No matter what you’ve chosen to feed your pet your head is probably spinning with concerns. If you’re feeding kibble you may be wondering if it’s increasing your pets’ risk of cancer. If you’re feeding grain-free you may be wondering if it’s increasing your pets’ risk of Dilated Cardiomyopathy. If you’re feeding canned you may be wondering if it contains pentobarbital, the euthanasia drug that’s so commonly a cause of recalls these days. If you’re feeding raw you may be concerned about pathogens that could cause illness. If you’re feeding home made you may be concerned about whether your pets’ food is covering all the necessary nutrient bases for your pet to thrive.
Recently there have been reports of raw pet foods making humans sick. This outbreak primarily spans the human food industry. Raw chicken that was inspected and passed by the USDA was contaminated with Salmonella Infantis. The USDA does not consider Salmonella to be dangerous in “NRTE” (not ready to eat) products because the public is expected to cook the product when they get home, thus rendering the Salmonella inert. However, in this case, 92 humans have been reported to have gotten ill from these chicken products, 21 of which have been hospitalized. There are zero deaths associated with this outbreak and it spans 29 states. (23) While most kibble companies source their meats from rendering industries (meats that are not fit for human consumption and therefore must be cooked into a slurry and denatured, then dried prior to shipping to manufacturers (24) ) Darwin’s pet food’s chicken is from the same supplier that you would purchase from for meat in your home. As a result, their chicken (like yours in your home if you purchased from the grocery store during this recall) was contaminated with Salmonella Infantis as well. However, no human illnesses have been linked to exposure to Darwin’s products. (25) Though there have been 6 pets that were sickened (which is an extraordinarily rare instance in commercially available raw pet food products) you, as a loving pet owner, are now left with the decision to purchase cooked and sterilized kibble with ingredients sourced from meat rendering trash, or to purchase raw, unsterilized meats sourced from the same sources you trust for your own consumption.
How does one go about making the decision to feed “safe” junk or to feed “unsafe” fresh foods? A little perspective provided by the CDC may help you out! CDC data on 31 of the most virulent pathogens shows that the chances of a human becoming hospitalized by a domestically acquired foodborne pathogen is about 0.0001% (or 1 in 10,000), and the chance of death is 0.000004% (or 1 in 4,000,000) (26) In comparison to other risks that you may intentionally take, HRSA data shows that the chances of a hospitalization from a MMR Vaccine is 0.0001% (or 1 in 10,000), and the chance of death is 0.000006% (or 1 in *6,000,000) (27) Therefore, the risk of raw meats making you or your family sick are within the same range (or lower) than the risk of side effects or death from a MMR Vaccine that is intentionally and conscientiously given.
*”Underreporting” is one of the main limitations of passive surveillance systems, including VAERS. The term, underreporting refers to the fact that VAERS receives reports for only a small fraction of actual adverse events. (28)
The competitive market and industry-funded FDA has done an excellent job of confusing pet parents and has done little to provide accurate and inclusive direction for everyone. One of the single most important points to understand, when determining which foods are safest, is FDA motivation around consumer recommendations and recalls.
Here are some key safety facts on each category of pet foods:
Dry Kibble and Canned Foods –
- Dry Kibble and Canned Foods are generally heavily processed, often utilizing ingredients that are sourced from the biodiesel industry, oleochemical industry, rendering industry, food waste industries, and even agricultural waste industry. Just a few ingredients in the AAFCO Official Publication that are never used in raw foods include Dried Poultry Litter (ag waste), Dried Poultry Waste (ag waste), Dried Swine Waste (ag waste), Dried Ruminant Waste (ag waste), Corn Gluten Meal (biodiesel waste), Salvage Pet Food (ag waste), Distressed Pet Food (ag waste), Sludge, Hydrolyzed Leather Meal, Hydrolyzed Hair, Hydrolyzed Poultry Feathers, Meat and Bone Meal, Meat Meal Tankage, Pasta Product, Raw Leather Residue, Powdered Cellulose. (32)
- Dry Kibble Pet Foods are responsible for CDC regulated Salmonella Outbreaks on 3 occasions, in 2007, 2008, 2012. Sickening 190 people. (13)(14)(15)
- FDA states that cooked foods are safer than raw foods, as cooking decreases or eliminates pathogen load. However, pathogen studies show that the lower the moisture content of a food, the longer it must be cooked to kill pathogens. The inefficiency of cooking on pathogens is proven the recall history of dry kibble products.
