Raw pet food producer hit with FDA Warning Letter

G & C Raw, LLC (G & C) needs to clean up its act according to a December 12, 2019 Warning Letter from the US Food and Drug Administration (FDA).

G & C is a manufacturer of raw pet food and is based in Versailles, Ohio.

FDA inspected the G & C manufacturing facility in April and May 2019, and found several instances of insanitary practices, potential for cross-contamination, inappropriate and uncontrolled thawing conditions for frozen ingredients, and inadequate preventative controls.

Some of the practices and deficiencies highlighted in the Warning Letter include:
1. Frozen beef hearts were set out at room temperature to thaw on April 22nd, and remained at room temperature until April 24th, when they were used in the manufacture of raw Beef Veggie and Fruit Dog Food. This extended exposure to room temperature would have allowed bacteria to proliferate in the raw beef hearts.
2. An employee wearing gloves lifted a barrelG that had been resting on the floor, grabbing the bottom of the barrel with one gloved hand. Without changing to a fresh pair of gloves, that employee then used both hands to handle the raw meat ingredients, potentially transfering contaminants from the floor to the ingredients
3. An employee was observed using a cell phone while weighing open containers of raw Beef Veggie and Fruit Dog Food. The employee continued to handle the raw dog food without changing to a fresh pair of gloves.
4. An employee used a hose connected to a processing area sink to wash down a van in the parking lot, then returned the hose to the processing area for inside use.
5. Two finished product samples collected during the inspection were found to contain Listeria monocytogenes, a human and animal pathogen. One environmental sample contained Listeria grayi and Listeria innocua, non-pathogenic species that are indicators of insanitary conditions.

In addition to the problems identified during the 2019 inspection, the Warning Letter also noted that G & C pet foods analyzed in 2018 by the Ohio Department of Agriculture were found to contain Listeria monocytogenes in one instance, and Salmonella in another.

While the contaminated products were recalled by the company, FDA considered this an indication of an ongoing problem.

The FoodBugLady weighs in

Some pet food bloggers, and many consumers, are inclined to give raw pet food manufacturers the benefit of the doubt whenever a product recall is announced or an enforcement action is undertaken against such a company by FDA.

“FDA is discriminating against raw pet food,” and “FDA is discriminating against small companies who can’t fight back,” are two rallying cries I have seen in recent years.

In my opinion and experience, this is nonsense.

Conditions such as those described in the Warning Letter issued to G & C would not be tolerated in the manufacture of human food, regardless of the size of the company. Equally, they should not be tolerated in the manufacture of pet food, regardless of whether the finished product is raw, canned, or kibble.

Insanitary practices are insanitary practices, no matter where they occur or by whom they are perpetrated. There is no excuse for sloppy handling, poor supervision of employees, or unsafe holding temperatures.

Anyone who undertakes to produce a commercial food for human or for animal use must bear full responsibility for the safety of the finished products.

Consumers should – and must – demand no less.

Recalls and Alerts: December 22 – 26, 2019

Here is today’s list of food safety recalls, product withdrawals, allergy alerts and miscellaneous compliance issues. The live links will take you directly to the official recall notices and company news releases that contain detailed information for each recall and alert.

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United States

Food Safety Recall: Almark Foods expands its earlier product recall to include all hard-boiled eggs manufactured at the firm’s Gainesville, Georgia facility, including all retail, pillow pack, pouch pack, frozen diced, and protein kit products, due to potential contamination with Listeria monocytogenes.

Food Safety Recall: Bakkavor Foods USA, Inc. recalls Trader Joe’s Egg Salad (6 oz; All Use By date codes up to and including 12/27/19; UPC 0066 6695) and Trader Joe’s Old Fashioned Potato Salad (20 oz; All Use By date codes up to and including 12/27/19; UPC 0032 1747) due to potential Listeria monocytogenes contamination.

Food Safety Recall: Dierbergs Markets recalls various products containing hard-boiled eggs supplied by Almark Foods due to potential Listeria monocytogenes contamination. Please refer to the recall notice for a complete list of affected products.

Food Safety Recall: Reichel Foods Inc. recalls Pro2Snax To The Max Granny Apples /Hard Boiled Egg/Cheddar/Cashew & Craisin (UPC 649632001490) and Pro2Snax To The Max Gala Apples/Hard Boiled Egg/White Cheddar/Almond & Craisin (UPC 649632001483) due to potential Listeria monocytogenes contamination.

Food Safety Recall: Great American Deli recalls GAD #114 Egg Salad Sandwich (4.8 oz; UPC 7-41431-00114-2) due to potential Listeria monocytogenes contamination.

Food Safety Alert (Update): FDA warns that yellowfin tuna from Truong Phu Xanh Co., LTD with a production date in 2019 should not be consumed because it may have the potential to cause scombrotoxin fish poisoning. Tuna from this supplier could have been sold thawed or frozen; and could have been sold as ground tuna meat, poke cubes, steaks, or loins; this product could still be within its shelf life.­­ Anyone who received tuna from this supplier should not sell, serve, or consume it and should discard it.

