On Monday, FDA officials issued another disappointing update into their ongoing investigation into the mystery surrounding the illness and death of thousands of dogs linked to jerky pet treats. The report covers, in excruciating detail, the culmination of nearly ten years of work. Unfortunately, microbiological and toxicological testing of treats remains inconclusive:
“To date, testing for contaminants in jerky pet treats has not revealed a root cause for the reported symptoms in pets.”
Since the investigation began in 2007, FDA has received approximately 5,200 complaints of illness associated with consumption of chicken, duck, or sweet potato jerky treats, most of which involve products imported from China. The reports involve more than 6,200 dogs, 26 cats, three people, and include more than 1,140 canine deaths.
Sadly, these numbers are just the tip of the iceberg, because the vast majority of illnesses go unreported simply because so many factors must come together for the reporting to occur.
SOME IMPORTANT GAINS
On the surface, it would appear that the FDA has made an enormous effort to locate the cause, testing the treats for what they believe are the most likely toxicological suspects. They are developing and improving tests for chemicals for which none had previously existed.
Importantly, the FDA collaborated with the Centers for Disease Controls on a study to determine whether jerky pet treat exposure is associated with illness in dogs. The goal of the study was to compare the foods eaten by sick dogs to those eaten by dogs that did not get sick to better understand what is making dogs sick. The manuscript of the study has not yet been published.
ADULTERATED PRODUCT REMAINED ON THE MARKET
A closer look reveals a troubling picture, one where officials claim to be hampered by a lack of resources and tests that do not exist, animal studies that have yet to be done and adulterated pet products remain on the market.
An even deeper examination reveals some disturbing inconsistencies, omissions, and mistakes in the report. The report uncovers, that despite tremendous knowledge gaps in science, when food regulations were violated, and contaminated products were discovered, no regulatory action was taken. Repeatedly, products that were found by the FDA to contain ingredients not listed on the label – products that were found to be adulterated and misbranded – were left to remain on the market – exposing consumers to unnecessary risks.
The report revealed, that during testing, dozens of drugs, various chemicals, and undeclared ingredients were found that were not allowed in food and were not listed on the ingredient label. However, in every instance of a violation, FDA took no regulatory action. Not one of the adulterated pet treats were recalled.
ADULTERATED JERKY PET TREATS
|B. cereus (2014)||61||2 samples tested positive||Not provided||Unknown|
|Glycerol (2014)||114||10 samples tested positive||"Up to 200,000 ppm|
(20 % of the product weight)"
|Sulfur (sulfites and sulfur dioxide) (2014)||40||40 samples tested positive||"Expected levels" (concentration not provided)||Unknown|
|Glycerol (2015)||104||"Several" tested positive||83,000 ppm to 108,000 ppm||Adulterated|
|Sorbitol (2015)||92||18 samples tested positive||7,890 ppm to 175,000 ppm||Adulterated|
|3-monochloropropane-1,2-diol (3-MCPD) (2015)||20||7 samples tested positive||0.049 ppm to 0.352 ppm||Unknown|
|3-monochloropropane-1,2-diol (3-MCPD) (2016)||24||5 samples tested positive||0.029 ppm to 0.04 ppm||Unknown|
|71||"Multiple" toxic chemicals tested positive||"Very low" (concentrations not provided)||Unknown|
|50||"Multiple" toxic chemicals tested positive||"Very low" (concentrations not provided)||Unknown|
|Ethylene glycol (2014)||71||2 samples tested positive||"Very small amounts" (concentration not provided)||Adulterated|
|Propylene glycol (2014)||71||"Several" samples tested positive||20 ppm to 35,000 ppm||Adulterated|
|Dihydroxyacetone (2014)||71||2 samples tested positive||"Very small amounts"|
(concentration not provided)
|Propylene glycol (2015)||50||"Several" samples tested positive||Concentration not provided||Adulterated|
|Glycolic acid (2014)||71||"Multiple" samples tested positive||"Trace amounts" (concentration not provided)||Unknown|
|Diglycolic acid (2014)||71||1 sample tested positive||"Trace amounts" (concentration not provided)||Unknown|
|Xylitol (2014)||71||1 sample tested positive||170 ppm||Adulterated|
|Sorbitol (2014)||71||17 samples tested positive||300 ppm to 170,000 ppm||Adulterated|
|Glycerol (2014)||71||"Multiple" samples tested positive (exact number not provided)||Concentration not provided||Adulterated|