- Canned pet foods are specifically excluded from Adulteration laws. Canned pet food manufacturers may petition to utilize known toxic products.
- Canned pet foods have been involved in many of the deadliest recalls in history. (29)
- Kibble and Canned foods that use rendered meats must denature their products to ensure that no human would mistake the product as edible. (30) Denaturing agents include coal tar, carbolic acid, citronella, food coloring (carcinogenic) and charcoal. As these agents are mandatory, they are not required to be listed on your products label.
Raw Frozen*, Dehydrated, Freeze Dried, Air Dried –
- Most commercially available *frozen raw pet foods source from the same meat sources that you would buy from, or better (such as local farms) (31)
- Raw foods do not generally require the addition of synthetic vitamins and minerals because the nutrients of the whole foods in the product are not cooked out. Synthetic Vitamins and minerals have the risk of toxicity or contamination. Some synthetics are more toxic than arsenic, and many synthetics are the cause of recalls in kibble and canned food products. (33)(34)
- Frozen raw pet foods are significantly more heavily regulated under the FDA’s Zero Tolerance Policy than kibble or canned foods. Frozen raw pet foods can be recalled for having a **pathogen that is not capable of causing illness, in a level that is not capable of causing illness. Meanwhile, meats you purchase from the grocery store can test positive for pathogens in most cases and still be sold to you under the assumption that you will cook it at home. (35)
- Foods that are purchased for pet food consumption from human food sources do not need to be denatured
*HPP – High Pressure Pasteurization (HPP) is a form of sterilization that arguably contributes to endocrine disorders, decreased nutrient levels and increased rancidity in fats (36)
**Co-ops/Home made – Co-ops products are generally not accessible to regulators to ensure safety. These products are very unlikely to contain sufficient nutrients to feed exclusively and are more likely to be contaminated with pathogens than commercially available products. Home made diets, as stated above, are also more likely to contain pathogens unless cooked. Cooking requires supplementation to ensure completeness for your pets nutritional needs.
Comparison of FDA regulation based on personal interests
| Kratom | Raw Pet Foods | Children’s Cereal | Dry Kibble Pet Foods |
| Kratom competes with Opioid sales | Raw Pet Foods compete with dry kibble sales | Children’s cereal manufacturers support a variety of established industries | Dry kibble manufacturers support a variety of established industries (biodiesel, oleochemical, food waste and rendering industries) |
| Kratom companies are generally small, independent suppliers | Raw Pet Foods are generally from small, independent manufacturers | Children’s cereal manufacturers are huge corporate entities | Dry kibble pet foods are primarily owned by Mars, Nestle, Del Monte, and other huge corporate entities |
| Kratom experienced a first time recall due to Salmonella contamination, sickening 199, 50 of which were hospitalized (25%) (4) | Raw pet foods have experienced several pathogen related recalls, though none (0%) have been proven to be a public health risk through proper serotyping and quantification, and no human illnesses from raw pet foods have been validated. (20) | A Kellogg’s Honey Smacks recall in 2018 experienced one of numerous Salmonella related recalls, sickening 135, 34 of which were hospitalized (25%) (5) | Dry pet food recalls in 2007, 2008 and 2012 infected 190 people with 20 (10.5%) of them being hospitalized due to the outbreak strain of Salmonella Infantis. (18)
|
