Varying your pet’s diet – also known as “rotational feeding” – not only keeps your pet from becoming bored with his food but also may have significant health benefits. Believe it or not, many processed foods like kibble or canned foods may not actually be 100% complete and balanced – even if the packaging says it is.
The word holistic started gaining traction in the late 1960’s and has been increasing in popularity ever since. The word has many different meanings to many different people. For most, the word brings about thoughts of wholesome, healthy, natural, fresh, etc. It’s evolved to invoke an emotional response to pet owners. As such, we’re conditioned to think holistic represents at least some level of quality, purity, or healthfulness of a pet food product bearing the term. It gives us a sense of confidence and trust in the product. But what is special about pet food packaging that proudly claims the product is holistic? Are there any guarantees?
Let’s start by looking up the word in the Meriam Websters dictionary. It lists two definitions of the word holistic:
Characterized by comprehension of the parts of something as intimately interconnected and explicable only by reference to the whole.
Characterized by the treatment of the whole person, taking into account mental and social factors, rather than just the symptoms of a disease.
Given these definitions, it’s obvious that the pet food industry has warped consumers’ perception of what holistic means. Neither of these definitions really apply to pet food, or guarantee its quality. In fact, it seems that the consumers perception of what this means is entirely different.
A little secret in the pet food industry is that the Association of American Feed Control Officials (AAFCO) defines various terms for pet food. This can mean that the definition of a word in the dictionary can be very different than the AAFCO definition. Examples include terms like natural and organic – the AAFCO definition of these terms is very specific and not at all what the average person would expect.
Even more surprising is that in the pet food industry terms like ‘holistic’, ‘biologically appropriate’ and ‘super-premium’ have no definition and are there just to catch your eye. In other words, these terms plastered all over pet food, treat and supplement packaging tells a story to the consumer that might be purely fictional. This is known as “puffery” – or in other words subjective, rather than objective views. This practice is not exclusive to the pet industry, as it is common in many industries. Puffery serves to “puff up” an exaggerated image of what is being described.
The term holistic doesn’t have a definition in regard to pet food, supplements, or treats. It’s just marketing. Because the term holistic is not regulated it offers no guarantees on the quality and sourcing of the ingredients or the nutritional value or digestibility of the product. Knowing this, it is frustrating to walk the aisles of a pet food store or visit pet food company websites only to see the term used to describe their brand and quality of products. Further, a simple google search of “best holistic pet foods” will reveal various ‘Top Pet Food’ lists claiming benefits and ranking of holistic products, some even with holistic in the name. Sadly most, if not all, of these lists do not use meaningful or tangible nutritional benchmarks to rank pet foods. Instead, they are ranking foods based largely on marketing hype.
These facts do not necessarily mean that foods claiming to be ‘holistic’ are bad. It just means that you may have to do some homework to determine the quality and nutritional adequacy of the product.
Any company can use the term holistic on their packaging and describe their product without having to meet any standards whatsoever. So, what should you know when choosing your pet’s food? When evaluating or choosing your pet’s food it’s important to review the ingredient panel and guaranteed analysis. Unfortunately, this simply isn’t good enough. One of the best ways to evaluate your pet food is to reach out to the company and ask some direct questions to determine how they validate their nutritional adequacy, product safety and how transparent they are. Learn more about what questions to ask here.
There are a lot of products and companies that make health claims and clean sourcing that aim to provide a certain level of comfort to the consumer. However, most companies are not willing or able to prove it. Simple email requests for documentation of processes and testing from me, as a retailer, often go unanswered. The lack of response is sometimes from companies most pet owners know and trust. Believe it or not, some of these companies would surprise even the savviest pet owner.
There’s a widespread lack of data across food, supplement, and treat categories. For example, a lack of data exists to substantiate claims such as ancient grains prevent the risk of DCM (dilated cardiomyopathy or heart disease). Or that adding taurine to a product makes it heart-healthy. What about high-protein pet foods? There’s no benchmark to define what that means – or that it’s beneficial. Why? Because nobody has held these companies accountable for their claims. They’ve never needed to provide data to support these claims because nobody has ever really asked. One can make the argument that the lack of data from manufacturers opened the doors up for bad science behind the grain-free and heart disease debate to flourish. Simply, bad science won because there was inadequate data to support the effectiveness of grain-free food to provide adequate nutrition. Manufacturers were and still are silent because they are unable to stand behind their products and support the retailers who sell their products. Harsh, but true.
