FDA Confirms Pentobarbital in Dog Food

Pet owners warned to avoid certain Evanger’s and Against the Grain dog food

FDA is advising pet owners and pet caretakers not to feed their pets with certain lots of Evanger’s and Against the Grain dog food after confirming the presence of the euthanasia agent pentobarbital in both products.

Following discussions with FDA, Evanger’s announced a voluntary recall on February 3, 2017 of five lots of its 12-ounce Hunk of Beef canned dog food, all with an expiration date of June 2020: 1816E03HB, 1816E04HB, 1816E06HB, 1816E07HB, and 1816E13HB. On February 9th, Against the Grain voluntarily recalled lot #2415E01ATB12 BEST DEC 2019 of its Grain Free Pulled Beef with Gravy dog food after the agency detected pentobarbital that product. The Pulled Beef with Gravy was manufactured in the same facilities as Evanger’s products and using beef from the same supplier.

In addition to the presence of pentobarbital, FDA reports a bill of lading from Evanger’s supplier of ‘Inedible Hand Deboned Beef – For Pet Food Use Only. Not Fit for Human Consumption’. This is despite Evanger’s claim that the beef in its Hunk of Beef product came from a ‘USDA approved’ supplier. FDA also has determined that the supplier’s facility does NOT have a grant of inspection from USDA’s Food Safety and Inspection Service. The meat from the supplier does not bear a USDA inspection mark and would not be considered human grade. Lab testing by USDA-FSIS of Evanger’s Hunk of Beef confirmed that the meat in the product was beef.

Other issues cited in a preliminary investigation report (FDA Form 483) released today by FDA include evidence of unsanitary conditions, inadequate refrigeration, improper storage, and inadequate control of ambient temperature during hand-packing operations at Evanger’s Wheeling, IL facility and unsanitary conditions and ‘avian activity’ at its Markham, IL manufacturing location.

FDA’s investigation is ongoing and will include examination of the suppliers of beef to Evanger’s and Against the Grain to determine the source of the pentobarbital. The agency is also coordinating with USDA to address possible areas of shared jurisdiction.

Consumers with cans of the recalled product should refer to the Evanger’s and Against the Grain recall notices for information on returning the product.

This article first appeared on Food Safety News and is reposted here with permission.

Another Pentobarbital-related Pet Food Recall

Late this afternoon, Against the Grain Pet Food voluntarily recalled one lot of Against the Grain Pulled Beef with Gravy Dinner for Dogs (12 oz. cans; Lot #2415E01ATB12; Expiration date of December 2019) due to the potential presence of pentobarbital. The recalled dog food was manufactured and distributed in 2015 to independent pet retail stores in Washington and Maryland.

Who is Against the Grain Pet Food?

The company website makes the following claim:

Unlike 95% of other brands, Against the Grain owns its own manufacturing facility and produces its own products. This gives us accessibility and the ability to create totally unique and innovative products. Our manufacturing plant adheres to the highest standards of preserving our natural resources. For example, the use of natural light (skylights) is dominant throughout our plant, we have the maximum amount of recyclable materials in our retail packaging, all packaging materials are recycled, our water is supplied by our own on-site well, resulting in our conscious efforts to be socially and economically responsible.

In fact, Against the Grain Pet Food is part and parcel of the Sher family business. The telephone number provided on the Against the Grain Pet Food Contact page is 847-537-0102, the same phone number that appears in the February 3rd Evanger’s recall notice. The Against the Grain trademark (serial number 85569018) was registered on 2013-02-12 and is owned by Chelsea L. Sher. And, according to an article in the August 2012 issue of Pet Business, the Against the Grain product line, launched by Chelsea Sher and her twin brother Brett Sher, is manufactured at the Evanger’s factory. In effect, Against the Grain is an Evanger’s brand.

So, what’s the big deal?

The big deal is that the product recalled on February 3rd by Evanger’s was manufactured in June 2016 (with a June 2020 expiry date). The Against the Grain product recalled earlier today was manufactured six months earlier, in December 2015 (with a December 2019 expiry date). This is not a one-shot event.