| FDA advice to consumers, “… the FDA advises consumers to avoid Kratom…, in any form and from any manufacturer” (1) | FDA advice to consumers, “FDA does not believe feeding raw pet foods to animals is consistent with the goal of protecting the public from significant health risks.” (17) | FDA advice to consumers, “The FDA is advising consumers to not eat and discard recalled Kellogg’s Honey Smacks cereal. If already purchased, consumers should throw it away or return to the place of purchase for a refund.”(5)
|
FDA’s advice to consumers, “Individuals handling dry pet food can become infected with Salmonella … People who believe they may have been exposed to Salmonella should monitor themselves for … symptoms.“ (19) |
| FDA advice to consumers:
“There is strong evidence that Kratom affects the same opioid receptors as morphine… The agency also remains concerned about the use of Kratom as an alternative to FDA-approved pain medications or to treat opioid withdrawal symptoms.” (1) |
FDA advice to consumers,
“Compared to other types of pet food, raw pet food is more likely to be contaminated with disease-causing bacteria. (17) Though according to FDA, CDC and Scientific data Dry Kibble is more likely to be contaminated with disease-causing bacteria |
Sugar is scientifically proven to affect opioid receptors in the brain, yet FDA does not suggest limiting cereal consumption. (2)(3)(6)
A lawsuit against Kellogg’s states that their “low sugar” products contain 18-40% added sugar. (7) |
Dry kibble pet foods are responsible for 3 CDC regulated outbreaks, sickening 190 people in 3 years. (13)(14)(15) FDA, however, does not directly advertise for consumers to have concerns over pathogens in dry kibble pet foods. |
| FDA states that Kratom has been responsible for up to 44 deaths (8) though Death Certificates do not indicate Kratom as a cause of death in most cases. (9) | FDA reports that there has not been any reported cases of severe human illnesses or deaths directly associated with raw pet food products. (1) | FDA states that Opioids were responsible for 49,068+ deaths in 2016. (10) (0.021% of users) | FDA and CDC reports that there has not been any reported cases of death associated with dry kibble pet food, but there have been 190 illnesses, 20 of them severe. (13)(14)(15) |
| Consumer Reports states that 3-5 million Americans (1.2% of the population (11)) have tried Kratom. Kratom is primarily for pain management and addiction recovery, which implies that very few to no children are exposed to this product. Based on an average of this number 0.0011% of consumers have been allegedly died from this product. (8) | Recent surveys show that up to 40% (34.8million Americans max) of the public is aware of and/or uses raw food products for their pets. (21) Other sources say as few as 4% (3.48million Americans) of people use exclusively raw products. Like meats purchased from the grocery store for human food consumption, it is rare that children are expected to handle the products, and adults have been trusted for centuries to handle raw foods appropriately. | In 2017, 236,000,000 Americans were prescribed Opioids (71.8% of the population (11)) and 2 million Americans are addicts (2.4% of users (12)) | Industry statistics show that dry kibble products comprise 77% of all pet food sales which means about 66,990,000 users are exposed to dry kibble daily. (22) |
Written by Chelsea Kent
REFERENCES:
- FDA Safety Recalls: https://www.fda.gov/Safety/Recalls/ucm603536.htm
- The relationship between opioid and sugar intake – https://www.ncbi.nlm.nih.gov/pmc/articles/PMC3109725/
- Sugar is a gateway drug – http://drugabuse.imedpub.com/is-sugar-a-gateway-drug.php?aid=7783
- Kratom CDC Outbreak, Salmonella 2018 – https://www.fda.gov/Food/RecallsOutbreaksEmergencies/Outbreaks/ucm597265.htm
- Honey Smacks Cereal CDC Outbreak, Salmonella 2018 – https://www.fda.gov/food/recallsoutbreaksemergencies/outbreaks/ucm610827.htm?utm_campaign=FDA%20Outbreak%209_26_2018&utm_medium=email&utm_source=Eloqua
- Excessive sugar intake alters binding to dopamine and mu-opioid receptors in the brain – https://www.ncbi.nlm.nih.gov/m/pubmed/11733709/