FDA Warning Letter: FDA warns G & C Raw, LLC, a producer of raw pet food, that an inspection of the company’s facilities revealed numerous instances of improper handling of raw ingredients and finished products as well as insanitary conditions during the production and packaging of the company’s raw pet food products. As of the date of the Warning Letter, the company has not responded adequately to FDA’s concerns.

Canada

Allergy Alert: Tosuta International Sales Ltd. recalls three varieties of Lander’s Australia Shortbread Cookies due to undeclared gluten, wheat and milk. Please refer to the recall notice for a complete list of affected products.

Food Safety Recall: D. Tyers Foods International Inc. recalls Casa Madaio brand Burrata cheese (250g; Lot #19337; Use by 12/20/2019) due to generic E. coli and Staphylococcus aureus contamination.

Europe

Allergy Alert (Belgium): Cyril Chocolat recalls Cyril Chocolat brand Choco Black and White (250g; Best before 30/05/2020) due to undeclared hazelnuts.

Allergy Alert (Belgium): Jumbo Belgique recalls Jumbo Mini Burgers-Nuggets (140g; Lot #201494; Best before 16/01/2020) due to undeclared soy.

Allergy Alert (Belgium): Revi Food recalls Bouillon de Poisson “à l’Ostendaise” (700g; Expiry date 09/01/2020) due to undeclared celery.

Allergy Alert (Belgium): Industry recalls SoFine and ProTerra brands Chicken Sticks and Vegan Nuggets due to undeclared mustard. Please refer to the recall notice for additional details on the recalled products.

Allergy Alert (Ireland): Aldi recalls Cucina Green Pesto (190g; all lot codes) and Cucina Red Pesto (190g; all lot codes) due to undeclared peanut.

Allergy Alert (Netherlands): Jumbo recalls Jumbo Wholemeal Bread Rolls (4-pack; Best before December 29, 2019, January 12, 2020, February 9, 2020, March 8, 2020) due to undeclared mustard.

Allergy Alert (Netherlands): Jumbo recalls Jumbo Mini Burgers-Nuggets (140g; Lot #201494; Best before 16/01/2020) due to undeclared soy.

Food Safety Recall (Austria): Broger Bregenzerwälder Fleischwaren GmbH & Co KG recalls Rosenspeck (all best before dates from 19.01.2020) due to potential Listeria monocytogenes contamination.

Food Safety Recall (Belgium): Fresh Concept recalls Saucisson au persil / parsley sausage (150g; various lot codes and Best Before dates) due to Listeria monocytogenes contamination. Please refer to the recall notice for a complete list of affected lot codes.

Food Safety Recall (France): SAPRESTI TRAITEUR recalls SAPRESTI TRAITEUR brand Tourbillon de bloc de foie gras de canard et figues (135g; sold between 20/12/2019 and 23/12/2019) due to Listeria monocytogenes contamination.

Food Safety Recall (Germany) Märsch Importhandels-GmbH recalls Ja! Mandeln gehackt / chopped almonds (100g; Best before 25.06.20) due to foreign matter (metal) contamination.

Asia, Africa and the Pacific Islands

Allergy Alert (Singapore): Cold Storage Singapore (1983) Pte Ltd. recalls Waitrose Basil Pesto Green (190g) and Waitrose Pesto Tomato (190g) due to undeclared peanut.

Allergy Alert (Israel): Ruledin food importers Ltd. recalls chocolate flavored cream coated sweet waffle (40 x 18g; Expiry dates 21/8/20, 22/8/20, 23/8/20; Product of Turkey) due to undeclared milk.

Australia and New Zealand

Food Safety Recall (Australia): Daly Potato Company recalls Daly Potato Company Bacon and Dijon Gourmet Potato Salad (Use By 08/01/2020) due to Listeria monocytogenes contamination.

Valley Proteins receives FDA Warning Letter one year after pentobarbital found

Valley Proteins, Inc., a renderer located in Winchester, Virginia, was issued a Warning Letter from the US Food and Drug Administration (FDA) on November 18, 2019, one year almost to the day after FDA found pentobarbital in a sample of the company’s “animal fat product.”

The Warning Letter cited several violations of the Federal Food, Drug and Cosmetic Act revealed during the course of FDA inspections carried out in February 2019 and April 2019.

The animal fat product was adulterated due to the presence of pentobarbital

According to the Warning Letter, FDA advised Valley Proteins on December 18, 2018 that the agency had found pentobarbital in a sample of the Company’s animal fat product.

Despite the requirements spelled out in the Company’s formal Recall Plan, Valley Proteins “…did not take immediate action to notify customers or recall the product…”

On four separate occasions in February and in April 2019, FDA inquired as to whether the Company planned to recall the contaminated product. Valley Proteins declined to initiate a recall and refused to supply FDA with requested information regarding the amount of potentially affected product that was distributed by the Company before it learned of the pentobarbital contamination.

