Pentobarbital in Pet Food. A dirty little secret is now out in the open

This story by Phyllis Entis first appeared in The Bark and is reposted here with permission

Talula died on New Year’s Day, 2017, a casualty of pentobarbital-adulterated pet food.

Pentobarbital is the active ingredient in the sedative Nembutal. People who rely on this habit-forming drug over a long period of time develop a tolerance to it, requiring ever-higher doses to achieve the desired sedative effect. Veterinarians use pentobarbital both as a sedative and as a humane euthanasia agent.

In the 1990s, several veterinarians contacted the U.S. Food and Drug Administration (FDA) to express concern that some of their companion-animal patients had become less responsive to the drug. They worried that the animals might have developed tolerance to the effects of pentobarbital as a result of chronic exposure to low levels of the drug in pet foods.

The FDA Digs In

Reacting to the red flag raised by the veterinary community, the FDA surveyed a selection of dry dog foods (kibble) for pentobarbital residue in 1998 and again in 2000. The 1998 survey included 90 individual samples from 49 different kibble varieties and 17 different brands. Twenty-nine of the 49 products were found to contain pentobarbital, with nearly 50 percent of the 90 individual samples testing positive for the drug.

In the second survey, which began in December 2000, the FDA screened 60 samples of kibble for pentobarbital, this time also measuring how much of the drug was present in the contaminated samples.

Compared to the 2000 survey, the one done in 1998 included more products with rendered ingredients near the top of the ingredient list, and the proportion of samples containing pentobarbital in the first survey was notably higher than in the second: 49 percent versus 18 percent. This led the FDA to conclude that pet foods containing higher amounts of rendered ingredients were more likely to be contaminated with pentobarbital.

Even a trace amount of pentobarbital is enough to establish that a pet food is adulterated. Nevertheless, the FDA took no regulatory action against the manufacturers of the pentobarbital-contaminated kibble identified in either survey. According to the agency, the level of pentobarbital in even the most highly contaminated sample was far below the amount that might make a dog ill.

In response to persistent rumors that the rendered remains of euthanized companion animals were being recycled into pet food, the FDA also tested pentobarbitalpositive samples from the 2000 survey for the presence of cat or dog DNA. Results were negative, and the agency concluded that the rendered remains of euthanized cattle or horses were the most likely sources of the pentobarbital contamination.

Rendering is the practice of using heat to extract useable fat and protein from animal carcasses, animal by-products and foodprocessing waste (such as used cooking oil). With a few exceptions, products of rendering are not considered fit for human consumption. However, they may be used as ingredients in animal feeds and pet foods as long as they do not contain any poisonous or harmful contaminants, such as pentobarbital.

The Evanger’s Affair: A Tangled Web

Pentobarbital was back in the news in 2017. Evanger’s Hunk of Beef au Jus canned dog food was linked to the death of Talula, and to the illness of four other dogs who had been fed from the same can. A massive quantity of pentobarbital was found in samples of the pet food, and the drug was also recovered from Talula’s stomach contents on necropsy.

Where did the pentobarbital come from? No rendered ingredients were listed on the product labels, and Evanger’s claimed to use “USDA-inspected, human-grade” beef in its products.

Evanger’s label claims were called into question when FDA investigators examined bills of lading and invoices from Bailey Farms, Evanger’s principal supplier of beef. The paperwork described the meat as “Inedible Hand Deboned Beef. For Pet Food Use Only. Not Fit For Human Consumption.” In addition, some samples of Evanger’s canned dog food contained trace quantities of horse meat. (Horse meat is permitted in pet food as long as its presence is disclosed in the list of ingredients.)

Evanger’s management pounced immediately on the horse-meat finding, insisting the company had been misled, and that Bailey Farms must have supplied Evanger’s with meat from chemically euthanized horses, mislabeling it as beef. The horse meat, Evanger’s claimed, was the source of the pentobarbital found in the canned dog food.

In response to urging from the FDA, Evanger’s voluntarily recalled a limited quantity of Hunk of Beef on February 3, 2017. On March 3, citing an “abundance of caution,” Evanger’s expanded its initial recall to include every batch of Hunk of Beef, Braised Beef and Against the Grain Pulled Beef canned dog foods manufactured between December 2015 and January 2017. (The “Against the Grain” brand name is owned by Nutripack LLC. Both Nutripack and Evanger’s are owned by members of the Sher family.)

According to the company, the March recall encompassed all of the products that contained meat supplied by Bailey Farms. By mid-April, this assurance was proved hollow. Pentobarbital was found in two Cocolicious canned dog-food products manufactured in 2015 by Evanger’s for Party Animal, a small California-based company. On April 24, Party Animal announced a recall of both products.

The Beef Tallow Connection

The Evanger’s incident prompted media outlet WJLA to commission a survey of other canned pet-food brands for pentobarbital contamination. The results of that survey rocked pet owners: in 2018, WJLA reported that several Gravy Train canned dog foods were adulterated with pentobarbital.