- CA Judge Certifies Class in Kellogg False Advertising Cereal Lawsuit – https://www.natlawreview.com/article/ca-judge-certifies-class-kellogg-false-advertising-cereal-lawsuit
- The dangers of taking Kratom – https://www.consumerreports.org/dietary-supplements/the-dangers-of-taking-kratom/
- Read real accounts of deaths related to Kratom, the new “dangerous opioid” – https://www.mcall.com/news/breaking/mc-nws-kratom-opioid-fda-death-examples-20180209-story.html
- NIH Overdose Death Rates – https://www.drugabuse.gov/related-topics/trends-statistics/overdose-death-rates
- Demography of the United States – https://en.m.wikipedia.org/wiki/Demography_of_the_United_States
- Opioid crisis fast facts – https://www-m.cnn.com/2017/09/18/health/opioid-crisis-fast-facts/index.html?r=https%3A%2F%2Fwww.google.com%2F
- Dry Dog Food CDC Outbreak, Salmonella 2007 – https://www.cdc.gov/salmonella/2007/pet-food-9-4-2007.html
- Dry Dog Food CDC Outbreak, Salmonella 2008 – https://www.cdc.gov/mmwr/preview/mmwrhtml/mm5744a2.htm
- Dry Dog Food CDC Outbreak, Salmonella 2012 – https://www.cdc.gov/salmonella/dog-food-05-12/index.html
- Get the Facts! Raw Pet Food Diets can be Dangerous to You and Your Pet, February 2018 https://www.fda.gov/AnimalVeterinary/ResourcesforYou/AnimalHealthLiteracy/ucm373757.htm
- FDA’s Advice: Know the Risks of Feeding Raw Foods to Your Pets, June 2014 https://www.fda.gov/ForConsumers/ConsumerUpdates/ucm403350.htm
- Multistate Outbreak of Human Salmonella Infantis Infections Linked to Dry Dog Food (Final Update), July 2012 https://www.cdc.gov/salmonella/dog-food-05-12/index.html
- UPDATED: CORRECTED BEST BEFORE DATE Diamond Pet Foods Expands Voluntary Recall, May 2012 http://wayback.archive-it.org/7993/20170112111740/http://www.fda.gov/Safety/Recalls/ArchiveRecalls/2012/ucm304917.htm
- For detailed information on this topic please email FoodRegulationFacts@gmail.com
- Consumer Reports, Should You Feed Your Pet Raw Food https://www.consumerreports.org/pet-food/should-you-feed-your-pet-raw-food/
- US Pet Food Industry Statistics and Facts https://www.statista.com/topics/1369/pet-food/
- CDC Salmonella Infantis Outbreak 2018 https://www.cdc.gov/salmonella/infantis-10-18/index.html
- A rare look inside a rendering plant, Poisoned Pets – Pet food safety news and information http://www.poisonedpets.com/a-rare-look-inside-a-rendering-plant/
- FDA Updated: FDA Investigates pattern of contamination in certain raw pet foods made by arrow reliance inc, including Darwin’s Natural Pet Products and ZooLogics Pet Food https://www.fda.gov/AnimalVeterinary/NewsEvents/ucm596555.htm
- CDC, Estimated annual number of hospitalizations and deaths caused by 31 pathogens transmitted commonly by food, United States https://www.cdc.gov/foodborneburden/PDFs/scallan-estimated-hospitalizations-deaths-foodborne-pathogens.pdf
- HRSA (Health Resources & Services Administration) Data and Statistics https://www.hrsa.gov/sites/default/files/hrsa/vaccine-compensation/data/monthly-stats-aug-2018.pdf
- VAERS Home, Guide to Interpreting VAERS Data https://vaers.hhs.gov/data/dataguide.html
- FDA Melamine Pet Food Recall of 2007 https://www.fda.gov/animalveterinary/safetyhealth/recallswithdrawals/ucm129575.htm
- LII, 9 CFR 325.11 – Inedible articles: denaturing and other means of identification https://www.law.cornell.edu/cfr/text/9/325.11
- Answers Pet Food – From Farm to Bowl https://www.answerspetfood.com/about.html
- AAFCO OP – American Association of Feed Control Officials Official Publication 2018
- MSDS Sodium Selenite – http://www.sciencelab.com/msds.php?msdsId=9927277
- FDA Vitamin D Recall – https://www.accessdata.fda.gov/scripts/ires/index.cfm#tabNav_advancedSearch
- Food Safety and Inspection Service Understanding Microbiological Sampling and Testing https://www.fsis.usda.gov/wps/wcm/connect/b983318f-a4cf-4418-a6f0-d63015a9418b/1-EIOA-Micro-Sampling-Testing.pdf?MOD=AJPERES
- Scientific Evidence of Effects of HPP on Meat Products https://herospets.com/scientific-evidence-of-effects-of-hpp-on-meat-products/
Food Regulation Facts 