Dear Readers,

On March 31, 2013, I announced that I was “moving on,” and I ended my daily posts on eFoodAlert. Since then, I have been concentrating on my creative writing projects. Nevertheless, I’ve continued to monitor food safety stories, muttering under my breath from time to time about the quality of some of the coverage. But I have not been motivated to comment publicly on any of these stories until today’s release of a pet food safety study carried out under the auspices of The Association For Truth In Pet Food (ATPF). I decided that I could not let this report stand unchallenged and unanswered.

The Association for Truth In Pet Food (ATPF), headed by Susan Thixton, has just released a report that details the results of mycotoxin, nutrient and bacteria tests carried out on a number of brands of canned and dry cat foods and dog foods. According to James Andrews, writing for Food Safety News, the testing program was sponsored by consumers through crowdfunding and coordinated by ATPF.

Susan Thixton, writing in her TruthAboutPetFoods.com blog, describes the results of the study as “shocking and sad.” In my opinion, her adjectives are correct, but misapplied. What I find “shocking and sad” is the waste of consumers’ money in a wild goose chase after low-level pathogens of minimal risk to either humans or their pets.

Consider the “qualifying pathogens” reported in the detailed study:

• Acinetobacter. This is a low-grade pathogen that is mainly associated with hospital-acquired infections (especially in intensive care units), or with community-spread outbreaks in war zones and natural disaster areas.
• Pseudomonas. These bacteria are present in the environment, in our water, and in food. It is a cause of “swimmer’s ear.” Otherwise, Pseudomonas is an opportunistic pathogen, typically either hospital-acquired or affecting individuals with compromised immune systems or respiratory systems, such as cystic fibrosis patients.
• Streptococcus. While some species of Streptococcus are pathogenic (eg., Streptococcus pyogenes), others are benign. Some species of Streptococcus are used in the production of fermented dairy products, and are considered to be probiotic.
• Staphylococcus. While Staphylococcus aureus is associated with food poisoning (via its production of enterotoxins), and with infections, other species of Staphylococcus are either benign or are low-grade pathogens associated with hospital-acquired infections. Staphylococcus epidermidis is a common inhabitant of the skin of humans and animals. Even Staphylococcus aureus is carried on the skin and in the nasal passages of many individuals.
• Bacillus. Most species of Bacillus are benign and are widely dispersed in the environment. Bacillus is a spore-former and very heat-resistant. It can be found with great frequency in dried foods, including spices, flour, and powdered dairy products. Bacillus cereus is a source of foodborne illness, but it must attain high concentrations before it can cause illness.

In addition to these “qualifying pathogens,” the study organizers decided to troll through the foods for a long list of other irrelevant microbes, including: Anaerococcus, Comamonadaceae, Corynebacteriaceae, Halomonas (another low-risk pathogen associated with contamination of intravenous lines), Cloacibacterium, Bifidobacterium (a probiotic), Pantoea, Gemella, Peptoniphilus, Actinomyces, Sphingobium, Bradyrhizobium, Tumebacillus, Paracoccus, Paenibacillus, Lactococcus, Acetobacter, Chloroplast, and Lactobacillus (a probiotic).

The author of the study provided absolutely no rationale for this selection. Nor was any explanation offered for excluding known human and animal pathogens, such as Salmonella and Campylobacter, from the list. Where was the logic in this? What was the point in throwing money at a laundry list of irrelevant microbes? The funding did not allow species-level identification of any of the bacteria, according to the study report. Yet, without species-level identification, the results of the bacterial testing of the pet foods are worthless.

I also take issue with the presentation of the mycotoxin test results. The results are reported at levels of parts per billion (PPB), whereas these results are usually reported as parts per million (ppm) . By changing the manner of reporting the results, the study makes the data appear more shocking. For example, FDA recommends a limit of 10ppm for fumonisins in grain destined for pet food. This is the same as saying10,000 parts per billion. Even the worst performing pet food sample was well within this guidance level. Furthermore, the comparison table presents an arbitrary set of risk values generated using a proprietary formula developed by Alltech, an animal nutrition company. There is no way to substantiate the validity or the significance of these so-called risk levels.

I have refrained from commenting on the portion of the report dealing with nutritional analysis, as this is outside of my expertise. I sincerely hope that someone else will put this portion of the report under a microscope.

I acknowledge the good intentions of Susan Thixton and the Association for Truth in Pet Food, but I am appalled at the way in which this study was designed and carried out. The portions of the study relating to bacterial analysis and presentation of the mycotoxin results are the epitome of junk science. The pet-loving consumers who funded this study – and their dogs and cats – deserved far better.