Discriminating against raw foods is it fair? A survey of raw pet food Manufacturers By Meg Smart DVM PhD

Raw  Pet Foods

AVMA and AAHA Partnership
On July 18, 2012 the and American Veterinary Medical Association  (AVMA) announced the formation  of  partnerships o in preventive health care  for pets in order to address the declining health of the nation's pets. Members of the partnership include the American Veterinary Medical Association, the American Animal Hospital Association (AAHA), Association of the American Veterinary Medical Colleges, and health industry leaders including Abbott Animal Health ,Banfield Pet Hospital, their healthcare LLC animal health division, Boehringer-Ingelheim Vetmedica Inc, ButlerSchein Animal Health, Elanco Animal Health, Hill's Pet Nutrition, Merek Animal Health, Merial,MVVI Veterinary Supply, Novartis Animal Health US Inc., Pfizer Animal Health and Veterinary Pet Insurance all sponsoring initiative at various levels. This partnership was formed because of a decrease in regular veterinary visits and an increase in preventable illnesses in dogs and cats.

A task force assembled by the American Animal Hospital Association and the American Veterinary Medical Association  developed and approved concise easy to understand  comprehensive preventive health care guidelines for dogs and cats. For more information visit the website www.PetHealthPartnership

At the AVMA 2012regular annual session  passed resolution five, that the AVMA discourages the feeding to cats and dogs of any animal based protein source that has not first been subjected to a process to eliminate pathogens because of the risk of illness to cats and dogs as well as humans.

AAHA has come out with a similar statement indicating raw protein diets are now demonstrated to be a health risk for several groups:

·         the pets consuming the diet

·         Other animals in contact with those pets

·         humans, and family members

·         The  public

Bacterial Contamination of Pet Food

All raw food will contain live microorganisms. The significance of these bacteria and their importance in either preserving the health or causing illness in the animals ingesting them is the subject of great debate. As complex life forms evolved a relationship with the microbial organisms within the environment developed. This relationship is intricate and can be both beneficial and destructive. During the evolutionary process, life forms developed a symbiotic relationship with the microbial organisms within its environment. This relationship is extremely complex and we're just beginning to understand it now.

A study published in 1993, Stone et al utilizing the techniques available to them found that the Salmonella serovares isolated from the dogs feces were identical to those found in the raw diet. Dogs that were clinically ill showed a similar pattern. Clostridium perfringens endotoxin was also found in the diuretic feces its role in the gastro enteritis was not investigated. Verotoxin (E. coli O157:H7) was not found. Although this trial demonstrated a clear relationship between Salmonella and gastroenteritis in greyhounds several questions still remain unanswered. The age, the training level, and racing records and reproductive status were not identified for any dogs in the study, so one cannot answer the question whether stress was a predisposing factor. Also the authors commented on the potential risk that dog handlers were under, but no attempt was made to investigate whether the kennel personnel ever became sick or were carriers of Salmonella. (Stone, G. G, Chengappa, M.M., Oberst, R.D. et al. application of polymerase chain reaction for the correlation of salmonella serovars recovered from Greyhound feces with their diet .J Vet Diagn Invest 1993 5:378-385. Is about as an

A review article in 1976 indicates that the widespread and natural occurrence of canine  subclinical Salmonella infections is well documented. This is attributed to coprophagia and eating carrion. This review referenced published papers that go as far back as 1948 (Wolff A.H., Henderson N.D., and MacCallum G.I. Salmonella from dogs and the possible relationship of salmonellosis in man Amer J Pub Hlth. 38: 403-498 1948) the authors conclude that dog can harbor 53 salmonella sero types with a prevalence of as high as 27%. Most cases in dogs are subclinical... The most common etiological agents are S. typhimurium and S anatum (Morse E.V., Duncan D.A., and Ester D.A. et al Canine Salmonellosis: A review and report of dog to child transmission of Salmonella enteriditis. AJPH Vol66:82-84 1976

In an article published in 2001 expressing public health concerns associated with feeding raw meat diets to dogs reflects more into the practices and level of hygiene associated with slaughter animals intended for human consumption. In general the meat products not intended for human consumption are rendered and made available as dry meal to the dry pet food manufacturers. This article covers a wide variety of potentially infectious and parasitic diseases present in the meat generated from our packing plants and fish. The authors’ conclusions are never to feed raw meat or fish and limit access to carrion and hunting. They encourage the feeding of commercial pet foods as an excellent source of nutrition (LeJeune J.T.and Hancock D.D. public health concerns associated with eating raw meat diets to dogs JAVMA Vol2191222-1225, 2001)

