Raw Food Related Illness

For years the FDA has been falsely stating that raw pet foods are dangerous to feed due to the high risk of pathogens associated with them. These statements have been made despite the FDA’s own published statistics that contradict that information. They have even gone on pathogen seeking witch hunts in raw food products to come up virtually empty-handed… all the while leaving dry kibble and canned foods (the real statistical culprits) alone. They have finally come up with something on raw foods…. or have they???

Raws for Paws of Minneapolis, MN had a recall on 2.8.2018 for a “possible Salmonella health risk.”  The FDA publication notes that there are two human illnesses associated with this recall. https://www.fda.gov/Safety/Recalls/ucm596043.htm

Pretty scary right?  Maybe the FDA is on to something…. Or maybe not, consider this:

1. FDA only has the authority to enforce a recall if there is a confirmed case of human illness caused by the pet food.  This recall does not state that it was a Mandatory Recall, implying that the FDA is still only assuming that the raw pet food was the cause of the illnesses.  If the FDA had any real proof they would label the recall “Mandatory.”
2. The strain of Salmonella (S. Reading) indicated as the cause of illness in this case caused a multi-state CDC regulated Outbreak in September of 2016, caused by Alfalfa Sprouts. https://www.cdc.gov/salmonella/reading-08-16/index.html.  The CDC does not actually list foods other than Sprouts as a potential host for S. Reading. As a matter of fact, Clinic Microbiology and Infection, Volume 22, Issue 2, February 2016, pages 110-121 on Salmonellosis: The Role of Poultry Meat does not even list S. Reading is a type of Salmonella ever found in poultry meat during studies on Salmonella Serovars. https://www.sciencedirect.com/science/article/pii/S1198743X15010307.  Additionally, of the 2,300+ Salmonella Serovars, only a small percentage are capable of causing illness in warm-blooded animals and only 79 of them are tested for (because only those are known to cause illness and to test for serovars that don’t cause illness would be cost prohibitive)… Salmonella Reading is not one of the serovars that NCBI recommends testing for: https://www.ncbi.nlm.nih.gov/pmc/articles/PMC516822/table/t1/ So how in the world did the FDA get a positive Salmonella test for a strain of Salmonella that no one tests for???
3. FDA cultures raw food samples in an enrichment broth which selects and enhances the growth of pathogens like Salmonella, while selectively killing microorganisms that would naturally compete with the pathogen and prevent its propagation.  The broth is then incubated for anywhere from 16 hours to 5 days, at up to 115.2⁰F (this is a very wide range for a scientific analysis).  Scientists are unable to differentiate live cells from dead cells.  Therefore, it’s likely that samples with large amounts of dead cells would still result in a “false positive” for pathogens. The FDA acknowledges that “the preventative measures that can be applied for pathogenic bacteria growth and toxin formation due to time and temperature abuse include, 1) refrigeration of the product and controlling refrigeration temperatures, 2) proper icing of the product, 3) controlling the amount of time that the product, is exposed to temperatures that would permit pathogenic bacteria growth or toxin production 4) rapid cooling of the product.” Ultimately, FDA acknowledges that under normal handling conditions, raw foods are not likely to accumulate pathogens… so did this particular home not handle their food appropriately?  FDA also admits that “pathogenic bacteria also could be introduced during processing, even after cooking.
4. The USDA, who is responsible for investigation, oversight and enforcement of quality control for Meat, Poultry and Egg does not have a hand in any regulation or oversight of pet food products as a whole.  Pet Food falls completely under FDA jurisdiction.  Therefore, the only way for an all meat product, such as the situation with Raw for Paws (which does not contain anything BUT meat) to be inspected or regulated under any authority is for it to be processed in a USDA facility.  If this were the case the USDA inspection number would be placed on the product.  Therefore, if FDA actually cared to prevent these sorts of occurrences wouldn’t it be logical for the FDA to find a way to ensure USDA involvement in pet foods (which share FDA and USDA regulated products)?  It seems the only “oversight” here is on the part of the FDA and USDA.
5. Its no secret that if a pet food company wants to capitalize on the waste of the human food industry (or any other industry) they have the legal right to do so.  In 2017 the USDA FSIS forced recalls of dozens of meat products, including Turkey: https://www.fsis.usda.gov/wps/portal/fsis/topics/recalls-and-public-health-alerts/recall-summaries.  Once a product is out of USDA jurisdiction if enforcement actions are taken against the product it does not necessarily mean that all the meats associated with those batches will be recalled.  In most cases, meats are not tested for pathogens until after they are in market circulation and in some cases they are not tested until after there are consumer complaints or illness. Should the USDA receive a consumer complaint and test a product, find it positive for a pathogen or contaminant, then enforce a recall, the company will likely only recall the exact products in question… they are highly unlikely to track down every bit of meat that came from that batch, especially if certain “scraps” were sold off to a measly dog food company.
6. FDA was provided with Risk Assessment Statistics sourced from their own website, CDC and USDA sources and more in 2017.  These statistics showed that Raw Frozen, Dehydrated, Air Dried and Freeze Dried Raw Foods are up to 664 times safer to consumers than kibble and canned foods (with the exception of High Pressure Pasteurized Frozen Foods).  Apparently they had never looked at their own publications long enough to realize that their safety claims against raw food were false but now that they do is it coincidence that they have “finally” come up with the first situation in commercial raw food history of human illness?

…does it seem even stranger that the one case they have come up with is based on a raw food containing a strain of Salmonella Serovar that is so uncommon in raw food that even Scientific Studies on raw meats don’t mention it?

It is yet to be seen what comes of all of this.  There are still many questions at hand.  For example, what is the sourcing used by Raws for Paws?  Could they of purchased a turkey product from a source that was later recalled in the human food world?  If so, does this mean FDA should be pointing fingers at human foods and the USDA, not raw pet foods?

Did the FDA supply Raws for Paws with their split sample and allow them to have their own laboratories test the product for S. Reading as well?  FDA is notorious for being unable to provide this legally required sample. Did they do it?  If they did, what were the results from Raws for Paws?

Had the infected humans recently consumed any Alfalfa Sprouts in their homes?  By all means, anyone that feeds raw foods to their dogs are health conscious enough to be eating some Sprouts!!!

Is this scenario the FDA’s attempt to appear legitimate? Is it the USDA’s inadequate inspections? Is it the manufacturers complacency or lack of quality control? Is it all of the above?  No one knows yet… but we certainly should all be considering the inadequacies of the Industry on many levels.

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