These are just some recent examples. Many products within the industry, including ones perceived as natural and high quality, lack actual measurable transparency and quality control. This means that their benefits, or claim of benefit, could easily be overshadowed by poor sourcing, toxins, and/or formulation.
For supplements, few companies do inbound testing on their raw ingredients or at least make those results public. Such testing would verify that the ingredient is what it says it is. It should also screen for toxic contaminants and ensure each ingredient has verification of origin and quality supply chain. In today’s pandemic economy, a company should be able to claim AND certify ingredients within their supplements or products that are not sourced from China. That final product should also have an analysis that confirms the targeted levels of active ingredients and reconfirms the lack of toxins.
When it comes to toxic screening, CBD is of particular concern, because it can be a highly toxic plant. This is because hemp performs a process called phytoremediation. Meaning that it absorbs heavy metals and many of the agricultural chemicals in the soil such as pesticides, herbicides, and fertilizers. Inbound raw ingredients should always be tested for these toxins – in addition to the final product. CBD and other supplement companies should openly provide this information – however the majority can’t because they do not conduct these tests.
For treats – the same applies. Do the inbound raw ingredients have quality control measures that allow the company to be fully transparent? Will that company shares those reports? These same transparency concerns also apply to pet food. We also see a general lack of transparency and accountability leaving both manufacturers and retailers open for potential problems. Establishing accountability simply starts with both pet owners and retailers asking these questions and demanding improvement. Change won’t happen overnight, but improvement has to start somewhere.
It’s clear how transparency across nearly all pet categories is lacking. Transparency has become a feel-good word for those who don’t know any better. However, for those that do, it’s become a cringe-worthy tagline that is an Achilles heel.
The reality is that asking these questions and holding companies accountable is a path that most are hesitant to venture down. However, gone are the days of blind trust in manufacturers. Blind trust has cost the health and lives of many pets too many times to count. The definition of insanity is doing the same thing over and over again and expecting a different result. As pet owners and advocates, we need to start asking the tough questions to demand accountability for the betterment of the industry, and most importantly our pets.
The following is a general, but not complete, list of questions to ask for food, supplement, and treat manufacturers. Keep in mind that most companies will be unable to provide all the answers and that the goal is to encourage actual, rather than perceived, transparency. It will take time, but change will require asking these questions and ultimately basing buying and retail stocking decisions on the availability and willingness to provide satisfactory answers.
Nutrition goes far beyond an ingredient label and the guaranteed analysis.
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.)
….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.
We have always received advice to cook meat thoroughly in order to eliminate pathogens such as Salmonella, E. Coli, or Campylobacter. However, there is limited documentation linking raw feeding to enteric pathogens. A study conducted by DogRisk1 examined stool samples from dogs fed raw diets and those fed kibble-based diets. The study found that “Zoonotic meat-borne bacteria, such as Campylobacter, Salmonella, and enteropathogenic Yersinia, were only sporadically detected in RMBD (raw meat-based diets) by PCR.”1 In other words, there is no consistent association between raw diets and enteric pathogens.
By following basic, safe handling practices (which we already do when handling our own meat to prevent illness) – such as practicing good hand hygiene, disinfecting surfaces after preparation, and not feeding spoiled meat – the risk of enteric pathogens can be minimized.
It is worth noting that some of the largest and most significant pet food recalls in the U.S. have been linked to dry food. This indicates that heat-treated foods also carry a significant risk of pathogens. Additionally, research shows that most pet owners do not regularly wash their hands or clean their pet food bowls. Therefore, regardless of the type of food you feed your pet, it is important to practice proper hygiene.
The Covid-19 pandemic has caused significant disruptions in the availability of pet food. If you rely on canned food for your pet, you may have noticed frequent out-of-stock situations at larger retailers. However, shopping at independent pet stores can offer a solution and support local businesses. In this article, we’ll explore the reasons behind supply chain disruptions, including labor and supply shortages, imported ingredient delays, and inclement weather. We’ll also discuss the increased demand for pet food due to higher pet adoption rates. Additionally, we’ll address the possibility of formula changes and provide guidance on finding assistance for out-of-stock pet food.