The Gravy Train name is owned by Big Heart Pet Brands, a subsidiary of the J.M. Smucker Company. After an internal investigation, the company announced that the source of the pentobarbital was beef tallow from a single supplier. At first, Smucker and Big Heart Brands initiated a company-to-company product withdrawal of a range of products from retail stores. Eventually, the company issued a voluntary recall of all the affected products.

Beef tallow was blamed for yet another pentobarbital contamination episode in 2018, this time involving a limited quantity of Orijen and Acana kibbles manufactured by Champion Petfoods. The relatively low level of pentobarbital in the tallow was not considered to be a health hazard. Champion reacted promptly to quarantine the contaminated tallow and retrieve the potentially affected production lots from its distribution chain. Most of the product manufactured with the contaminated tallow never reached the retail market, and there was no formal recall.

Beef tallow, the fat extracted from rendered beef, is usually disclosed on pet food labels as “beef fat” or “animal fat.” By law, tallow intended for use in human food, pet food and animal feed must not be derived from chemically euthanized animals. In practice, the Evanger’s incident exposed a large hole in this regulatory dyke: the food industry and the FDA’s reliance upon an honor system to identify and segregate carcasses of chemically euthanized animals.

When FDA inspectors visited Bailey Farms in 2017, they were told that the company relied on its customers (i.e., the farms from which it picks up dead animals) to tell its drivers whether any of the dead animals had been chemically euthanized. The drivers were instructed to mark those carcasses with orange paint before loading them onto their trucks. The orangemarked carcasses were segregated from the other carcasses upon arrival at the rendering plant.

According to Bailey’s owner, Gregory Schiel, the company would prefer not to pick up chemically euthanized animals at all. However, Schiel expressed concern that some customers might falsely claim that chemically euthanized animals had died from natural causes in order to dispose of the carcasses more easily.

The Legal Fallout

The Evanger’s affair spawned several lawsuits, including at least two class action lawsuits.

Pet owners who purchased Evanger’s products filed a lawsuit against Evanger’s, Against the Grain, Nutripack and the Sher family’s management company, collectively alleging one dog death (Talula) and seven illnesses as a consequence of feeding a product manufactured by the defendants.

A pet owner who purchased the recalled Party Animal products filed a lawsuit against both Party Animal and Evanger’s, alleging that the Party Animal product made her dog seriously ill.

Party Animal sued Evanger’s and Nutripack.

Evanger’s sued Bailey Farms, its meat supplier.

Colony Insurance Company sued Evanger’s, Nutripack and the class representatives in both class action lawsuits. In its filing, Colony Insurance claimed that Evanger’s owners had lied on the insurance policy application, thus voiding the policy.

The Gravy Train incident resulted in a class action lawsuit against Big Heart Brands. Collectively, plaintiffs in that lawsuit alleged 27 pet deaths (26 dogs and one cat) and two illnesses in pets fed one or more Big Heart canned dog foods.

At the time of the pentobarbital revelation, Champion Petfoods was also defending itself from a class action lawsuit based on alleged excessive heavy metal contamination. The plaintiffs added pentobarbital contamination to the existing complaint.

Of the 28 pet deaths alleged by the plaintiffs in the various lawsuits, only Talula’s death was lab-confirmed to have been due to pentobarbital contamination in a commercial dog food. In the other 27 deaths, the reported symptoms matched those associated with pentobarbital, but the food was not tested at the time the pets fell ill, and in most cases, necropsies were not carried out.

All of the lawsuits are still pending.

Hill’s quietly adds to pet food recall list

Nearly two months after its last update, Hill’s Pet Nutrition has added another lot code to the list of products recalled due to elevated levels of vitamin D.

The company has expanded its recall of Hill’s® Prescription Diet® i/d® Canine Chicken & Vegetable Stew 12.5oz (SKU 3389) to include Batch code 102020T21.

The item was sold in the USA and Canada.

The series of recalls was triggered by reports of pet deaths and pet illnesses due to toxic levels of vitamin D in the pet foods. The first recall was announced on January 31, 2019. An expansion of the recall was announced on March 20, 2019.

The recalled products were distributed around the world. A breakdown of recalled products by country was posted on eFoodAlert on March 21st, and has since been updated.

The Hill’s recalls have triggered more than 20 class action lawsuits across the USA. A motion for a multidistrict litigation has been submitted, which would transfer all the actions related to the Hill’s recall to U.S. District Court for the Northern District of California. The hearing date for the motion is set for May 30, 2019.

According to information obtained in response to a Freedom of Information Act request, the source of the excessive vitamin D was an error in the formulation of the vitamin pre-mix by a Hill’s supplier.

The identity of the pre-mix supplier has not been revealed.

 

 

Darwin’s Natural Pet Products silent recall surpassed 11 tons of raw dog food

This story by Phyllis Entis first appeared in Food Safety News and is reposted here with permission

On February 7, 2019, in a move announced only via email to its direct customers, Arrow Reliance, doing business as Darwin’s Natural Pet Products (Darwin’s), recalled 11.7 tons of raw dog food.

The recall was first divulged to the public on March 26, 2019, by the US Food and Drug Administration (FDA) via a news release cautioning pet owners to avoid feeding the recalled products.