 An article on systemic salmonellosis in two cats fed raw meat diet is often quoted as evidence that feeding raw meat-based diets to cats can result in clinical salmonellosis. What this case study does not report is the number of cats in the household being fed the diet, the number of people in the house exposed to these cats, and whether Salmonella was cultured from other areas of the house, and whether these cats were housed indoors or outdoors. This report does however indicate that salmonella in cats is considered uncommon disease and clinical  cases are often associated with some kind of stress either  another disease, infection  or environmental (Stiver S.L.,Fraizier K.S., Mauel M.J. and Styer E.L. J Am Animal Hosp Assoc 39:538-542, 2003)

Research was conducted in Minneapolis-St. Paul area looking at the availability brands, salmonella contamination and labeling of raw pet food. Sixty raw meat diets were purchased representing 11 brands. These diets were raw frozen, dehydrated or freeze-dried. The protein sources represented where lamb, beef, chicken or duck. None of the stores provided food borne illness warnings. On the label nutritional adequacy by formulation only and the cautionary statements varied. 71% of the diets tested positive for salmonella. The authors recommended that warning statement be included on all labels. No mention was made as to how the meats were handled after the animals were slaughtered and what meat was used in the raw diets. (Mehlenbacher S., Churchill J., K.E., Bender J.B. availability, brands, labelling and salmonella contamination of raw pet food in the Minneapolis St. Paul area. Zoonoses Public health2012 10: 1883-2378

In another study 240 raw samples from 20 raw meat diets 20 samples from 2 dry dog foods and 20 from 2 canned dog foods were purchased commercially on 4 dates to one apart. 53% of all products cultures non type specific Ecolab during at least one culture period, 5.9% of raw diet contained Salmonella enteric. Their conclusion was that bacterial contamination is common in raw diets (Strohmeyer R.A., Morley P.S. Hyatt D. R. et al 2006. Evaluation of bacterial and protozoa contamination of commercially available raw meat diets for dogs. J Am Vet Med Ass VOl228 (4):537-42

A review article in 2006 indicates a lack of information exists on how natural pet treats and raw food diets can affect the health of pets and owners. An estimated 1% of reported cases of Salmonella annually are related to contact with companion animals. As of 2006 raw pet foods have not been associated salmonellosis in humans , the authors also indicate the risk to human posed by handling and feeding of pet treats and raw food diets remains unqualified suggesting the reasons are lack of clinical symptoms in dogs and cats shedding salmonella, the underreporting of health risks by those in human medicine and veterinary medicine, the expense of culturing and susceptibility testing and a lack of a formal system for collecting data on zoonosis in companion animals. This does not hold true for the cases of human salmonella associated with dry dog foods where the cases have been identified and the source of salmonella identified. The authors  go on to describe ways in which to increase to probability of proving a health risk exists.(Finley R., Reid-Smith  R., Weese J.S. 2006 Human Health Implications of Salmonella contaminated Natural Pet treats and Raw Food Clinical Infectious Diseases 42:686-91)

The authors of another review article published in 2011 concluded “Clearly, there is some compelling evidence may be a theoretical risk nutritionally. Although the authors state that raw food poses a substantial risk of infectious diseases of the pet, the pets environment and the humans, level 1 and level 2 evidence is still needed (SchlesingerD.P. and Joffe S.j. 2011,Raw food diets in companion animal: A critical review. Can Vet J 52 54—53.

Study	Design	Results	Conclusions
Leonard E K. et Al 2011Zoonoses and public Health 58:140-149	Cross sectional design	23.2% of dogs had one sample positive	Highlight the potential health risks of  feeding raw animal products
	Oct 2005 to MAY2006 138 dogs from84 households	25% of the households had at least one dog shedding
	5  consecutive daily fecal samples from each dog samples	12 serotypes of S.entericasubsp. enterica identified
		Serotypes Typhimurium (33.3%), Kentucky (15.4%) Brandenburg 15.4%, Heidelberg(12.8%)
		Risk Factors: Livestock contact. Probiotics previous 30 days, commercial, raw or homemade dog food More than 1 dog In a 2 variable model only raw animal products were significant
Finley R. et al 2008 Zooonoses and Public Health55:462-469	166 commercial frozen raw food diets randomly selected from local pet stores in 3 Canadian  cities for a period of 8 months	The overall prevalence of Salmonella was 21%: 67% of diets contained chicken	Demonstrates  risk of raw food diets and the need for implementing  regulatory  guide lines for the production of these diets to control and eliminate bacterial risk associated with their consumption
		18 serotypes
		Resistant to 12 of 16 antimicrobials tested

