Has anybody heard of the FDA’s Food Safety Modernization Act? For those who aren’t aware of the FSMA, it’s an initiative the FDA rolled out a couple of years ago with the goal of creating safer pet (and human) food. Pet food manufacturers have been wondering how much teeth FSMA would give the FDA but it appears that with the recent surge in pet food recalls in 2013, the FDA has been given plenty of teeth.
At first glance, the FSMA seems like a long awaited godsend to pet owners. The FDA is not only forcing food manufacturers to put caloric amounts on their bags (like human food labels), but they are focusing less on recalls but more on prevention of tainted foods and increasing food manufacturer accountability.
This all sounded like a wonderful thing as the pet food recalls started rolling out in early 2013. The first victims of the FSMA seemed to be poisonous chicken jerky treats that were recalled not for the reasons we expected, but for antibiotic residue. But they were off the shelves and pet owners were happy.
As 2013 moved on, the number of pet food recalls grew exponentially but this time the FDA shifted it’s attention to salmonella. When The Honest Kitchen issued a voluntary recall due to salmonella, a disturbing trend ensued as suddenly, raw food manufacturers were targeted. Steve’s Real Food recalled their Turducken Canine Diet in March 2013, followed by Jones Natural Chews Woofers, Bravo! Chicken Blend and BARF World Lamb and Combo Patties. Other dry foods were recalled for salmonella in the last month (Natura, Iams and Diamond) but these are cooked foods. How can the FDA expect raw foods to be free of salmonella and other naturally occurring bacteria that are found in all raw meats? More importantly, what does this mean for the future of commercial raw food manufacturers?
Zero Pathogens: The Kill Step
Controlling salmonella in pet food requires a “kill” step during processing. Killing salmonella in cooked foods is easy: the cooking process itself destroys the bacteria. This means that cooked pet foods can use rancid meats from dead, dying, disabled and diseased animals and feel good that the cooking and processing will destroy any pathogens in the food.
Raw food manufacturers however start with high quality USDA inspected meat and test their products more frequently for contaminants. In addition, most raw pet foods don’t contain grains which are a common source of mycotoxins and aflatoxins. This is why raw food recalls prior to 2013 were virtually unheard of. Yet in the last month, three high quality raw foods have been recalled for salmonella while under the watchful eye of the FDA and their new rule of zero pathogens in pet foods.
A Slippery Slope
Is the goal of zero pathogens in raw food a realistic goal? The FDA believes it is and the High Pressure Pasteurization (HPP) machines are on standby. For now, many raw food manufacturers are fighting HPP and with good reason: the HPP process destroys not only harmful bacteria but the beneficial bacteria that a dog needs to create and maintain a healthy gut and immune system. Arguably, HPP raw food is not really raw food because it’s missing one of its key benefits: naturally occurring beneficial bacteria and enzymes.
While increasing their efforts to test pet foods for contaminants is an admirable and desirable function of the FDA. the witch hunt for salmonella is misguided. Yes, salmonella has the potential to harm humans and some severely immune compromised dogs (although removing beneficial bacteria from their diets may be short sighted). But should raw foods be robbed of their natural nutrition in lieu of washing our hands after serving?
The conventional mindset of preventing disease is backwards thinking and initiates a slippery slope of ill health. While dogs and people who eat sterile foods won’t be harmed by acute salmonella poisoning, they will start to suffer chronic disease from the lack of beneficial bacteria. This deficiency in beneficial bacteria will result in digestive issues and a degradation of the immune system and this will soon be seen as allergies, chronic disease and, ironically, more susceptibility to pathogens such as salmonella! Maybe salmonella wouldn’t be as much of a threat to dogs and people in the first place if their intestinal flora wasn’t debilitated by processed foods and the overuse of antibiotics!
As 2013 unfolds and pet food manufacturers fall under greater scrutiny, it’s important to keep the salmonella recalls in perspective. If you purchase a commercially prepared raw food that isn’t exposed to HPP, why not send a quick email to that manufacturer as a show of support? They could really use it right now and they are behind the scenes fighting HPP for the benefit if your dog.
As always, the best and easiest solution is to look to Mother Nature. Feed your dog fresh, raw foods from local farmers. Grass fed animals are less likely to harbour harmful E. coli. While raw meats may carry salmonella, they have lots of good bacteria and enzymes that help your dog manage salmonella the same way their ancestors have been doing for millennia.
In short, dogs aren’t harmed by salmonella: they are harmed by mistuned digestive and immune systems that are devoid of beneficial bacteria, allowing harmful bacteria like salmonella to flourish in the gut and create illness. If the FDA really wanted to prevent sick dogs, they would understand this and not hold raw foods to the same standards as processed foods.