 – February 12, 2021, and March 15, 2021 – March 19, 2021, because your routine monitoring yielded Salmonella-positive results for pet diets manufactured on common equipment during those periods.”
The explanation of such food safety issues within this letter is what, in my opinion, makes this worse than a recall letter. Recalls are supposed to catch unfortunate accidents and rare occurrences of pet food adulteration. The highlights of these violations go far beyond a mistake, oversight, or single incidence of human error because they expand across multiple products, multiple lots on multiple dates of manufacture simply because they were common mispractice across all four of their manufacturing facilities. Further, it’s important to point out that these recalls were indeed so large, likely because of two reasons: poor food safety AND documentation of manufacturing. Was it likely that all lots impacted were contaminated? No, instead a large amount of product was recalled in an attempt to reduce the potential for any to be in the marketplace. On the other hand, is it likely that all contaminated products were found or recalled? It is uncertain, and this is because nowhere within the FDA reports does it state that all retained samples were tested for all products in the marketplace. It is unknown if all contaminated products were caught since aflatoxins are never evenly dispersed in grains, and instead you have ‘hot spots’. The hot spots are the reason why a robust and thorough screening program is needed for incoming raw ingredients, during manufacture and prior to distribution into the marketplace. In other words, if these programs are implemented properly, things like aflatoxin and salmonella are preventable. As a result, the FDA likely made a press release so consumers, retailers and veterinarians can be hyper-vigilant in seeing early warning signs of aflatoxin poisoning in case all affected lots were not recalled.
Within this letter, the FDA also states that voluntarily recalling product does not prevent the recurrence of such hazards (aflatoxin and Salmonella) in their products. Hence the need for Midwestern Pet Foods to respond to this robust Warning Letter with their plans to mitigate these risks, upgrade their Food Safety procedures in the future, document proper training and implementation of the programs (i.e. aflatoxin analysis and environmental Salmonella detection). While Midwestern has responded to some of these violations, as outlined within the Warning Letter, there still remains more work to be done as well as additional inspections of all facilities to ensure compliance.
Not until the FDA inspects the facilities to ensure that their corrective measures are implemented and being executed properly, will the Warning Letter be resolved. In the meantime, since the warning letter and investigation are still open, one would be prudent to be cautious of any product coming from any facility with an open or unresolved issue.
At this point, you may be wondering what happened to Hill’s Warning Letter that was issued as a result of excessive levels of Vitamin D. This massive recall was also global and resulted from Hill’s not following their own food safety procedures. This Warning Letter is also currently unresolved, likely due to COVID restrictions and the FDA not being able to adequately execute a robust inspection. One could also argue that regulatory authorities don’t have the capacity to police everyone all of the time, or that they may be letting such a large manufacturer get by for reasons we can maybe discuss at another time. Regardless, the lesson is that unless a warning letter is resolved you should probably find another pet food for your pet, or stock a different brand in your retail or clinic location.
An unresolved Warning Letter has actually never happened in the pet food industry, although it has happened in veterinary product and livestock industries. This is because pet food companies have historically complied with any changes that the FDA suggested after issuance of the Warning Letter. So, what happens if a pet food, treat, or supplement company fails to make adequate changes or fails to comply altogether? It’s likely that the U.S. Department of Justice would have to bring on an injunction on the FDA’s behalf. For an example of this, we’d have to look to human industry examples to determine what would happen…
Current Good Manufacturing Practices (cGMP) are historically what trip up food and supplement manufacturers. Failure of a company to conduct their manufacturing under such practices after being issued a Warning Letter would result in the U.S. Department of Justice doing what? on behalf of the FDA. Just one example, the FDA shut down Sunset Natural Products for manufacturing and distributing adulterated dietary supplements following a ruling by a U.S. District Court which issued a consent decree against the company. Under a consent decree the company is not allowed to manufacture or sell their products until the FDA determines the business is in compliance with the Federal Food, Drug, and Cosmetic Act. While this has not happened often, it is possible for companies to resurrect themselves post past? an event such as these, but it does take quite a bit of reinvention.
Per the FDA/CVM: injunctions have also been regularly filed against dairy farms that have introduced food containing illegal drug residues into the U.S. food supply. FDA initiates civil actions like seizures and injunctions for different reasons than criminal actions. Civil actions are brought to protect the public from harmful products under FDA’s jurisdiction. Criminal actions are brought to punish culpable parties for wrongful action and discourage the behavior. Given the different goals and legal requirements for each, there are different procedures that FDA follows to initiate each type of case. Please see Chapter 6 of FDA’s Regulatory Procedures Manual for FDA’s policies about pursuing seizures, injunctions, and prosecution of criminal matters.
Depending on the nature of the violation, it is the FDA’s general practice to give individuals and firms an opportunity to take voluntary and prompt corrective action before it initiates a judicial action. In some cases, however, judicial action is necessary to protect public health. As noted above, all judicial action must be pursued by FDA through the U.S. Department of Justice.
Based on this and other incidents we can hypothesize that if a company did not adequately respond to or respond at all to a Warning Letter, the FDA would take legal means to shut down operations of that pet food company. In this case, involving Midwestern there are a number of issues across all of their facilities indicating that substantial overhaul of their cGMP is needed. If this does not happen, or happen to the level of satisfying the FDA, we could potentially see an injunction against the company – although this would be a first for the pet food industry.
At the end of the day, this is not just about Midwestern Pet Food, because there are multiple recent examples of adulterated pet foods in the marketplace that include Evanger’s, Sunshine Mills, Hill’s Pet Nutrition, Blue Ridge, NomNom…I could keep going. The lesson is just another example of why it is so important to ask pointed and meaningful questions of your pet food manufacturers. These questions include but are not limited to:
Bottom line: If your pet food company cannot answer these questions or they say the information is proprietary, don’t feed their food!
Nicole Cammack
Nicole founded NorthPoint Pets & Company to fill a void for pet parents: information and transparency. Nicci understood that, while there are countless pet stores and unending opportunities for buying online, much of the information about pet food and health is incomplete, biased, or misleading. Since 2014, she is proudly leading an incredibly talented team that boasts several national awards as the leader in independent pet retail, innovation, education, health, nutrition and transparency.
Research & evolution are the foundation for everything NorthPoint stands upon. Currently, Nicole is working on her PhD at the University of Georgia (UGA), College of Veterinary Medicine in Canine Nutrition & Metabolomics. In short, she is studying how the way we feed our pets can influence disease. Although research is not a new field for her, as she has experience in clinical research for diseases such as obesity, diabetes, Alzheimer’s Disease and various cancers. Her undergraduate and graduate education includes biology, chemistry, business and nutrition. She has worked in the pharmaceutical industry on multiple R&D projects and has had the privilege to learn from leading international figures in both the human and pet health industries. When not at NorthPoint or UGA she can be found presenting at national conferences, including federal, state, and municipal organizations. Her most recent publication reports on the prevalence of reported pathogenic infections related to raw pet food diets.
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