While the horror of the Smucker’s debacle unfolds and the number of dog foods contaminated with sodium pentobarbital – a drug typically used to euthanize pets – grows, 20 years ago the US Food and Drug Administration (FDA) found the very same drug in many of the same brands still on the market today.
TWENTY YEARS AGO THE SAME THING HAPPENED
Decades ago, the FDA – after hearing anecdotal reports that sodium pentobarbital wasn’t working like it used to – wondered if pets were becoming immune to it because they were being exposed to it from some other source. That’s when the FDA thought it might be in pet food.
So, back in 1998, and again in 2000, the FDA tested a number of dry dog foods and found the very same drug in some of the very same pet foods being taken off the market today – including Gravy Train, Kibbles ‘N Bits, and Ol’ Roy – 20 years ago.
The results of those studies is documented in Dog Food Samples Used in CVM Pentobarbital Surveys and Analytical Results which reveals the results of analysis which showed the presence of pentobarbital in numerous brands of dog food. While the study was not meant to be representative of the pet food market, the FDA concluded that:
“There appear to be associations between rendered or hydrolyzed ingredients and the presence of pentobarbital in dog food. The ingredients Meat and Bone Meal (MBM), Beef and Bone Meal (BBM), Animal Fat (AF), and Animal Digest (AD) are rendered or hydrolyzed from animal sources that could include euthanized animals.”
THE TROUBLE WITH FINDING CATS AND DOGS AND HORSES
Based on the findings, the agency wanted to know where the drug was coming from so they conducted species analysis testing on the dog food. To do that, they developed a test based on the assumption that the origin of the pentobarbital was from euthanized dogs and cats or possibly horses. But the trouble with their test was, it couldn’t identify any of the species they thought might have been responsible for the contamination, including canine, feline or equine DNA.
Despite the failed testing, and because the FDA found only “very, very low levels” of sodium pentobarbital (parts per billion) in the dog foods, they decided it was a risk they were comfortable living with. As the agency did not believe it posed an immediate danger to pets, their conclusion was at those low levels it was “unlikely to cause them any adverse health effects,” so the agency decided did not take a position to eliminate euthanizing drugs from pet foods and animal feed.
“The low levels of exposure to sodium pentobarbital (pentobarbital) that dogs might receive through food is unlikely to cause them any adverse health effects, Food and Drug Administration scientists concluded after conducting a risk assessment.”
What became of the dog foods they found contaminated with pentobarbital 20 years ago?
They stayed on the market, and not a single one of those illegal pet foods was withdrawn or recalled from the market.
HOW HISTORY REPEATS ITSELF
And here we are today, with the FDA saying virtually the same thing today as they did 20 years ago:
“The FDA’s preliminary evaluation of the testing results of Gravy Train samples indicates that the low level of pentobarbital present in the withdrawn products is unlikely to pose a health risk to pets.”
Perhaps that is true, but the difference today is that the FDA emphasized that pentobarbital in any amount – even in parts per billion – is illegal in pet food, saying that “pentobarbital should never be present in pet food and products containing any amount of pentobarbital are considered to be adulterated.” Citing law, the FDA reminded manufacturers and consumers alike that:
“Any detection of pentobarbital in pet food is a violation of the Federal Food, Drug, and Cosmetic Act—simply put, pentobarbital should not be in pet food.”
A HISTORY OF ENABLING MANUFACTURERS
Perhaps that if the FDA had taken a stronger position about the pentobarbital laced dog foods twenty years ago by requiring their removal from the market, manufacturers would have been sent a stern message: A zero tolerance for pentobarbital.
Perhaps if the FDA didn’t have such an exhaustive – and lengthy – list of compliance policies, many of which tell pet food manufacturers the FDA will not take action over certain – how shall I put it – objectionable practices we wouldn’t be where we are today. Perhaps we wouldn’t be facing the problem of pentobarbital laced meat from euthanized pets (cats, dogs and horses) in pet food today.
One particular policy that haunts us today states that even though canned pet food may contain material from 3D and 4D animals – “regardless of the origin of animal tissues used” – the FDA considers it fit for animal consumption even though it is in violation of law:
“Pet food consisting of material from diseased animals or animals which have died otherwise than by slaughter, which is in violation of 402(a)(5) will not ordinarily be actionable, if it is not otherwise in violation of the law. It will be considered fit for animal consumption.”
Two other terrible policies tell pet food manufacturers the FDA will consider the diversion of contaminated or adulterated food for animal use, as long as it’s not otherwise in violation of the law.
Even though the FDA is fully aware that dead, dying, disabled, or diseased (4-D) animals are used as animal food, the agency allows its use as long as it’s heat-processed (cooked in a can or rendered). However, if the objectionable material is raw then they’re in violation of the law:
“*Uncooked meat derived from 4-D animals is adulterated under Section 402(a)(5) of the Act, and its shipment in interstate commerce for animal food use is subject to appropriate regulatory action.*’
Which brings us to the the final insult to consumers, the FDA will not consider it objectionable if pet food manufacturers wish to use rendered animal tissues from animals that have died otherwise than by slaughter in pet food. Rendered material is the most likely source of pentobarbital contaminated meat in pet foods today just as it was twenty years ago.
Perhaps, if the FDA did not allow so many violations of the Federal Food Drug and Cosmetic Act, then pet food manufacturers would have a clear, bright line between what’s allowed and what’s not: What’s legal and what’s not. But, as long as compliance policies blur the line between these two defining points of law, incidences like the one we are facing today will continue to happen.
READ MORE ABOUT IT
Food and Drug Administration/Center for Veterinary Medicine Report on the Risk from Pentobarbital in Dog Food
Appendix – Dog Food Samples Used in CVM Pentobarbital Surveys and Analytical Results
Dog Food Survey Results – Survey #1, Qualitative Analyses for Pentobarbital Residue
List of Compliance Policies Affecting Animal Feed and Pet Food Manufacturers
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