|Sorbitol (2015)||50||6 samples tested positive||100 ppm to 53,000 ppm||Adulterated|
|Glycerol (2015)||50||"Multiple" samples tested positive (exact number not provided)||Concentration not provided||Adulterated|
|Oxalic acid (2014)||71||55||50 ppm to 1,800 ppm||Adulterated|
|Oxalic acid (2015)||50||12||52 ppm to 610 ppm||Adulterated|
|Amantadine (2014)||71||27||Concentration not provided||Adulterated|
|Monensin (2014)||71||27||"Trace amounts" (concentration not provided)||Adulterated|
|Azithromycin (2015)||50||7||Concentration not provided||Adulterated|
|Amantadine (2015)||50||9||Concentration not provided||Adulterated|
|Sulfaclozine||9||2||Highest concentration found was 0.102 ppm||Adulterated|
|Sulfaquinoxaline (2015)||9||1||Up to 0.078 ppm (tolerance level of 0.1 ppm)||Adulterated|
|Tilmicosin||9||1||Highest concentration found was 0.0056 ppm||Adulterated|
|Amantadine||9||1||Highest concentration found was 0.036 ppm||Adulterated|
|DEET||9||1||Highest concentration found was 0.0041 ppm||Adulterated|
|4-ipomeanol (2014)||71||1||10 ppb to 50 ppb||Adulterated|
|Malic acid (2014)||71||46||50 ppm to 16,100 ppm||Adulterated|
|Fumaric acid (2015)||8||8||50 ppm-180 ppm||Adulterated|
|Malic acid (2015)||50||44||99 ppm to 970 ppm||Adulterated|
|Maleic acid (2015)||50||6||"Trace amounts" to 21 ppm||Adulterated|
|Glycolic acid (2013)||71||69||"Trace amounts" (concentration not provided)||Adulterated|
|Diglycolic acid (2013)||71||1||"Trace amounts" (concentration not provided)||Adulterated|
|Sulfites (2015||50||5||7.3 ppm to 120 ppm||Adulterated|
|SO2 (sulfite, bisulfite, and meta-bisulfite) (2015)||50||5||5.8 ppm to 96 ppm||Adulterated|
|Bufotenin (2015)||50||1||Positive (concentration not provided)||Adulterated|
DRUG REPORTING INCONSISTENCIES
FDA reports they believe it is “unlikely that the reports of illness it has received were caused by the presence of antibiotic residues in jerky pet treat products.” FDA scientists dismiss the New York State Agriculture and Markets’ (NYSDAM) findings as insignificant and noted that when measurable levels of antibiotic drugs were found in the treats, they were consistently at “very low levels – almost all were less than 0.0001 percent (< 1 part per million, or less than one inch in 16 miles).” And that NYSDAM testing results “showed very low (parts per billion) residues in some of the samples.”
Yet, in a recent NYSDAM report, they found sulfaclozine, an illegal antibiotic for which there is a zero tolerance, at 2 ppm in jerky pet treats. Additionally, NY discovered sulfaquinoxaline in concentrations up to 828 ppb (tolerance is 100 ppb) in jerky pet treats. The lab also detected amantadine in 36% of jerky pet treats tested (the highest concentration detected was 0.882 ppm) and they found DEET in 38% of samples jerky treats tested at concentrations up to 0.572 ppm.
In contrast, FDA says that “sulfaquinoxaline was found in [only] 1 store-bought sample. The highest concentration detected was 0.078 ppm” tested by NYSDAM.
Further, FDA writes that NYSDAM found sulfaclozine (for which there is a zero tolerance) in only 2 samples and the “highest concentration detected was 0.102 ppm.” FDA also claims the NY lab only found amantadine in one sample and the “highest concentration was 0.036 ppm.”
These reporting inconsistencies are a pattern that has continued throughout FDA reporting of the investigation. Consistently, they have minimized and underreported the amount and number of drugs found by the NYSDAM in the treats.
CASPAR MILQUETOAST CAUTIONS
Had any of the products been recalled, retailers would have been required to post recall notices in their grocery stores both online and off in conspicuous locations warning unsuspecting consumers of potential dangers.
The one tool which the FDA could use to raise awareness about the danger of these products is not being adequately utilized to its full potential. Instead, the agency continues to issue wishy-washy warnings that seem to be carefully crafted to subdue any unnecessary fear in consumers and to limit the agency’s liability:
“FDA reminds pet owners that jerky pet treats are not necessary for pets to have a fully balanced diet, so eliminating them will not harm pets. Commercially produced pet food, which is very safe, contains all of the nutrients that pets need.”
Placing suitable warnings, appropriate to the risk level, on the FDA website is essential to effectively educate consumers about the risk of feeding a potentially deadly jerky pet treats to their dogs.
Until the FDA can overcome the obstacles to finding the answers to the jerky pet treat poisonings, the FDA should, at the very least, change the tone of their cautions to one with an appropriate level of concern for consumer safety.