Finley et al 2007 Can Vet J 48(1):69-75	16 dog were fed Salmonella  contaminated commercial raw food diets 12 Salmonella free commercial raw food diets	Seven exposed  dogs shed Salmonella 1-7 days after consumption Five  of the seven shed the same serotype as diet and 2 of the seven had same serotype and a  antimicrobial resistance pattern	Dogs fed salmonella contaminated raw food can shed and therefor may be a source of contamination
SinellH.J.,Klingbeill H., Benner M 1984 J of Food Protection 46(6):482-484	408 sample s of liver, lung, bovine rumen and pig oesophagus  examined over a 26 month period from slaughter animal judged suitable for human consumption	56.6%had 24 types of Salmonella S. typhimurium the most prevalent 8 strains of var Copenhagen most frequent was pig esophagus lest frequent was pig liver and bovine rumen
Morley et al 2006 J Am. Vet Med Ass 228(10):1524 1532	Cross sectional study Food fecal and environmental sample s collected and cultured for Salmonella Isolates serotyped and tested for susceptibility to 16 antimicrobial plus PFGE, ribotping	S. enterica isolated from 6% of all samples and 93% of fecals 94.3% Serotype Newport 87% had identical resistance. Multiple strains cultured from the raw food	Raw food was likely the source
Wong T L 2007J Applied Micro1103(4):803-807	300 sample from imported and domestic pet chews were cultured for Salmonella	5.3% of imported and 6.7 % of the domestic chews were contaminated	Imported pet chews  are a source of novel pathogenic and antimicrobial resistant   Salmonella Contaminated pet chew a are potential source of Salmonella

Table 1 Peer reviewed articles on microbial  contamination of raw pet foods

A Survey of Some Popular Raw Food Manufacturers about Quality Control, Safety and Nutritional Adequacy

Preamble to Survey:

 Research indicates that the link between the feeding of raw diets (which contain bacteria such as E.coli and Salmonella rarely pathogenic) and disease in the pets or their owners is very weak , yet the link between the feeding of dry kibble and clinical cases of salmonella in humans is well documented. I am contacting you as a member of CARPFM (Canadian Association of Raw Pet Food Manufacturers) or a raw pet food manufacturer outside Canada, to ask if you will answer the following questions ( I appreciate that you may not want to reveal some of this information for business reasons

1) The practices you have put in place to insure there is minimal bacterial contamination of your finished product?

·         www.reddogdeli.com> All our materials come primarily from federally inspected facilities that are required to do pathogen testing. Processing for all products is done in a temperature-controlled environment (below 40 degrees) to prevent bacteria growth and flash-frozen. Our facility is cleaned and sanitized on a daily basis. We do random batch testing with an independent lab to ensure this is effective. We are currently working on setting up in house testing so we can do basic pathogen testing on every batch.-

·          www.sojos.com We have a proprietary process that involves sterilizing and testing the frozen meat and then testing again after the freeze drying process to ensure the absence of food borne pathogens.

·         K9natural: Human food hygiene standards are followed in the k9 factory

·         www.artisanrawdogfood.com My product is produced in a provincially inspected plant and we use only human grade products. My product is as safe or safer than eating any meat from any grocery store

·         Mountain Dog Food:: We use fresh product shipped to us  from federally regulated plants that would otherwise be destined for the human consumable ,market. The product is held at temperatures that limit bacterial growth throughout the process and processed in time frames that limit growth

·         Spring Meadows : As the Canadian Pet Food Industry continues to grow across Canada, the Canadian Association of Raw Pet Food Manufactures has announced the implementation of a new “Good Manufacturing Practices Recognized Quality Standards” initiative.  This initiative provides an accomplished measure of Pet Food Safety and Quality Programming within the Canadian Raw Pet Food Industry.

·         www.naturesvariety.com:Instinct® Raw is made in the Midwest in our company-owned manufacturing facility. We utilize robust systems to ensure the quality and safety of all of our foods, including Sanitation Standard Operating Procedures (SSOP’s), Good Manufacturing Practices (GMP’s), A Hazard Analysis & Critical Control Points (HACCP) program, regular lot segregation, and other human food industry best practices. As part of our food safety protocols, we also utilize a 100% natural process called High Pressure Processing (HPP) to ensure food safety. This USDA-approved process kills pathogenic bacteria under pressurized chilled water, so the food is quality assured to be safe without being cooked. In addition to the steps lis All of our poultry, pork, bison, and beef come from the U.S. and our lamb and venison are imported from Australia and New Zealand. Our vegetables and fruits are sourced from the U.S., Europe, and the Middle East, depending on the ingredients. Our grains and starches are sourced from the U.S., Canada, and Brazil - herbs and spices from North America, Europe, and the Middle East. Our pharmaceutical grade vitamins and minerals are from North America, Europe, the Middle East, and Asia. The rabbit protein we use in our raw diet is from China. The rabbit in our canned is sourced from Italy and China, while the rabbit in our kibble is from France. We employ a U.S. educated food scientist in China to oversee our rabbit sourcing. All rabbit protein is tested before shipment from China and again after it arrives in the U.S. for processing into our raw diet. We are very confident in how we handle our sourcing from China. We source most of our ingredients from the U.S. and turn to other locations only as needed. We are very stringent on our sourcing and have good relationships built with our vendors for quality ingredients.ted above,

