It’s tough to find a contaminant when you don’t know what you’re looking for. But that doesn’t mean FDA isn’t trying hard to figure out why chicken jerky pet treats from China seem to be making so many dogs seriously ill.

Since the beginning of 2011, FDA has received a total of 537 reports from dog owners and veterinarians of dogs that fell ill after being fed these popular dog treats. Several days ago, I asked Laura Alvey of FDA what the agency was doing to solve the mystery, and received this reply:

“Testing continues and is ongoing. We have tested samples from all over the country.

Since so many of the reports received involved vomiting and diarrhea, we were looking for microbial pathogens. We have tested for salmonella and none have come back positive. We have been testing for chemical toxicants, including melamine, melamine analogs and diethylene glycol (DEG) and none have come back positive.

Unless we detect a contaminant and have evidence a product is adulterated, we are limited in what regulatory actions we can take. The regulations don’t allow for products to be removed based on complaints. We will continue to monitor.

We have reached out to relevant competent authorities in other countries to request intelligence on increased reports of illness in dogs associated with consumption of chicken jerky treats, any investigations conducted, analyses conducted on suspect product, etc. We have received some feedback regarding our questions and some suggested collaboration/sharing of information.“

I asked the same question of the Canadian Food Inspection Agency (CFIA), and had a very different – and far less comforting – reply from Dr. Carl Rudat, a Veterinary Program Specialist with CFIA.

“The CFIA,” Rudat said, “does not have a process that records calls about chicken jerky treats. The CFIA has not conducted analyses of these products. Pet food and pet treats are unregulated commodities in Canada. However, due diligence is being done and Chinese pet treat facilities have been inspected by CFIA veterinarians. I hope you find this information useful.”

So, Canada is NOT recording or tallying illness reports on chicken jerky treats, is NOT testing chicken jerky treats, and does NOT regulate pet food and pet treats. But have no fear, because “due diligence is being done.”

I pursued the issue further. “Was CFIA in communication with FDA on this issue?” I asked.

“CFIA is aware that the FDA is testing chicken jerky originating from China,” was his reply. “To date, nothing definitive has been determined.”

If CFIA does not regulate pet food and pet treats, what was the regulatory authority for CFIA’s policy entitled Import of Pet Food, Treats and Chews Containing Animal Products and By-Products? Why the heck was CFIA inspecting Chinese pet treat facilities? And what was meant by the reassurance that “due diligence is being done?”

I posed these questions (politely, of course), and was told that the legal framework for CFIA’s Import of Pet Food, etc. policy is the Health of Animals Act and Regulations. Animal by-products are regulated under this Act, and “…most pet food begins as an animal by-product.” Dr. Rudat added that CFIA has the authority to prevent “diseases of concern” from entering Canada. He did not elaborate on his “due diligence” statement.

Sounds to me as though pet food is regulated when CFIA finds it convenient, but not otherwise.

The situation on the US side of the world’s longest undefended border is quite different. FDA has taken a lead role in trying to find the source of the chicken jerky problem, and is continuing to pursue the issue assiduously. Unfortunately, as FDA Spokeswoman Laura Alvey reminded me, the agency cannot take regulatory action unless a contaminant has been detected and there is evidence that a product is adulterated.

I expect that FDA eventually will find the answer to this mystery. Presumably, once FDA comes up with a solution for the problem, Canada will gladly accept the fruits of a free ride.

Since January 1st, 2012, FDA has received 184 reports of pets who became ill after being fed chicken jerky dog treats. That’s on top of the 353 reports lodged with the federal agency in calendar year 2011, according to information provided  to eFoodAlert by FDA Spokesperson Laura Alvey.

Most of the 2011 reports – 283 of them – were filed after FDA issued an updated warning to dog owners on November 18th, 2011.

As I reported last November, FDA continues to warn pet owners that chicken jerky products imported from China may be associated with the development of Fanconi-like syndrome in dogs who eat the treats on a regular basis. Similar problems have been reported in Canada, according to the Canadian Veterinary Medicine Association.

Unfortunately, neither FDA nor the Canadians have been able to identify an ingredient or contaminant in the chicken jerky dog treats that would account for the illnesses. “Testing is ongoing,” Alvey reported to me yesterday by email. “We have tested samples from all over the country for microbial pathogens (salmonella) and chemical toxicants and so far, nothing has come back positive,” she added.

FDA is encouraging consumers to submit illness-linked samples of pet treats to them for analysis. “[w]e would most certainly want to try to obtain a sample of a consumer’s pet product if they still had it and they were reporting it in association with a pet illness to the FDA,” Alvey stated.

Unfortunately, unless and until FDA can determine the presence of an adulterant (microbiological or chemical) in the pet treats, the agency is unable to request a recall. As always, suspects – including pet treats – are innocent until proven guilty.

Mollie Morrissette has been following this story closely, and has written several informative articles, which can be found on her Poisoned Pets blog site.