Pentobarbital in Pet Food: What is it and how does it get there?

In light of the most recent pet food recall I wanted to take a little time to talk about a chemical that has popped up in not one but two recent pet food recalls: Pentobarbital.

There’s what in where?!?!

Let’s start with “What is Pentobarbital?” Pentobarbital is a drug that in low doses can cause sedation and drowsiness and in high doses can cause respiratory failure and death. Its primary use in veterinary medicine is as a euthanasia solution for all types of animals and it is not an approved ingredient in pet foods and is considered an illegal “adulterant” in pet food.

What’s in Place To Stop It From Actually Getting Into Pet Food? According to the USDA regulations for human foods, any “Product found to contain violative levels of residues is considered adulterated and is subject to condemnation”. Meaning meat or meat products that have drug residues or potentially deleterious (to people) compounds are condemned and prevented from entering the human food supply. That does not mean that it automatically goes into pet foods though.  The AAFCO Model Bill and Guidelines used for pet food manufacturing reference the United States Code and the Code of Federal Regulations of the Food and Drug Administration Sec. 402 [342] to help ensure pet food ingredient quality and safety.

The actual wording of the FDA regulation …

“ADULTERATED FOOD

Sec. 402 [342]

A food shall be deemed to be adulterated –

(a) Poisonous, insanitary, etc., ingredients

(1) If it bears or contains any poisonous or deleterious substance which may render it injurious to health; but in case the substance is not an added substance such food shall not be considered adulterated under this clause if the quantity of such substance in such food does not ordinarily render it injurious to health”

Because Pentobarbital is considered a compound that is “injurious to health” even at low levels animals euthanized with Pentobarbital are not allowed to be used in pet food manufacturing.

So How Could It Get Into Pet Food?? In the United States, food animals (cattle, pigs, sheep, and goats) must be healthy enough to walk into a slaughter facility and any animal that is unable to walk (is “down”) or shows signs of illness must be individually inspected and cleared before and after slaughter to ensure that it is safe for the human food supply. FYI – just about everything in pet food is considered a “by-product” of the human food supply chain so human health safety is always the first check-point. For any of my really keen readers, more information about USDA animal inspections can be found here. Animals that are not healthy enough for traditional slaughter methods (ironic I know) can be humanely euthanized (i.e. injected with Pentobarbital) and their remains segregated to prevent them from getting into any food supplies. And again, Pentobarbital is not an approved ingredient in pet foods and is considered an illegal “adulterant”, so the short answer is that it shouldn’t.

So How Did It Get There??? The only way for detectable levels of Pentobarbital to be found in pet foods is through inclusion of animals (animals plural, as in probably more than one) that were killed by use of this euthanasia solution. A survey of dry dog foods sold in the Maryland area and published in 2002 by FDA-Center for Veterinary Medicine (CVM) found low levels of Pentobarbital in some of the foods tested, but it was in the part per billion (ppb) not percentages (% = parts per hundred). The levels in the dog foods tested  were well below what would be considered acutely toxic or harmful to dogs, but because of the concern that chronic low dose exposure could become harmful if ingested daily for years, many pet food manufacturers (including Big Pet Food) began testing for and excluding animal products with detectable Pentobarbital levels.

You Didn’t Answer the Question, How Did Pentobarbital Get Into the Food???? That I don’t know for sure, but the FDA-CVM released a statement today on their preliminary finding related to the first recall. It looks like the raw beef supplier was using a slaughter facility that was not following USDA protocols. If we combine that with an absence of quality and safety testing from the manufacturer or raw material supplier on that raw beef as it come in, then we have the perfect combination of safety failures to result in potential harm to our companion dogs and cats.

How Can I Trust My Pet Food?????  All of the large and many of the medium to small-sized pet food manufacturers have regular and enforced Quality Control standards.  Mistakes happen, but if the pet food/treat manufacturer has established and enforced Hazard Analysis Critical Control Point (HACCP) and Food Safety Modernization Act (FSMA) protocols in place a situation like this would have been found and prevented before the contaminated meat found its way into the pet food supply. These types of manufacturing checks and balances are designed to keep our companion animal’s (and our own) food safe, but they only work if the companies involved uses and enforces them. If a pet food manufacturer does not conduct any inspection or testing of the raw materials they receive, that manufacturer is relying on the integrity of their raw material supplier to provide the ingredients ordered. If that raw material supplier is in turn not routinely inspecting or testing animal products from the slaughterhouses and rendering facilities they work with then nobody in that pet food company really knows what is going into the foods that bare their name.

There are companies big and small out in the pet food marketplace that have a commitment to health and wellness, not just profit. Those pet food manufacturers are committed to producing high-quality pet foods and will inspect and test their raw materials before they are mixed into a food and will sample and test the finished products before and after they go to market. It is important to know not only who makes your dog or cat’s food, but also if they are doing it the right way.

Gratuitous cat picture, because cats.