In response to FDA’s finding, Valley Proteins asserted that pentobarbital is an “unavoidable contaminant not known to present a health hazard,” an assertion strongly refuted by FDA in its Warning Letter, which included the following statement:

Adulteration of animal food with pentobarbital is not unavoidable. It is your responsibility to prevent adulteration of animal food with unsafe new animal drugs by ensuring that you are not receiving ingredients from your suppliers that contain unsafe new animal drugs or by developing methods to ensure that materials you receive containing unsafe new animal drugs are segregated and not used for animal food.”

The animal fat product was adulterated due to Animal Food Hazard Analysis and Risk-Based Preventive Controls (PC) violations

Specifically, Valley Proteins did not “…identify and evaluate hazards that may be specific to the source of [the] raw material, which included carcasses of animals euthanized with pentobarbital” in that the Company’s Hazard Analysis “…did not list Pentobarbital as a known and reasonably foreseeable hazard.” 

Valley Proteins began cleaning operations and started testing for pentobarbital in January 2019. However, it did not provide FDA with any indications as to how it planned to account for adulterated product that was distributed prior to starting its cleaning and testing program.

In fact, the Company continues to assert that it has no legal requirement to recall any products due to pentobarbital contamination.

In an update to its Hazard Analysis documentation, the Company states that it will no longer accept or process “dead stock” (i.e., euthanized animals). However, in a letter to its customers, the Company indicates that it “…will accept euthanized animals for collection and disposal, but chemically euthanized animals will not be rendered.”

FDA has requested, but has not yet received, information as to how Valley Proteins proposes to collect and dispose of euthanized animals.

Microbial hazards

FDA also highlighted concerns regarding the Company’s process control to prevent microbial hazards.

Specifically,
1. Bills of Lading for some products should have – but did not – including the statement, “not processed to control microbial hazards.”
2. The Company’s process controls lacked adequate parameters for controlling some microbial hazards, including Salmonella, E. coli and Listeria monocytogenes.
3. The process control parameters provided to FDA by the Company did not match the parameters as determined in the scientific study presented to validate those process controls.

Where did the adulterated animal fat go?

According to a spokesperson for FDA, the Company claims that none of the adulterated animal fat was distributed to pet food manufacturers. However, the firm did not provide any documentation to support its assertion.

The Warning Letter describes the adulterated sample as having been taken from a finished fat tank “…used to store animal fat distributed for use in animal food.” This could refer to food for livestock, including poultry, cattle, etc.

FDA is at risk of becoming a paper tiger

Setting aside the specific violations cited in this Warning Letter, Valley Proteins is just the latest in a string of companies that has refused an FDA request for a product recall, for documentation, or for some other aspect of cooperation in an investigation.

In recent months, we have seen at least two other instances of non-cooperation, even in the face of a direct risk to the health of consumers or their companion animals.

Lystn, LLC (Answers Pet Food) initiated a lawsuit against FDA, the US Department of Health and Human Services, and the Colorado Department of Agriculture, among others, rather than agree to a recall of its contaminated raw pet food products.
FDA was forced to take the extreme step of suspending facility registration of Topway Enterprises Inc. (a Texas-based seafood producer), citing “…an unwillingness and disregard by the company to cease operations and correct severe violations at their facility.”

These two examples are only the tip of the iceberg. It is not uncommon for company officials to decline FDA inspectors access to consumer complaint records, product formulations, and other information that inspectors often need to conduct their oversight. It is not unknown for a company to deny an inspector permission to document observations by photography, and later dispute the accuracy of the inspector’s written observations.

FDA’s remedies in the face of non-cooperation are limited. In theory, FDA is empowered under existing law to demand full access to these records. In practice, however, there is little an FDA inspector can do to enforce the agency’s authority other than by suspending the inspection and applying for a court order.

Similarly, FDA’s mandatory recall authority is a clumsy and slow instrument of last resort. The mandatory notification and appeal process would render moot an eventual mandatory recall of a perishable product. FDA’s best tool is to issue a Public Health Alert, warning consumers of the hazard posed by the offending firm’s products.

It’s time for a more assertive FDA stance

A driver caught for speeding is obliged by law to produce relevant documentation (driver license, vehicle registration and proof or insurance) upon request. Declining such a request lands the driver in even hotter water than before. Nor can the driver fight the charge by claiming that a speed limit is arbitrary and thus may be ignored.

Perhaps it’s time for FDA to arm its inspectors with the appropriate warrant or court order at the start of an inspection, especially in the case of a company with a history of prior non-cooperation.

Perhaps it’s time for an amendment to the Food Safety Modernization Act. One that will grant FDA the authority to suspend a company’s operations in the event of non-cooperation with a lawful inspection.