FDA reveals name of Hill’s vitamin D premix supplier

DSM Nutritional Products Inc. (DSM) was the supplier of vitamin D premix to Hill’s Pet Nutrition.

DSM is an international corporation that is “…a world leading supplier of vitamins, carotenoids and other nutritional solutions…”, according to the company’s website. Its US headquarters are in Parsippany, New Jersey.

According to the FDA Weekly Enforcement Report released this morning (June 19, 2019), DSM was notified by Hill’s Pet Nutrition (Hill’s) that a dog had become ill after consuming Hills Prescription Diet W/D canned dog food, manufactured using the DSM vitamin premix.

On January 30, 2019, DSM initiated a recall of 2217 Canned Canine PMX Product Code: NP15268025, net weight: 25 Kg per package, package type: Woven polyethylene bag.

The recall encompassed two production lots – 9100058130 and 9100058131 – comprising a total of 2500 Kg (~2.75 tons) of premix.

The premix was produced on August 18, 2018.

DSM notified Hill’s of the recall by telephone. There were no other consignees, and no public recall notice was released.

Hill’s first notified FDA about potentially toxic levels of vitamin D in its canned dog foods on January 31, 2019 and initiated a recall of 25 products manufactured during the months of September 2018 through December 2018.

On March 20, 2019, Hill’s expanded the initial recall to include additional products and lot codes. A second expansion was announced on May 20, 2019.

The recalled products were distributed in the USA and around the world.

FDA initiated an inspection of Hill’s manufacturing facility in February 2019. According to the inspection report, Hill’s blamed a manufacturing error by its premix supplier (DSM) for the toxic levels of vitamin D in its canned dog foods.

Although the Hill’s written procedures called for testing of vitamin D levels in the premix, the company was unable to provide any evidence to FDA inspectors that those tests had been carried out.

Subsequent tests conducted on a retained sample of the premix revealed a level of vitamin D that was roughly 30 times the target range for this ingredient.

As of February 11, 2019, Hill’s acknowledged having received 85 consumer complaints reporting pet deaths.

More than 20 civil lawsuits have been filed against Hill’s Pet Nutrition by grieving pet owners.

FDA offers the following information regarding vitamin D toxicity to pet owners and veterinarians.

  • If your pet is having symptoms of vitamin D toxicity, contact a veterinarian immediately. Provide a full diet history to your veterinarian. You may find it helpful to take a picture of the pet food label, including the lot number.
  • Don’t feed the recalled products to your pets or any other animal. Contact the company listed on the package for further instructions or throw the products away in a way that children, pets and wildlife cannot access them.
  • Consumers can report suspected illness to the FDA electronically through the Safety Reporting Portal or by calling your state’s FDA Consumer Complaint Coordinators. It’s most helpful if you can work with your veterinarian to submit your pet’s medical records as part of your report. For an explanation of the information and level of detail that would be helpful to include in a complaint to the FDA, please see How to Report a Pet Food Complaint.
  • The FDA encourages veterinarians treating vitamin D toxicity to ask their clients for a diet history. We also welcome case reports, especially those confirmed through diagnostics. You can submit these reports electronically through the Safety Reporting Portal or by calling your state’s FDA Consumer Complaint Coordinators. For an explanation of the information and level of detail that would be helpful to include in a complaint to the FDA, please see How to Report a Pet Food Complaint.
  •  Veterinarians should also be aware that vitamin D toxicity may present as hypercalcemia, similar to dogs that have consumed rodenticide. In these cases, FDA suggests that veterinarians confirm diet history to verify whether the dog has been eating any of the recalled products.

For a comprehensive list of Hill’s Pet Nutrition canned pet foods recalled due to excessive Vitamin D, please visit Hill’s Pet Nutrition recalls: Country-by-country breakdown on eFoodAlert

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.