Written by Chelsea Kent
What is Pentobarbital?
Pentobarbital is a fatal drug most commonly used to euthanize dogs, cats and most pet horses. It is NEVER used in animals intended for consumption, such as livestock. It is capable of surviving high temperatures associated with cooking if it is put into a pet food product and thus impacting your pets health. The use of Pentobarbital in livestock animals intended for human, pet or agricultural consumption is illegal.
How does it get into food?
Renderers convert 47 billion+ pounds of inedible animal products into end user products such as soaps and pet foods. As renderers are not always making edible materials, they are sent the inedible remains of pet horses and euthanized shelter animals in addition to some livestock by-products. (FDA, 3)
Unfortunately for pet owners, according to Cornell Law, since Pentobarbital is not “added” to these products it is not legally considered an adulterant unless it is found in levels significant enough to cause severe illness and/or death. (1)
What foods might be contaminated with Pentobarbital?
Any product that holds a Rendering License, Horse Meat License, or uses “meat” or “by-products” of any kind may knowingly or unknowingly contain varying levels of Pentobarbital. A company that holds a Rendering or Horse Meat License has, intentionally and at a cost, applied and been approved to use “inedible” products in their pet food. Not only has any company with one of these gone through the effort of paperwork, and paid fees, but they must get inspected annually to maintain this license. It is therefore, never accidental or without cause that a company would maintain one of these licenses. Also, “Meat” means as much to you as it does to the company using it. What kind of meat? No one really knows and if they did, they would legally be required to tell you what it is. “Meat,” therefore, and by-products in some cases, may contain Pentobarbital and other contaminants.
How common is it in Pet Food?
Pentobarbital testing is expensive (around $400) and rarely done since Pentobarbital is illegal in pet foods. This doesn’t mean, however, that its not common. A study done by WJLA ABC 7 showed that 60% of Gravy Train samples tested positive for Pentobarbital. (2)
An FDA study in the 1990’s was conducted because the FDA’s Center for Veterinary Medicine received reports from Veterinarians that pentobarbital seemed to be losing its efficacy in dogs, in theory, because their chronic dietary exposure was making them less responsive to the drug. (3)
An FDA study done in 1998, back when there were fewer unethical companies on the market, showed that the vast majority of kibble products that were tested for Pentobarbital tested positive. (7) Pentobarbital recalls in pet foods tend toward canned food products. However, this is because the binders in kibble products dilute the Pentobarbital found in the meat and make it less immediately detectable. Low levels found in kibble can still have long term effects of the liver and neurological health of your pet.
How dangerous is it really?
FDA states that low levels of exposure to pentobarbital are unlikely to cause adverse health effects, however, a consumer has no way of knowing if levels are adequately “low” until after they’ve fed it to their pet and determined if it caused side effects or death.
Studies show that Pentobarbital increases Cytochrome P450 Enzyme levels, an enzyme that is strongly associated with the production of cancer cells. It has also been shown to increase liver enzymes and liver weight.(3)
Last but not least, consumption of DNA from same species tissues has a variety of potential neurological ramifications. As previously indicated, euthanized animal meats should not be in pet food and if they are the company would not be able to differentiate between horse, roadkill, dog or cat meat. Should your pet consume meat of the same species it increases the risk of species specific diseases and transmissible spongiform encephalopathies (TSEs) similar to Creutzfeldt-Jakob Disease or Kuru. These are neurologic disorders that attack the brain and cause damage that may not be immediately evident but which always leads to death. (4)
Doesn’t the FDA prevent substances like that from getting into pet food?
Officially, “if (any amount of) pentobarbital is detected in pet food, the FDA will investigate and take enforcement action as appropriate.” (5) Unofficially… oh wait… its actually totally official and written into FDA Policy… “A company may petition for use of an adulterated substance (such as euthanized animal meats).”
FDA’s Compliance Policy Guideline Sec. 690.300 on Canned Pet Food clearly states, “Pet Food consisting of material from diseased animals or animals which have diet otherwise than by slaughter, which is a violation of 402(a)(5) … will be considered fit for animal consumption.” (6)
What can I do to ensure my pets food doesn’t contain Pentobarbital?
We know “beef tallow” comes from cows and “chicken fat” comes from chickens, but what species does “animal fat” come from? The only way a company that uses an unidentified “meat” product would identifiable would be by utilizing DNA testing.