Large retailers such as supermarkets, big box stores, and even online retailers seem to have more significant out-of-stock problems than smaller independents. For you, this means that shopping at local independent stores could benefit you and the community you live in!
The Covid-19 pandemic has caused interruptions at every level of the supply chain, impacting various aspects that affect the availability of canned pet food. These disruptions, some of which may not have been previously considered, can take several weeks or months to manifest on store shelves. Let’s explore the key factors contributing to the slower production rates of canned pet food.
Labor shortages have had a significant impact on production, affecting livestock farms, canning facilities, and delivery drivers. These shortages have resulted from social distancing measures, lower facility capacities, and individuals needing to self-quarantine due to infection or exposure to the virus. With multiple instances of labor shortages, production lead times have increased from 1-2 weeks to 2-4 months. Consequently, some canned pet food manufacturers are currently unable to accept purchase orders. Certain brands or entire product lines may never resume production.
Supply shortages and delays are also contributing to the disruption. Livestock farms and slaughterhouses at the beginning of the supply chain have faced difficulties finding workers to process the necessary ingredients for pet food. Consequently, this has led to slower supply or temporary shortages. While there are alternative suppliers for common proteins like beef and chicken, more exotic options often experience long-term shortages.
Imported ingredients have encountered delays as well. Both national and international production facilities have implemented measures that require extended closures for quarantine, cleaning, and labor and supply shortages. Additionally, staffing shortages and safety measures enforced by the U.S. Customs and Border Patrol have prolonged the time imported products spend at ports, further exacerbating delays.
Inclement weather has also impeded transportation throughout the supply chain. Widespread delays caused by hazardous travel conditions and power outages resulting from winter storms have affected suppliers, production facilities, and retailers. Although this factor may not be the primary cause for empty shelves, it contributes to slower replenishment.
Many families took advantage of the extra time they’ve had the last couple of years and welcomed a new pet into their home.All those new pets inevitably brought a surge in demand for pet food. APPA reports 70% of U.S. households owned at least one pet in 2021, and pet owners have become increasingly interested in what they are feeding their pets. Wet and canned food, in particular, saw a dramatic increase in sales.
Some pet food manufacturers have chosen to discontinue or reformulate their recipes to bypass scarce ingredients to overcome some of the supply chain’s hurdles. So if your pet hesitates to eat his dinner, there may have been an ingredient swap that occurred. Be sure to check your pet food label to find possible ingredient substitutes.
If your pet food is currently unavailable, you likely have several questions in mind. Why is my pet food out of stock? Will it be restocked, and when? What alternatives are available for my pet’s dietary needs? Who can assist me in finding a comparable option?
Unfortunately, employees at Big Box stores are unlikely to provide answers because these large retailers do not have direct relationships with distributors. As a result, they possess limited or no information regarding out-of-stock items.
On the other hand, small independent pet retailers have the advantage of ordering and receiving products from multiple distributors. This proves beneficial when a particular supplier runs out of a specific item. Additionally, indie retailers maintain direct contact with distributors and enjoy close relationships with brand representatives. As a result, indie stores can provide accurate and real-time information sourced directly from the distributors themselves.
Moreover, indie pet store staff are well-equipped to assist you in finding suitable replacements if your preferred pet food is unavailable or discontinued. These recommendations are tailored to your pet’s needs, ensuring that they are not driven by sales goals but rather genuine concern for your pet’s well-being.
The below charts show a significant dollar amount increase for both dry and wet pet food formats. Dry food experienced a greater dollar growth; however it was actually a smaller percentage of growth in comparison to wet foods (data as of August, 2020). This means that there likely was more of a strain put on wet food producers, further adding to shortages.[vc_column width=”1/2″]
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Nicole Cammack
Nicole is the founder & owner of multiple-award-winning NorthPoint Pets & Company, in Connecticut, USA. She has completed undergraduate work in biological sciences, business and holds an M.S. in Nutrition. Currently, Nicole is pursuing a PhD in Comparative Biomedical Sciences (Canine Nutrition/Metabolomics) at the prestigious University of Georgia in the USA.
