I’m sorry, Susan Thixton, but I don’t buy your arguments (http://truthaboutpetfood.com/it-is-not-junk-science/). Let me respond to a few points and then I’ll shut up and allow readers to draw their own conclusions.

1. Let me begin by acknowledging that aflatoxin levels are, indeed, quoted in parts per billion. I should have made that clear. Fumonisins guidelines, on the other hand, are quoted in parts per million. See FDA document 7303.001 for this information.

2. The use of “qualifying pathogens” in the context of this pet food report is out of context with FDA’s purpose in establishing this list. The “qualifying pathogens” list was established in order to establish priorities for encouraging “…the development of new antibacterial and anti fungal drugs for the treatment of serious or life-threatening infections.” The term is not a commentary on the risk to human or animal health posed by these microorganisms when present in the environment or in a food product, whether human or animal.

3. The entire genus Staphylococcus and the entire genus Streptococcus are not qualifying pathogens. Only certain species within these two genera are mentioned in the FDA Final Rule. This is akin to reasoning that because a hawk is a bird and a hawk is a predator, therefore all birds are predators. Just because methicillin-resistant Staphylococcus aureus and vancomycin-resistant Staphylococcus aureus are on the qualifying pathogens list, that does not mean that ALL Staphylococcus are “qualifying pathogens,” even assuming the relevance of the designation to this pet food testing project.

4. In saying that a pathogen such as Acinetobacter is mainly associated with hospital-acquired infections, this does not mean that Acinetobacter is mainly or only found in hospitals. Rather, it means that most infections caused by Acinetobacter are hospital-acquired. Acinetobacter are widely found in the environment, in soil, and even on human skin.

5. I am not disputing the capabilities of Dr. Gary Pusillo as a veterinary nutritionist. Nor have I made any comments on the nutritional testing portion of the study, because veterinary nutrition is outside of my area of expertise, just as microbiology is outside of the expertise of Dr. Pusillo. Similarly, Dr. Purejav’s degrees are in the area of animal science, according to his LinkedIn profile. Would you ask a gastroenterologist to diagnose a neurological problem or read and magnetic resonance images of the brain? Of course not. Why, then, should one expect a veterinary nutritionist and an animal science expert to be the most appropriate individuals to develop, oversee and interpret the results of a microbiology testing program?

6. With all due respect to the reputation and status of Baylor University, the more closely I look at the microbiology findings -especially from the canned foods – the more skeptical I become as to the protocol used during testing. Canned foods should be sterile, with the possible exception of a few spores of highly heat-resistant bacteria. Yet a significant number of the canned food samples were found to contain a long list of microbes that are not especially heat-resistant. It takes special training and equipment and a highly controlled and sterile environment to conduct a reliable microbiology test on a canned food. Contamination of the sample by the lab analyst can occur all too easily. Not all labs are equipped for this level of testing, and not every lab technician or microbiologist has received the necessary training to perform the testing correctly. Baylor’s Microbiology program is housed within its College of Medicine, whereas this type of testing is more commonly taught in a food or pharmaceutical microbiology setting.

7. There is no such thing as searching for “all bacteria” in a food sample. Either a lab is provided with a list of bacteria to search for, or the lab will be asked to isolate and identify as many different bacteria from the sample as possible. Bacteria that are faster or more robust in their growth, or that are present at higher concentrations may outgrow and mask the presence of other bacteria in a sample. If the lab was provided with a list, then that list should have been included in the report.

Finally, Susan, we do not live in a sterile world. There are bacteria in and on just about everything with which we and our pets come into contact. Some of these bacteria are helpful – such as those that ferment milk or those that are used to produce beer or wine; some of them are benign – neither helpful nor harmful in most circumstances. And some – the minority – are pathogens, capable of causing infections in humans or animals. That is the world we live in.

As for the study that you commissioned, I applaud your good intentions. But, in my opinion, the outcome is still junk science.