2) Do test for bacterial contamination, how and have you set an acceptable level?

·         www.reddogdeli.com  We do testing for salmonella, Ecoli and listeria on random batches using a human-food laboratory. These test return positive or negative. Positive results means the batch cannot go out to market.

·         www.sojos.com According to FDA standards there is no acceptable level for pet foods so we operate on a zero tolerance

·         K9natural: Every batch is tested for enterobacteriaceae (< 300), e-coli 0157:h7 (nil), salmonella (nil),

·         www.artisanrawdogfood.com We do not test. However, we use the same health standards used for making human grade food and we wash rinse and sanitize all equipment after each use.

·         Mountain Dog Food:: Yes, we have monitoring program that uses ongoing sampling to identify inadequacies in our process program. While we do not inspect each batch, we do continual environmental and product sampling.

·         Spring Meadows: Yes we test weekly for bacteria.  We used the same standards that are set out in human consumption.  With the GMP (Good Manufacturing Practises) program we have implemented cleaning procedures and testing procedures for the whole Plant and the equipment inside it along with procedures for handling product.

·         www.naturesvariety.com: Nature’s Variety utilizes a “test and hold” protocol to ensure that all raw products test negative for harmful bacteria before being released for sale. Finally, we stand behind our products with a 100% Satisfaction Guarantee. To learn more about Nature’s Variety’s extensive food safety and quality protocols, please visithttp://www.naturesvariety.com/learning/raw/quality.

3) Have you discussed food safety and asked for assistance from any federal or provincial agency?

·          www.reddogdeli.com We have been working with other members of the Canadian Association of Raw Pet Food Manufacturers to put together guidelines for the industry. These guidelines were made with recommendations from the CFIA in Alberta. We are currently in the process of working with the BC Food Safety Council to set up inspections for our facility.

·         www.sojos.com : We have documented Good Manufacturing Practices and Hazard Control Protocol to ensure safe manufacturing. We are periodically inspected by the USDA and our state veterinarian

·         K9natural: all supply plants, production facilities, transport operators and storage facilities of product are controlled by nzfsa (New Zealand food safety authority) under a risk management programme. Major factory audits are carried out every 6 months and inspections every month.

·         www.artisanrawdogfood.com No

·         Mountain Dog Food:: Most if not all of our people have taken programs offered by the Alberta Food Processors association as it relates to HACCP function, and operation. Using their very well put together online learning tool our people understand what good bacterial control is and how it works. Through these programs we have reduced environmental bacterial loads to acceptable levels and can now say that we maintaining them at those levels.

·         Spring Meadows: We employed the Food Development Centre in Saskatoon to help us set up and implement our GMP program.

4) Have you ever had your plant inspected or sample take for culture for a retail store or your manufacturing plant?

·         www.reddogdeli.com Regular inspections are being set up in the next 6 months.

·         www.sojos.com: Yes, USDA takes random samples of product from the plant and from retail stores. We also have our facilities inspected and testing by a 3rd party lab.

·         K9natural:None

·         www.artisanrawdogfood.com : The plant is inspected by Calgary Health region in accordance with their routine checks of all food production plants.

·         Mountain Dog Food:: As part of the Canadian Association of Raw Pet Food Manufactures we have adopted their program of guidelines for production of raw pet food. Mountain Dog Food was instrumental in designing and writing these guidelines. As part of the guidelines we are expected to challenge the inspections process that includes a scoring done by a third party inspector (we use the Alberta Food Processors inspections group). There are no government agencies that will or can do this job

·         Spring Meadows: Yes we have as a member in good standing of the CARPFM we have to have an annual inspection( by a third party auditor) and pass the inspection with a minimum of 85% to be able to display the associations logo on any advertising or packaging.  We passed our last inspection with a 95.5%.

5) Have you ever recalled any of your products and if so why?

·          www.reddogdeli.com No. We have never had any batch come back positive from the plant.