Her background includes experience in the pharmaceutical industry on multiple R&D projects. Nicole has had the privilege to learn from leading figures in the human and pet health industries. Nicole has been heavily involved in police canine nutrition within the USA, helping to improve the modern care and feeding of working dogs. Her interests include working dog nutrition, raw feeding, pathogens, metabolomics, and nutrition’s relationship to disease in humans and canines. Her current research involves the exploration of the canine urinary metabolome and the relationship to diet.
Publications: Cammack, N.R., Yamka, R.M., and Adams, V.J. (2021). Low Number of Owner-Reported Suspected Transmission of Foodborne Pathogens From Raw Meat-Based Diets Fed to Dogs and/or Cats. Frontiers in Veterinary Science 8. doi: 10.3389/fvets.2021.741575.
https://www.frontiersin.org/articles/10.3389/fvets.2021.741575/full
Contact:
https://www.linkedin.com/in/nicole-cammack-8400084b/?trk=author_mini-profile_title
Jenna Harrison
Jenna enthusiastically joined our team in early 2021 bringing nearly a decade of pet industry knowledge and experience along with her. She is a proud mom to cats Aerie and Spook who are both credited with her interest in pet nutrition. Quickly Jenna realized that there was a lot to be desired for honest, unbiased and accurate information within the industry and she knew she wanted to help change that. Much like the team at NPP, she believes in the value individualized diet, fresh food and tailored advice can provide for overall health, regardless of age. She also is the mom to 4 sugar gliders, Crumb, Crosby, Bindi and Gatsby which helps bring additional small animal knowledge to our robust team. When she’s not helping pet parents at NPP Jenna can be found hiking with her husband Adam, horseback riding and painting pet portraits.
https://todaysveterinarybusiness.com/pets-appa-survey-covid/ https://www.avma.org/resources-tools/animal-health-and-welfare/covid-19/covid-19-impacts-food-production-medicine https://www.petfoodindustry.com/blogs/7-adventures-in-pet-food/post/9165-how-prevalent-are-covid-19-pet-food-ingredient-shortages https://www.americanpetproducts.org/pubs_covidpulsestudy.asp https://foodindustryexecutive.com/2020/12/pet-food-and-treat-sales-stay-strong-in-an-unpredictable-year/#:~:text=In%20fact%2C%20US%20pet%20food,up%20by%20more%20than%207%25. https://www.petfoodprocessing.net/articles/14294-state-of-the-us-pet-food-and-treat-industry-2020
Recalls due to aflatoxin contamination have resulted in the retrieval of hundreds of thousands of pounds of pet food. Tragically, these recalls have caused the loss of hundreds, and possibly thousands, of beloved pets. You might be wondering why such recalls continue to occur. The truth is that preventable measures can be implemented to avoid recalls associated with contaminants like aflatoxin.
When pets fall ill or pass away, it can be incredibly frustrating for pet parents and those involved in the pet industry. Aflatoxicosis is the term used to describe illness caused by aflatoxin. Diagnosing it can be challenging as the associated symptoms are considered ‘non-specific.’ In other words, they are vague and can overlap with those of various other diseases and conditions. As a pet owner, what essential information should you be aware of?
Let’s dive into the fundamentals:
Aflatoxins, produced by fungi such as Aspergillus flavus and Aspergillus parasiticus, belong to a group of toxins that can be found on various agricultural crops including corn, rice, wheat, oats, peanuts, cottonseed, and tree nuts, among others. These toxins are particularly prevalent in warm and humid regions of the world and are permitted in both human and pet food at very low levels. However, the risk and level of contamination increase under specific temperature and moisture conditions.
Four types of aflatoxins, namely B1, B2, G1, and G2, have the potential to contaminate food. Among them, aflatoxin B1 is the most concerning due to its hepatotoxic nature, meaning it is toxic to the liver and can cause severe illness and even death in pets. Aflatoxicosis, often resulting from cumulative exposure to contaminated pet food, can worsen over time. Consequently, contaminated products may remain in circulation for weeks or even months before the source is identified, leading to a recall announcement.
Previous incidents in 2005 and 2012 witnessed multiple recalls of aflatoxin-contaminated pet food, resulting in numerous pets falling critically ill or losing their lives after consuming these products. More recently, Sunshine Mills in 2020 and Midwestern Pet Foods in 2021 faced extensive recalls due to the presence of deadly aflatoxin contamination.