According to the FDA Enforcement Report issued on April 3, 2019, the recall encompassed:

  •  Natural Selections Turkey and Vegetable Meals for Dogs, frozen, raw dog meals, packaged in 2 lbs. thermo-formed sealed plastic package, divided into 8 oz. portions. Lot #5339, manufactured on 10/26/18 (listed as 5339(11)181026 on the label)
  • Natural Selections Chicken and Vegetable Meals for Dogs, frozen, raw dog meals, packaged in 2 lbs. thermo-formed sealed plastic package, divided into 8 oz. portions. Lot # 5309, manufactured on 10/19/18 (listed as 5309(11)181019 on the label)
  • •Natural Selections Chicken and Vegetable Meals for Dogs, frozen, raw dog meals, packaged in 2 lbs. thermo-formed sealed plastic package, divided into 8 oz. portions. Lot # 5375, manufactured on 11/6/18 (listed as 5375(11)181106 on the label)

Although Darwin’s claimed to have notified all of its affected customers via email of the Salmonella contamination, Food Safety News has learned that at least one customer did not receive the initial notification.

When FDA is concerned as to the effectiveness of a company’s recall action, the agency has the authority to request distribution information in order to audit the recall, as detailed within the agency’s Investigations Operations Manual.

According to a Product Information Update posted on the company’s website on March 27, 2019, Darwin’s declined to furnish distribution information to FDA, citing their customers’ right to privacy.

Darwin’s ships its products directly to end users, and does not use third-party distributors, wholesalers or retailers.

In its March 27th update, Darwin’s further claimed that FDA’s March 26th news release was in retaliation for the company’s refusal to share customer contact information.

When asked to respond to this allegation, an FDA spokesperson told Food Safety News, “The FDA’s first priority is to protect public health. In accordance with this mission, we want to ensure that anyone who may have purchased or used violative product is informed of the issue and the health risk, so that they can take appropriate steps to protect themselves and their pets. In the absence of an adequate public notification by the firm, or confirmation from the firm that it has promptly and effectively communicated the recall to all customers, the agency may issue its own public notification.”

Commenting on Darwin’s characterization of the company’s message to its customers as a warning, not a recall, the spokesperson added, “The FDA considers the actions taken by Arrow Reliance to remove the violative product from the marketplace to meet the regulatory definition of a recall.”

Finally, Darwin’s reiterated a past claim that Salmonella is not a concern for healthy animals, citing “information from experts” on FDA’s website.

The citation in question was a research article that concluded, in part, “This study suggests an overall decline in the prevalence of Salmonella-positive dogs and cats over the last decades and identifies consumption of raw food as a major risk factor for Salmonella infection.” (emphasis added).

The same study determined that almost half of the Salmonella-positive animals did not suffer from diarrhea.

Salmonella-infected animals are still capable of passing the bacteria in stool and infecting their human companions or other animals.

Salmonella-contaminated pet foods have caused illness in both pets and humans in the past. Most recently, a raw turkey meat pet food was linked to cases of Salmonella illness that were part of a nationwide outbreak of multidrug-resistant Salmonella Reading infections.

FDA recommendations to consumers

  •  If you have Darwin’s Natural Pet Products Natural Selections Chicken Recipe with Organic Vegetables for Dogs (5309(11)181019 and 5375(11)181106) or Darwin’s Natural Pet Products Natural Selections Turkey Recipe with Organic Vegetables for Dogs (5339(11)181026), stop feeding it to your pets and throw it away in a secure container where other animals, including wildlife, cannot access it.
  • Consumers who have had this product in their homes should clean refrigerators/freezers where the product was stored and clean and disinfect all bowls, utensils, food prep surfaces, pet bedding, toys, floors, and any other surfaces that the food or pet may have had contact with. Clean up the pet’s feces in yards or parks where people or other animals may become exposed. Consumers should thoroughly wash their hands after handling the recalled product or cleaning up potentially contaminated items and surfaces.
  • People who think their pets have become ill after consuming contaminated pet food should first contact their veterinarians. Veterinarians who wish to have pets tested for Salmonella may do so through the Vet-LIRN Network if the pet is from a household with a person infected with Salmonella.
  • The FDA encourages consumers to report complaints about pet food products electronically through the Safety Reporting Portal or by calling their state’s FDA Consumer Complaint Coordinators.

Incident timeline

  •  December 27, 2018, FDA received a pet illness complaint from a consumer, citing Darwin’s product. FDA obtained three intact packages of Darwin’s raw dog food from the consumer and found Salmonella in all three.
  • On or about the week of January 28, 2019, FDA notified Darwin’s of their findings and recommended a voluntary recall. Darwin’s notified by email those customers who had received product from one or more of the contaminated lots but declined to issue a public recall notice.
  • February 7, 2019, Darwin’s posted a Product Information Update on their website, acknowledging the incident.
  • March 26, 2019, FDA issued a caution to pet owners, informing the public of Darwin’s Salmonella contamination.
  • March 27, 2019, Darwin’s issued a second Product Information Update, rebutting FDA’s public statement.