Category: Evanger

Evanger’s “Muddy” Duck Story

In the latest twist to the duck tale, Susan Thixton, writing in Truth About Pet Food, reports the following clarification from Genetic ID, the third-party lab that tested Evanger’s Duck dog food:

“Genetic ID NA, Inc., the lab used by Evangers Pet Food, confirms the food tested was Grain Free Duck pet food – appearing to be the same food tested by the FDA.”

Susan adds that, as yet, she has been unable to obtain confirmation from FDA that the lot number of the Duck dog food tested by the agency matches the lot number tested by Genetic ID. Evanger claims that both FDA and Genetic ID tested samples from the same production lot of Grain Free Duck pet food.

Evanger’s web site contains the following update to their initial comments on FDA’s Warning Letter:

It has come to our attention that we used the term, “Super Premium Duck” in our response referencing the product that was tested. The product that was tested by both FDA and Evanger’s was “Grain Free Duck” in a 6 oz can, Lot #2401E02DK2. The term “Super Premium” refers to the Evanger’s line of food that the Grain Free Duck is categorized in. Again, both references refer to Evanger’s brand 6 oz duck can Lot #2401E02DK2.

For anyone who is curious about the lot numbering system used by Evanger, “24” refers to December; the third digit (in this case, “0”) represents the last digit of the year of production, meaning that the product in dispute was manufactured in December 2010 – just as Evanger indicated. “DK” – of course – identifies the product as duck. I have been unable to verify the meaning of the remainder of the lot code; I’m still waiting for an answer from Brett Sher on that. I suspect that the day of the month is identified by the pair of digits that follow the letter E.

Assuming that FDA and Genetic ID ran their analyses on samples from the identical batch, we are still left with a significant mystery; namely, how can two supposedly competent labs arrive at diametrically opposite test results using similar analytical methods on two samples from the same production batch?

Also, if FDA didn’t find any duck in the Grain-Free Duck product, what type of meat did they find instead?

I have been in touch with FDA’s Center for Veterinary Medicine, and I am hoping for an answer to these questions in fairly short order. Please stay tuned.

Evanger’s – The Light Dawns

Ever since I received a copy from Evanger’s of their lab report (also posted on the company’s web site), I have been trying to figure out how FDA could possibly determine that there was no duck meat present in their sample of dog food, while Genetic ID – the third-party lab used by Evanger – found duck DNA in the sample that was submitted to them for testing.

My first thought was that there was may have been a significant difference in lab methods used by FDA and Genetic ID. That thought was quashed earlier today, when I ascertained from FDA that the agency used a PCR method – the same type of method as the one used by Genetic ID. Even a slight difference in technique would not be enough to explain a total lack of positive duck meat reaction in FDA’s hands.

I was stymied until I revisited the wording of the FDA warning letter and compared it to the wording of the information released by Evanger.

Here’s the relevant portion of the Evanger statement:

“Our results show that, in fact, Evanger’s brand Super Premium Duck was detected positive for duck…”

And here’s the relevant statement from the FDA warning letter:

“The labeling indicates that Evanger’s Grain-free Duck Pet Food contains duck, but the analytical sample results did not detect the presence of duck in the product.”

A quick review of Evanger’s website brought everything into focus. Super Premium Duck and Grain-Free Duck are two VERY different products!

I challenge Evanger’s to submit samples of the same batch of Grain-Free Duck dog food analyzed by FDA to a third-party lab for testing.

Anyone care to speculate on the outcome?

Evanger’s Back In Hot Water With FDA

FDA weekly list of Warning Letters included an old familiar name this morning – Evanger’s Dog & Cat Food Company, Inc. (Wheeling, IL).

Readers of eFoodAlert who have been following the adventures of Joel and Holly Sher will remember that the company has been in and out of trouble with FDA since April 2008.

The latest problems revolve around misbranding and record keeping.

On August 19, 2010, FDA obtained samples of Lamb and Rice Dog Food from the company’s distributor. FDA’s analysis of the food failed to detect any lamb. Instead, the Lamb and Rice Dog Food contained beef.

On December 14, 2010, during its inspection of the company’s low acid-canned food manufacturing facility, FDA collected samples of Evanger’s Grain-free Duck Pet Food. Analysis of the food failed to detect any duck.

According to the Federal Food, Drug, and Cosmetic Act, “…a food is deemed to be adulterated if any substance has been substituted wholly or in part therefore.” Also, offering a product for sale under the name of another food constitutes misbranding.

In addition to the adulteration/misbranding issue, Evanger’s still has not fixed its processing documentation problem. FDA’s warning letter states that the “…firm was not able to provide processing and production records upon written demand, as required by 21 C.F.R. 108.35(h), for products manufactured in 2009…” – the period during which Evanger’s was operating under a suspended “Emergency Operating Permit” while it was supposed to be correcting its processing documentation flaws.

The company has been given fifteen (15) working days to bring its operations into full compliance, or to provide a time frame within which the corrections will be completed.

In a letter to its “Dear valued customers and distributors” dated Friday, May 6, 2011, Evanger’s disputed FDA’s lab findings on the Duck Pet Food, but made no comment on the absence of processing and production records mentioned in the agency’s warning letter.

Evanger’s letter goes on to claim that there is “…ABSOLUTELY NO HEALTH OR SAFETY ISSUE…” associated with the misbranding. I beg to differ. Some dogs are allergic or sensitive to particular sources of protein. If my dog was allergic to beef, I would be very upset to learn that the premium lamb-based product I had chosen for him contained beef instead – or in addition to – lamb.

In my post of June 17, 2009, I wondered whether Evanger’s was being singled out by FDA in order to “send a message” to the pet food industry. If this was the case, I suggested that we might owe Evanger’s an apology.

Instead, I am now convinced that Evanger’s owes its customers an apology.