If you suspect your pet has consumed pet food contaminated with aflatoxin there are several signs you should watch for. Be sure to alert your veterinarian and seek medical attention for your pet should any of these signs develop.
Your veterinarian or emergency clinic will conduct various tests to assess the health of your pet. In many cases, liver function tests, which are part of a comprehensive blood chemistry panel, can provide valuable clues for detecting aflatoxicosis. Elevated liver values, such as ALT (alanine transaminase) and AST (aspartate transaminase), are often observed in the test results. Additionally, increased total bilirubin concentrations and prolonged prothrombin time (PPT) may also be indicative of aflatoxicosis.
Pet owners frequently notice changes in their pets’ behavior, food intake, or energy levels around the time these symptoms begin to manifest. It is crucial to inform your veterinarian about any such changes as they can provide essential insights. Even small details can contribute to a better understanding of the overall picture. It’s important to note that unlike humans, pets consume the same diet consistently, which results in faster toxin accumulation in their systems. Consequently, their bodies may have limited time and capacity for detoxification in such situations.
Corn is widely recognized as a major contributor to aflatoxin contamination in pet food, making grain-free pet foods increasingly popular in recent years. However, it’s important to note that aflatoxin contamination is not limited to corn and remains a potential risk regardless of the type of pet food or its ingredients. To mitigate this risk, pet food manufacturers should diligently test all ingredients and final products for aflatoxin and other contaminants. Unfortunately, some manufacturers neglect this crucial step, leading to the presence of contaminated products in the market.
As a responsible pet owner, you can take action by contacting your pet food company or inquiring at the store where you purchase your pets’ food to ensure that the manufacturer implements adequate safety checks. Although safety checks are not currently mandated by law, contamination with aflatoxin would necessitate a product recall. Therefore, it is in the best interest of any pet food manufacturer to prioritize implementing rigorous safety measures.
Remember that every pet, as well as every person, is unique, leading to various factors that can impact a pet’s susceptibility to aflatoxicosis and other conditions. These factors include genetics, age, hormonal status, nutritional status, exercise, and other underlying illnesses, all of which can influence the severity of aflatoxicosis. In essence, even if pets consume the same food, their reactions may differ.
If you are feeding a currently recalled food, or if you suspect your pet may be exhibiting signs of aflatoxicosis:
If you want to know more about the types of questions you should ask your pet food company you can click here.
Morgan Hunt
Meet Morgan, a Veterinary Assistant/Technician at Branford Veterinary Hospital and a Pet Problem Solver at NorthPoint Pets & Company! She is a Certified Veterinary Technician. Her interests in the animal world are mainly behavior & nutrition. She has a Pit Mix named Tyson and a Dalmatian named Pongo who keep her on her toes learning more and more every day.
Nicole Cammack
Nicole is the founder & owner of award-winning NorthPoint Pets & Company, in Connecticut. She is also the Founder & CEO of Undogmatic Inc. 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 the human and pet health industry. She regularly lectures at national conferences, including federal, state, and municipal K9 events. Her current research involves identifying pathogenic risk factors and transmission among raw fed pets through a comprehensive worldwide survey.
You walk the aisles of your local pet store, or maybe you shop online – and you notice that your pet’s food, treats and supplements are marked “Made in the USA.” You think that this means it is free from any foreign ingredients, and therefore safe – right? Wrong. In fact, various ingredients can be sourced from anywhere in the world and then assembled (made) in the USA. And, suddenly we see how deceptive that “Made in the USA” claim can be.
China immediately comes to mind as a danger when we think about pet food and supply sourcing. This is because the 2007 melamine pet food recall was a rude awakening for pet owners in the USA. Prior to 2007, not many pet owners thought about where their pet food, treats, or ingredients contained within them came from. In fact, most recalls the decade prior were small in comparison and limited to excess vitamin D, methionine, and aflatoxin contamination.1 At the time, the melamine recall was the largest and most widespread recall of pet food in history – resulting in over 5,300 different products being removed from American shelves and at least four-thousand pet deaths.2 The biggest takeaway from this recall was that it included over 150 brands – those from grocery channel all the way to ‘premium’ brands. Showing that many companies sourced the same ingredients from the same places and utilized the same manufacturers despite what their marketing claims said. This is ultimately what prompted pet owners to start asking questions.