Happy Feeding!

Lisa Weeth, DVM, MRVCS, DACVN

 

 

 

Quality Control (and potential gaps therein) in the Pet Food Industry

I know, I know. It has been a while since I’ve added a new entry to the weethnutrition blog.  Last year turned out to be eventful in the Weeth household (as well as the world). We were living in the United Kingdom to witness Brexit first hand and then moved back to the United States in time for the 2016 elections and all the drama that entailed. I had the opportunity to speak to veterinarians on three continents about the importance of nutrition in the health and wellness of their patients, wrote a few articles, started a business in Los Angeles, and started training for the London Marathon.

However you lean politically and whatever your own crazy, busy schedule I think we can all agree that keeping our companion animal’s food supply (and our own!) safe and healthy is a priority. The problem is that the current pet food labeling standards and misinformation peddled by certain pet food companies and pet stores big and small make this challenging for caregivers and veterinarians. Just take our most recent pet food recalls as examples.

Annabelle and her “don’t even think of feeding me that slop” look.

In the last two weeks we had a recall because of a contaminant that could potentially kill dogs eating the food, followed by two recalls, one for dog food and one for cat foods, because of the potential for foreign material (namely metal bits) to show up in the cans.  I actually heard someone try to point to these recalls as “proof” of the problems with Big Pet Food’s corporate greed, while completely ignoring the fact that these recalls have affected small to medium size pet food providers. In my opinion, these recalls actually point to a bigger problem in the pet food industry, the disparity between the quality control standards of different manufacturers. I covered some of this in one of my past posts, but given these recent recalls I think a certain aspect of pet food manufacturing, co-packing,  warrants a focused topic all on its own.

…these recalls actually point to a bigger problem in the pet food industry, the disparity between quality control standards of different manufacturers.

What do I mean by “co-packing”?

In almost every industry there are more people with ideas for products than there are companies that exist to make those products. There is a whole specialty business in  “contract packing” (or co-packing for short) for beauty products, home-goods, beverages, snack foods, and yes, pet foods. There is a link to a pretty good pro/con graphic here.

Muti-use & multi-purpose equipment (image taken from http://www.animalfoodmachines.com)

Benefits of co-packing a pet food…

• Lower manufacturing cost: co-packers already have a factory in place
• Experience: they make lots of foods for lots of different companies
• Lower ingredient costs: they can buy in bulk, lowering the cost of starting materials for any one brand

Sometimes cheesy stock graphics are right, working together can be good for everyone.

Risks of co-packing a pet food…

• Potential lack of oversight: independent testing or audits are not required unless dictated by the owner of the pet food label
• Potential for unknown ingredient quality: co-packers can change raw material supplier at their discretion (like what happened in 2007 or what a certain heavily marketed pet food label claimed happened that caused them to lose a class action lawsuit)
• Potential for cross-contamination: lots of different foods may run through the same production lines (not so good for animals with ingredient sensitivities or allergies)

What is really in that can???

 

What does this mean for you as the dog and/or cat caregiver?

Know who manufacturers your pet’s food.  Every pet food label on every pet food sold in the Unites States (and Canada if they are following AAFCO label recommendation) will have a statement that says “Manufactured for…” or “Manufactured by…”.  This does not mean that co-packed foods are always bad and companies that make their own are always good, but having manufacturing in-house will give the company greater control and accountability for the ingredients that come in and foods that go out with their names on it.

If the brand you and your furry companion like best are made by a third-party co-packer, ask the company who makes their food (they probably won’t tell you, but if they do that’s a plus) and what kind of independent quality control tests they run.  At a minimum, they should be requiring third-party audits of the co-packer’s processing and raw materials and be conducting their own safety and quality control testing on the finished products.  Don’t let them get away with telling you that they run a “proximate analysis” and that this is good enough. Proximate analysis testing is used to determine the values of key nutrients (particularity protein, fat, fiber and water) and is used to populate the Guaranteed Analysis table on a pet food label. It is one of the minimum standards required by law for labeling and doesn’t tell you anything about the quality of the food or it’s safety to your dog or cat. For companies that make their own foods, the same requirements apply: what kind of quality control testing do they have in place?

Know who manufacturers your pet’s food!

One of the key differences between various pet food companies (at least in my opinion) is not their size, but their commitment to companion animal health and wellness. Do they have an idea, make a food, and sell it no questions asked?  Or do they have rigorous product testing and safety checks built in to catch problems before they reach the dog or cat consumer and their human caregivers?  If something does slip through do they act immediately to correct it, own the problem, and put checks in place to prevent it from happening again? Or do they shift blame to someone else? Do they just want to make a profit, or do they want to keep your dog or cat healthy for years to come?

Me and Dusty-Loki, the cat with two names but one love in life…food. Definitely not thrilled with this photo shoot.

Happy Feeding!

 

Lisa Weeth, DVM, MRVCS, DACVN