The Against the Grain recall notice states that the recall was initiated “Out of an abundance of caution.” What does this mean? Now, we enter the realm of speculation – something I am not usually willing to do. This time, though, I’ll make an exception. There are four possibilities that come to mind.

Possibility #1: The same shipment of beef was used to manufacture both recalled products.

This strikes me as highly unlikely. First of all, the February 3rd recall was for ‘Hunks of Beef’, while today’s was for ‘Pulled Beef’ – two entirely different formats. Secondly, if the same shipment was used in both products, the ‘Hunks of Beef’ product would have been manufactured with 6-month old beef. Possible, of course, but not highly probably, unless the company stores its raw meat in the deep freeze for months at a time.

Possibility #2: Beef from the same supplier was used to manufacture both recalled products, and the manufacturer is just being super-cautious.

Evanger’s February 3rd update, posted on the company website, states:

We feel that we have been let down by our supplier, and in reference to the possible presence of pentobarbital, we have let down our customers. Despite having a relationship for forty years with the supplier of this specific beef, who also services many other pet food companies, we have terminated our relationship with them and will no longer purchase their beef for use in our Hunk of Beef product. As Hunk of Beef is a very unique product, requiring very specific cuts of meat, this supplier’s meat was used in no other products.

If this is accurate, then the Against the Grain product should not contain meat from this supplier at all. Again, this explanation does not make sense.

Possibility #3: Either the company or FDA arranged for lab testing of a number of Evanger’s products and detected pentobarbital in a sample of the Against the Grain product.

Based on my years of off-and-on contact with the food industry and regulatory bodies, I am confident that FDA is testing extensively for pentobarbital in samples of Evanger’s products. We won’t know what, if anything, they find until their investigation is complete and they release their results. However, a positive finding of pentobarbital would certainly trigger an immediate recall.

Possibility #4: Either the company or FDA has found evidence that meat from an unauthorized source was introduced into the company’s products.

This, too, would be sufficient to trigger a recall “Out of an abundance of caution.” Again, we won’t know whether or not this took place until FDA completes its investigation.

The good news for pet owners is that, so far at least, this problem appears to be confined to products manufactured at Evanger’s Wheeling, IL facility. Let’s hope it stays that way.

Evanger’s “Muddy” Duck Story

In the latest twist to the duck tale, Susan Thixton, writing in Truth About Pet Food, reports the following clarification from Genetic ID, the third-party lab that tested Evanger’s Duck dog food:

“Genetic ID NA, Inc., the lab used by Evangers Pet Food, confirms the food tested was Grain Free Duck pet food – appearing to be the same food tested by the FDA.”

Susan adds that, as yet, she has been unable to obtain confirmation from FDA that the lot number of the Duck dog food tested by the agency matches the lot number tested by Genetic ID. Evanger claims that both FDA and Genetic ID tested samples from the same production lot of Grain Free Duck pet food.

Evanger’s web site contains the following update to their initial comments on FDA’s Warning Letter:

It has come to our attention that we used the term, “Super Premium Duck” in our response referencing the product that was tested. The product that was tested by both FDA and Evanger’s was “Grain Free Duck” in a 6 oz can, Lot #2401E02DK2. The term “Super Premium” refers to the Evanger’s line of food that the Grain Free Duck is categorized in. Again, both references refer to Evanger’s brand 6 oz duck can Lot #2401E02DK2.

For anyone who is curious about the lot numbering system used by Evanger, “24” refers to December; the third digit (in this case, “0”) represents the last digit of the year of production, meaning that the product in dispute was manufactured in December 2010 – just as Evanger indicated. “DK” – of course – identifies the product as duck. I have been unable to verify the meaning of the remainder of the lot code; I’m still waiting for an answer from Brett Sher on that. I suspect that the day of the month is identified by the pair of digits that follow the letter E.

Assuming that FDA and Genetic ID ran their analyses on samples from the identical batch, we are still left with a significant mystery; namely, how can two supposedly competent labs arrive at diametrically opposite test results using similar analytical methods on two samples from the same production batch?

Also, if FDA didn’t find any duck in the Grain-Free Duck product, what type of meat did they find instead?

I have been in touch with FDA’s Center for Veterinary Medicine, and I am hoping for an answer to these questions in fairly short order. Please stay tuned.