Melamine is an industrial chemical with uses ranging from a binding agent, flame retardant and as a polymer for utensils and plates. It has also been used as a fertilizer, although it is also not approved for use as such in the USA.3 For context, melamine-related compounds in the same family include cyanuric acid, ammeline, and ammelide. Melamine and related compounds have no approved use as an ingredient in animal or human food in the United States.3 Just knowing these facts, the thought that melamine was even introduced into the pet food supply is unsettling and it was only by sheer chance that these products did not make it into the human food supply.
The short version of the 2007 recall is that wheat gluten and rice protein were intentionally combined with melamine for its high nitrogen content. Higher amounts of nitrogen can cause the protein content of an ingredient to test higher than it actually is. In addition, cyanuric acid was also present and this combination of melamine and cyanuric acid is likely the reason the recall was so deadly – not the melamine on its own.3 This entire incident fueled the American pet owners obsession for ‘Made in the USA’ products. But are products that claim to be made in the USA void of ingredients from China? Maybe not.
The melamine recall gave rise to the “Made in the USA” mark on pet food packaging, and the current Covid-19 Pandemic is fueling another wave of consumer demand for these products. But what many consumers and pet owners don’t realize is that this term does not mean sourced in the USA. Instead, it means an American company could make pet food on American soil, but source ingredients like vitamin and mineral mixes from outside the USA and still put “Made in the USA” or “Manufactured in X US state” on the label. Further, many manufacturers will claim – at least verbally, that they do not source any ingredients or vitamins from China. So, is this actually the case? No, because most pet foods on the market contain a vitamin premix, at least in part that comes from outside the USA, which many include China. More on that in a bit.
The Federal Trade Commission (FTC) does oversee ‘Made in the USA’ claims – either expressed or perceived. This claim according to FTC standards means that all, or virtually all of the product must be made in the USA and contain no or negligible foreign content.4 According to the FTC standards, sourcing for foreign vitamin and mineral mix would be considered ‘negligible’ and therefore allow a pet food company to use ‘Made in the USA’ on the label so long as a significant majority of the remaining ingredients were indeed US sourced. One grey area here is that ‘negligible’ is not explicitly defined.
Further, negligible doesn’t necessarily mean a small amount of the final product because the FTC also takes into account the economic factors of where ingredients are processed and where the final product is processed.4 Simply, a fair amount of ingredients could be sourced outside the US, but the economic impact of processing the final product could potentially outweigh the outside sourcing.
Evidence of how misleading some companies could be can be seen in the recent case Weaver v. Champion Petfoods USA Inc., et al. The plaintiff in this case alleged that Champion Petfoods deceptively marketed their dog food products via claims such as “biologically appropriate”, “fresh”, “regional”, and “never outsourced”. In addition, he claimed that Champion should have to disclose trace amounts of BPA and pentobarbital – just for example.5 In short, the court dismissed all complaints because Champion Petfoods asserts that “biologically appropriate” is a nutritional philosophy – not a nutritional statement (aka a marketing tagline). Champion also asserts that they did not intentionally add BPA or pentobarbital to their foods – and also never warranted their products were free of these contaminants which releases them from any liability.
While rulings on all complaints favored Champion – it does not absolve them of the significant issues that have been exposed. It also doesn’t negate the fact that this is a loss for consumers who expect transparency and truth in what they are buying for their pets. The outcome of this case just proves the point that many of us in the industry often make: most pet food companies are marketing companies first, pet food companies second.
Ultimately this decision reinforces that manufacturers are not responsible for listing each and every material that may make its way into a final pet food product, nor are they required to be fully transparent on where and how ingredients are sourced.5 It also shows that many companies are not required, nor do they satisfactorily test inbound ingredients or outbound product for adequacy. Instead it provides examples of many of the marketing loopholes that manufacturers use to give the perception that the ingredients are superior, or sourced in one way over another – when in fact they are no different than other manufacturers.
