A Pathogen-Free World?

The FDA Food Safety Modernization Act (FSMA), the most sweeping reform of our food safety laws in more than 70 years, was signed into law by President Obama on January 4, 2011. Its aim was to ensure the U.S. food supply is safe by shifting the agency’s focus from responding to contamination to preventing it. For the first time, the FDA had a legislative mandate to require comprehensive prevention-based controls across the food supply, including imported food, for both people and pets.

According to the FDA’s Compliance Policy Guide (CPG), “any pet food or pet food ingredient contaminated with Salmonella is considered potentially harmful to health if it isn’t intended to undergo a subsequent treatment to kill bacteria.” Pet foods include dog and cat food (raw, dry, and everything in between), treats, chews, and nutritional supplements. The FDA now maintains a zero-tolerance policy for salmonella in pet food because of the potential threat to “at-risk” people (generally not dogs or cats), such as the elderly and those with compromised immune systems. This is more stringent than the requirement for food sold for human consumption, as it is assumed the latter will be cooked prior to consumption.

The new standards already exist, but according to Dr. James Marsden, professor of food safety and security at Kansas State University and the foremost expert in the field of food safety, the regulations are still being developed. “The FDA is behind in getting the rules released, in part because they are allowing the industry to get ready.”

Many believe that pet food manufacturers, especially small companies, are not ready for the FDA’s requirement that they have written and controlled safety systems for ensuring all ingredients are free of pathogens such as E.coli, salmonella, and listeria. We will begin to see the full force and effect of the FSMA within the next couple of years.

Inspection will be a key part of this new initiative and, for the first time, the FDA will have mandatory recall authority for all food products. Many dog guardians have seen ample evidence of this new authority already with the recent recalls of Honest Kitchen (dehydrated cooked), Steve’s Real Food & BRAVO (raw), and Natura and Diamond (dry) products due to potential salmonella contamination.

Dr. Marsden believes the risk of aflatoxin and mycotoxin contamination to dry pet food might even be greater than contamination of pathogens in raw food, as many of the kibble companies use old grain plants without the proper equipment and safeguards in place to eliminate risk. In addition, kibble is much more widely fed than raw food and the general public often does not take the same precautions in handling it as they would and do with raw meat.

The majority of commercial raw food manufacturers are trying to reduce the risk of contamination by relying on a “test and hold” system, shipping only product which test negative. While that helps minimize the risk, it doesn’t meet the zero-tolerance requirement as companies are only testing a small sample, which  leaves them more exposed to recall. The FDA will allow only one or two recalls before requiring the company be shut down.

The only real way to ensure no pathogens exist in raw food products is to include a “kill” step during processing. High Pressure Pasteurization (HPP) is a process of applying water pressure to the meat at a controlled temperature to kill bacteria. This process has been around for about ten years and used more extensively the past five by a number of commercial raw food pet manufacturers. Stella & Chewy’s and Nature’s Variety use this process for all of their products. More recently, and only partially, the process has been adopted by Primal, BRAVO, and Northwest Naturals (which produces raw food for a number of other companies).

According to Stella & Chewy’s website, “HHP is the only scientifically recognized pasteurization process that does not use heat or irradiation to accomplish this.” The company says HPP does not change the nutrient value or flavor of the food, but for many raw food purists this process is controversial and undesirable, as they believe it not only kills the harmful pathogens but also the naturally occurring beneficial bacteria and enzymes necessary for proper digestion and a healthy immune system.

Dr. Marsden says that while this can happen, it is easy to restore the beneficial bacteria with the addition of probiotics to the food. Stella & Chewy’s takes additional safety measures by combining HPP with their patent-pending process that “uses a series of devices that emit low levels of safe, pathogen-fighting gases such as ozone and hydrogen peroxide.” Dr. Marsden says HPP will become an industry standard as the other options for eliminating pathogens, such as irradiation and chemical treatments, become even less desirable to consumers .

Dr. Marsden acknowledges that the raw food industry has done a tremendous job in protecting the integrity of their product while meeting the new regulations. “It’s a monumental task.” His view of the future?  “Lots of stainless steel and total control of pathogens.”

Many who feed commercial raw food are concerned that the new regulations and requirements will be too costly and onerous for the many locally produced raw pet food manufacturers. Dr. Marsden agrees this is a concern and hopes trade associations and university extension programs will provide some support.

Since the risk of contamination is greater to humans than to animals, it’s important to take the same simple precautions you would in handling any raw meat product in your kitchen –  wash your hands and implements thoroughly and often.