An article published by Truth About Pet Foods in 2017 evidences how difficult it can be to identify if a meat source is a “Farm” or a “Renderer” that only supplies inedible meats. The article also shows how even “natural” and “holistic” marketing on a package doesn’t always indicate that they are ethical and selling a good quality product.(8) In 2017 Evanger’s “Grain-Free and Gluten-Free,” “Super Premium,” “Very Nutritious,” “Kosher” canned pet foods (sounds good, right?) was recalled for containing Pentobarbital in their Hunk of Beef formula. While the company continues to claim they had no idea their product contained meats from euthanized horse meat, they hold a current License as a Rendering Plant with the Illinois Department of Agriculture. (9) They are classified as “Rendering Type – B” which authorizes them to very specifically maintain access to “parts of bodies of animals (of any kind and assumed to be “inedible”), scrap, bones, fat, used cooking grease and oils.” (10) Further, in a Warning Letter published by the FDA on 6.29.17 to Evanger’s, Evanger’s stated that they “conduct random pentobarbital tests of finished products prior to shipment into the market to ensure that the raw materials are unadulterated” to which the FDA responded “samples collected by FDA during this investigation demonstrate that pentobarbital contamination is not homogeneous throughout all units in a lot… finished product testing cannot mitigate the risk of pentobarbital in your raw material.” (11) Cost quotes from multiple laboratories all showed that Pentobarbital testing costs upwards of $300. It seems unlikely that a canned food company would incur such costs without necessity.
Finding a clean, safe product for your pet can sometimes be a hassle and most consumers don’t have the time or expertise to adequately search for complete and accurate information. One of the best ways to stay abreast of current and accurate data is to join an advocacy organization that seeks the truth in pet food manufacturing and regulatory practices. Here are some recommendations:
CONSUMERS: Association for Truth in Pet Foods – https://associationfortruthinpetfood.com/
RETAILERS: Food Regulation Facts Alliance – https://foodregulationfacts.com/
MANUFACTURERS: Next Generations Pet Food Manufacturers Association – http://www.ngpfma.org/
VETERINARIANS: Veterinarians currently do not have an advocacy group. If you, or someone you know, is interested in advocating for Vets at AAFCO meetings, please contact Chelsea Kent at FoodRegulationFacts@gmail.com to get started! In the meantime, if you’re a vet I recommend you follow all of these sites to get the most comprehensive and up to date information possible.
You can also follow these sites for constant updates on the industry:
Dr. Karen Becker, DVM at Mercola.com – https://healthypets.mercola.com/sites/healthypets/dr-karen-becker.aspx
Pet Fooled – https://www.petfooled.com/
Rodney Habib’s Planet Paws and Paws for Change – https://www.pawsforchange.global/
Dogs Naturally Magazine – https://www.dogsnaturallymagazine.com/
- https://www.law.cornell.edu/uscode/text/21/342
- http://wjla.com/features/7-on-your-side/fda-to-investigate-after-abc7-exposes-euthanasia-drug-in-dog-food
- https://www.fda.gov/AboutFDA/CentersOffices/OfficeofFoods/CVM/CVMFOIAElectronicReadingRoom/ucm129131.htm
- http://scienceblogs.com/neurophilosophy/2008/08/11/the-shaking-death-cjd-epidemic/
- https://www.law.cornell.edu/uscode/text/21/348
- https://www.fda.gov/ICECI/ComplianceManuals/CompliancePolicyGuidanceManual/ucm074710.htm
- https://www.fda.gov/AboutFDA/CentersOffices/OfficeofFoods/CVM/CVMFOIAElectronicReadingRoom/ucm129135.htm
- http://truthaboutpetfood.com/the-type-of-meat-evangers-really-used/
- https://www.agr.state.il.us/sharepoint/licenselist.php?facc=Rendering%20Plant
- http://www.ilga.gov/legislation/ilcs/ilcs3.asp?ActID=1376
- https://www.fda.gov/iceci/enforcementactions/warningletters/2017/ucm565516.htm
Food Regulation Facts 
This reference link shows Illinois registered Rendering facilities. Evanger’s (not Bailey Farms) is listed as the 10th from the top. Evanger’s, therefore, knew they were purchasing (with intention) rendered products and this is confirmed by the last reference, the FDA Warning Letter where Evanger’s stated that they do regular Pentobarbital testing to ensure their products are in compliance with Adulteration limitations. This type of testing is never done if there is not a known reason to incur this expense as it is hundreds of dollars to do this test.
Evangers is suing Bailey Farms, the supplier from which they purportedly purchased the pentobarbital contaminated ingredient. If you look up Bailey Farms website, you see that they operate a rendering plant, a carcass pick up service, and they also make and sell dog food under their own brand (!) When you say “they” hold a rendering license, are you referring to Evangers or Bailey Farms? Also, the Hunk of Beef was a whole meat product, not a rendered product. My understanding from talking with pet food company people is that they buy meals from rendering companies, but not one has said they do the rendering themselves. The sheer number of rendering companies (450+) gives pet food manufacturers all the flexibility they need to keep up production sufficiently to meet demand. Whereas operating a rendering company would sorta box them in, wouldn’t it? I’d appreciate it if you would clarify who the “they” is you refer to. Thanks!