One loophole that does not appear to have any regulation governing claims or advertising involves a phrase such as “Manufactured in our US facility” and/or “Manufactured in our Kentucky Kitchens”. Simply naming a US state is a gray area since this statement would be true, but it does not point to the sourcing of the ingredients. This is extremely deceptive to the consumer who is unaware of these details. Regardless, companies such as Tyson, Fromm, Wysong, Merrick, Wellpet (Wellness, Eagle Pack, Holistic Select) have had lawsuits dismissed as a result of this gray area – or due to gray areas under the FTC standards.6
There are multiple vitamin premix companies in the US that also source individual components from outside the US, including China. The way they get around that fact is they mill or blend the vitamin premix in US facilities and simply act as if as if ‘manufactured’ is the same as ‘sourced’ in the USA. Regardless, sourcing of a particular ingredient from the US or otherwise does not guarantee safety, and therefore doesn’t discount the need for adequacy or contaminant testing.
If pet food or vitamin premix companies advertise ‘made in the USA’ they should be willing to provide a certificate of origin for each of the ingredients on their label. Interestingly, most companies we surveyed were not willing to provide this information. Opening the discussion about vitamin premix sourcing opens up another complicated layer of pet food industry safety, sourcing and transparency. Although, as discussed, a certificate of origin for a final pet food or premix product would not ensure individual ingredients did not originate from outside the country of origin. For example, if a vitamin premix is formulated and combined in Germany – it can still have individual vitamins that are sourced from China or otherwise. The certificate of origin for the final product would say Germany. This is because the country of origin is defined as the country where the last substantial economically justified working or processing is carried out. This is the very reason why pet food companies may not understand their product contains ingredients from China – although ignorance should not be an excuse.
As of the date of this article, there is only one vitamin mix company claiming to be 3rd party verified to not source any ingredients from China.7 This sounds good, however, it is simply marketing because there is not an authority providing benchmarks for determining what 3rd party verification in this context means. In fact, there are several companies that perform the verification by sourcing and auditing. There are several non-China sourced vitamin premixes for pet food available in the market, but there is only one that advertises it. However – one must realize that there are some ingredients to these premixes that only come from outside the USA. For example, sources for L-carnitine only come from China or the Czech Republic, meaning that if a premix contains L-carnitine, that premix is not 100% USA sourced – despite any marketing claims. The same goes for some other vitamins and minerals as well.
The above considered, there are reputable premix companies that have been sourcing ingredients from places other than China both before and after the melamine recall. Some even make the ingredients themselves ensuring control over the process. These companies are the ones that continually receive awards and recognition for their blending, sourcing and commitment to quality each year. These companies also have marketplace longevity showing an extensive safety record. Simply, they don’t have to advertise their USA sourced, or non-China sourced ingredients because their reputation and performance speaks for itself. Vitamin premix companies that hang on advertising claims without verification, performance, or data to back their claims are likely a disaster waiting to happen. This is something that pet owners and pet industry professionals should be cognizant of.
We’ve learned that most US pet food companies who claim not to use ingredients from China aren’t exactly transparent. For instance, when companies are specifically questioned about whether they source ingredients from China, they typically respond in one of two ways: either stating that their ingredients are sourced “globally” (which, by the way, includes China), or claiming that such information is proprietary.
The proprietary response is a problem because companies will use this to hide certificates of origin for various ingredients, or the premix itself (China or elsewhere), or the fact that they do not perform adequacy testing. What the big miss here is that not all ingredients from China are bad. Yes, I said it – not everything that comes from China is dangerous – so long as a company is verifying safety and adequacy. In fact, ‘USA’ made or sourced should never be an excuse to not adequately test products.
The reality is that China actually owns and controls a vast majority of the vitamin and supplement market. The same goes for human vitamin products as well. Chinese companies were able to see the consumer trends toward health and wellness decades ago and purchased a large amount of businesses in this sector. As with anything else, there are bad players and there are some that go above and beyond – even exceed US quality in some instances. It’s common knowledge that some industrially produced vitamins and supplements from China pose significant risk. In addition, we know that this area is also a significant culprit for counterfeit medications. The concerns from this area are legitimate and created significant issues for countless people across the globe. However, these do not negate the fact that some legitimate supplies largely come from China or may be superior to others.
