Over the holidays, the U.S. Food and Drug Administration (FDA) posted a 15-day Warning Letter to raw pet food maker G & C Raw, LLC following inspections the agency conducted on April 22-25 and May 17, 2019. What FDA investigators found were appalling conditions inside the raw dog food company, a list of violations so long I will only give you the condensed version, here:
Dirty, wet boots: Employees were observed stepping over totes containing raw product as drops of water from their boots fell into the containers thereby contaminating the dog food, which the FDA noted, “with undesirable microorganisms or other contaminants, such as dirt or other foreign material, that may be present on the floor, employee footwear, the dustpan, or other non-food contact surfaces.”
Food contamination: FDA inspectors witnessed an employee lift a barrel from the floor and placed it on its side, directly on top of raw meat and organ ingredients. The FDA noted that doing so “could contribute to the contamination of your animal food with undesirable microorganisms or other contaminants, such as dirt or other foreign material, that may be present on the outside of the barrel.”
Ingredients on trash can: An employee placed a box of bone meal ingredient on top of a trash can that was being used to throw away containers that had fallen on the floor and raw ingredients, such as fat, that had not met quality standards, while scooping bone meal out of the box. Inspectors warned them that – duh – doing that has the potential to put contaminants into the box of bone meal instead of the trash can, or to accidentally take something out of the trash can to put into the animal food being manufactured.”
Raw meat left out for days: The company did not thaw their frozen ingredients in a manner that minimized the potential for the growth of undesirable microorganisms. Specifically, investigators noted raw product sitting out – sometimes for days – at room temperature.
Lack of hygiene: The FDA noted that G & C Raw didn’t take precautions to ensure that their employees who had direct contact with the animal food, animal food-contact surfaces, and animal food-packaging materials use hygienic practices to protect against the contamination of the company’s raw pet food.
Listeria found in raw food: On April 25, 2019, FDA collected a finished sample of their dog food and an analysis of the Raw Ground Turkey Dog Food product identified Listeria monocytogenes in five of subsamples and one of two composite samples analyzed for Listeria. Pathogens, including Listeria monocytogenes (which state regulators found in their pet food in the past) and in their processing environment, adds further evidence of the magnitude of the list of violations.
Pathogen contamination: The FDA warned the company that many of their manufacturing practices could contaminate their products with pathogens, thereby subjecting their pet food to “decomposition,” an indication that their animal food was “contaminated with filth, or that otherwise may cause animal food to be adulterated.”
Corrective actions? Well, not exactly: In response to the FDA request for corrective actions of violations noted after the inspections of their processing facility, G & C Raw e-mailed the FDA a “copy of an advertisement for a hand-washing sink” they told them they had ordered, without any indication of when it would be installed or how personnel would be instructed to use it.
The company wrote in another e-mail that they had installed a paper towel dispenser and that a separate hose had been purchased for cleaning vehicles outside. They included some photographs as well, but the FDA explained that “aside from the paper towel dispenser, it is difficult to identify what these photographs are showing and their relevance.”
But mainly, G & C Raw did not include information explaining which food safety and handling procedures were discussed with their employees, or what their expectations for their employees are. And there was no explanation about how their processing practices are changing to adapt to the new equipment. Or how long will raw material stay out, or who will be monitoring this process and how will the material be rotated?
Finally, the Warning Letter makes clear that G & C Raw has 15-days to take action to correct the violations cited in the letter and that a failure to correct the violations may result in “legal action without further notice, including, without limitation, seizure, and injunction.”
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