·         sojos.com: No

·         K9natural: None

·         www.artisanrawdogfood.com Never recalled but I have kept some product back that was partially thawed

·         Mountain Dog Food:: We have never had a recall… or recalled any production

·         Spring Meadows: No we haven’t recalled any product as of yet.  We have a Recall Procedure in place that coincides with batch, production and best before dates.

6) How do you test for the nutritional adequacy of your products?

·         www.reddogdeli.com We have done a nutritional analysis on our products.

·         www.sojos.com: We use biochemical lab analysis in order to certify that our diets meet or exceed the AAFCO nutrient profiles.

·         K9natural: firstly with the aid of certain software a product formulation is constructed which will enable a meeting of affco nutritional profiles to be achieved. Thereafter lab testing further confirms this in addition to any nrc  guildlines as per 2010 publication.  As a company k9 natural is also conducting feeding trials via Massey university (following affco protocols)

·         www.artisanrawdogfood.com: We have done two things. Firstly we balance our product based on a prey model for bone, fat, meat, offal and vegetables. We also double grind our veggies so they are more bioavailable to the dogs. In addition we use multiple sources of protein so that the dog gets white meats, red meats, veggies, salmon, offal, eggs, etc. Each puck is completely balanced. The second way is that when coming up with the formula we used the tests according to the AAFCO feeding trial tests. We have had more than 30 dogs fed our food for over 6 month and maintain or improve their health.

·                     Mountain Dog Food:: We have a blending program we developed internally, that can identify with very respectable accuracy the nutrient profile of our blends. This is then compared to the AFFCO, NRC, (and old CVMA) standards to ensure we are within parameters or identify short comings that may need to be addressed depending on the goals of the formula.Most of our products have been in the market for a decade and we have yet to see any feedback indicating deficiencies.Our biggest concern is that many of the nutrient minimum levels are set not as a function of need but to cover up the short comings in the dietary sources. When we put together our nutrient profile and did some investigative work of whole animal studies we were a bit shocked to learn that no animal exists, or mixture of animals, could be blended to meet the standards. It was only after the fact that we realized, that it appears, some of the standard was set to 'improve' the nutrient take up of nutritional sources. So we are sceptical of its value (the standards) and its origins.

·                      Spring Meadows: We employ Sun West Labs to do our nutritional analysis and the Food Development Centre to do the shelf life analysis.

7) Any additional comments would be welcome

·         www.reddogdeli.com We used non-medicated meats because we believe that animals raised in natural conditions are less likely to be ill or have a high pathogen count. For poultry for example, free-run/free-range poultry is much less likely to have salmonella and the strands it may carry would not be anti-biotic resistant.

1)      http://www.cbc.ca/marketplace/2011/superbugsinthesupermarket/

Salmonella Recalls Associated with Dry Pet Foods

A case control study of S. schwarzengrund primarily in young children was the first reported incident in dry pet food. 79 patients in 21 states were identified 48% were 2yrs old or younger This study covered 3 years and centered around one pet food manufacturer and the organism was cultured from the enrobing/flavour room. This plant recalled 105 of  dry cat and dog foods before permanently closing.(Jones T., Ingram L.A.; Fullerton K.E. e tal. www.pediatrics.org/cgi/doi/10.1542/peds.2006-1218.

The most resent recall involved dry dog and cat food with 49 human cases reported.These illnesses came after the recall of at least 11 brands of dry dog food that were all manufactured at Diamond Pet Foods' plant in Gaston, South Carolina, USA. Lab tests confirmed that those sick were infected with a rare strain of Salmonella infantis, which was linked to the outbreak using DNA fingerprints of the bacteria. Those infected became ill between October 8, 2011, and April 22. Total human cases reported in the USA include three in North Carolina, three in Missouri, two in Ohio, two in Pennsylvania, and one each in Alabama, Connecticut, Michigan, New Jersey and Virgina (PET Food Industry news release http://www.cdc.gov/salmonella/dog-food-05-12/index.html (http://www.petfoodindustry.com/Default.aspx?pageid=5307&id=46583&terms=salmonella) (http://www.cdc.gov/salmonella/dog-food-05-12/index.html).

Discussion

Although I have not done an extensive literature search I found many peer reviewed scientific articles about the contamination of raw dog foods with Salmonella appearing as early as 1949. None of these articles found human illnesses associated with this contamination as many of the Salmonella were considered non-pathogenic as opposed to the human cases associated with dry pet foods. One has to ask why the sudden flurry of activity in making strong accusations and recommendations about the risk of raw pet foods by the AVMA and AAHA. I believe if recommendations are to be made they should be made for all pet foods no matter how they are manufactured