While high-quality ingredients coming from China may actually sound counterintuitive, we often forget that Traditional Chinese Medicine (TCM) dates back at least 23 centuries – likely much further. One of the foundational concepts of TCM is the balance of energy and includes the use of herbs, whole foods and other modalities to promote a healing effect within the body. While my description is oversimplified, the point is that those within the Chinese culture who embrace the philosophy of TCM believe in and understand the importance of high quality, clean and well-sourced raw materials and supplements. In other words, obtaining vitamins, minerals and supplements from reputable sources within China, or elsewhere, and then verifying quality and purity with 3rd party testing for use in pet food and human supplements can be safe.
In fact, the problem is that we are focusing on the wrong target. This argument is often used to disguise significant issues of our own. Instead of looking to place blame on one particular thing, we should be seeking to hold ourselves and others accountable. Instead of simply blaming China, we should realize that the problem is actually twofold:
Poorly sourced and contaminated ingredients can come from anywhere. We have allowed those within other countries and the US to get away with providing subpar and dangerous raw materials for a very long time. These adulterated ingredients could be by error, accident, be innocent, or intentional. As discussed earlier, incidents have originated from the USA as well as China. Instead, we should be asking pet food companies how they ensure the safety of their ingredients and product as a whole. Those questions include:
This question is important because it identifies whether or not a company has processes and procedures in place that would have prevented issues like the melamine incident and the recent Hill’s vitamin D recall. The pet food company or more likely the manufacturer that makes their products should have a Global Food Safety Initiative recognized 3rd party food safety certification (i.e. SQF, BRC, etc.). These certifications verify they follow procedures they have in place ensuring adequacy.
If the answer is yes, follow up questions should be: do those products meet an AAFCO nutrient profile? Are you willing to provide a copy of that analysis?
Note that most companies are deceptive and provide ‘target analysis’, which is what is predicted – not necessarily representative of what is in the finished product. Be careful with terminology here. In addition, beware of the word proprietary – this does not hold a strong argument and may be a tactic to hide lack of testing or inadequate testing. Most companies we surveyed either answered “no” or that this information was “proprietary”.
If the answer is yes, for any number of their formulations you should also ask if they make those publicly available. Again, proprietary is often used when this question is asked and that should be a red flag for any pet owner or pet store owner.
To assess digestibility, researchers feed a predetermined amount of the formula under study to several dogs for 14 days. Subsequently, they collect and analyze the stool to determine the percentage of absorbed macronutrients and micronutrients in comparison to the amount that was fed. This process does not involve any invasive procedures, inhumane conditions, or otherwise harm to the animal. Again, most of the companies we asked either refused to answer, claimed the information was proprietary, or indicated they do not perform this test. In short, companies that do not conduct digestibility trials remain unaware of the actual calorie content or digestibility of their food, which ultimately makes your pet the subject of experimentation.
Keep in mind that digestibility and typical nutrient analysis mean nothing without the other. Digestibility shows the amount of nutrients absorbed. The analysis shows the amount of nutrients contained within a product.
As we discussed, ingredients from China are not necessarily bad as long as they are well-sourced. Also, we now know that companies can and should be able to verify quality and purity via analysis and contamination testing of ingredients coming into their facility.
Again, if companies were analyzing their final product both for nutritional adequacy and contaminants many of the memorable recalls and pet food scandals could have been prevented. The same examples apply – the melamine recall, the Hill’s Vitamin D recall and it’s also highly likely the dilated cardiomyopathy (DCM) and grain-free debacle would never have amounted to the mess it has with these quality control measures in place. In other words, if companies were able to 3rd party verify that their foods contained required nutrients at appropriate levels and that those nutrients were digestible then grain-free foods, taurine deficiency, or other factors would not have been ‘blamed’ for DCM.
Ultimately, dangerous ingredients and products can come from anywhere. Believing that because something comes from the USA provides assurance of safety is arguably irresponsible. It’s also arguably reckless for companies to advertise USA made/sourced products in an effort to provide the perception of transparency. Ff companies don’t have solid quality control in place – it’s not a matter of if, but when, and how big or deadly that recall will be.
Now, with our understanding that it is highly probable that a portion of your pet food originates from China, and that ingredients from other regions could also pose a risk, we realize that these risks are persistent and cannot be disregarded. Instead, it’s up to us to ensure we’re supporting companies who are doing the right thing.
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