It’s tough to find a contaminant when you don’t know what you’re looking for. But that doesn’t mean FDA isn’t trying hard to figure out why chicken jerky pet treats from China seem to be making so many dogs seriously ill.

Since the beginning of 2011, FDA has received a total of 537 reports from dog owners and veterinarians of dogs that fell ill after being fed these popular dog treats. Several days ago, I asked Laura Alvey of FDA what the agency was doing to solve the mystery, and received this reply:

“Testing continues and is ongoing. We have tested samples from all over the country.

Since so many of the reports received involved vomiting and diarrhea, we were looking for microbial pathogens. We have tested for salmonella and none have come back positive. We have been testing for chemical toxicants, including melamine, melamine analogs and diethylene glycol (DEG) and none have come back positive.

Unless we detect a contaminant and have evidence a product is adulterated, we are limited in what regulatory actions we can take. The regulations don’t allow for products to be removed based on complaints. We will continue to monitor.

We have reached out to relevant competent authorities in other countries to request intelligence on increased reports of illness in dogs associated with consumption of chicken jerky treats, any investigations conducted, analyses conducted on suspect product, etc. We have received some feedback regarding our questions and some suggested collaboration/sharing of information.“

I asked the same question of the Canadian Food Inspection Agency (CFIA), and had a very different – and far less comforting – reply from Dr. Carl Rudat, a Veterinary Program Specialist with CFIA.

“The CFIA,” Rudat said, “does not have a process that records calls about chicken jerky treats. The CFIA has not conducted analyses of these products. Pet food and pet treats are unregulated commodities in Canada. However, due diligence is being done and Chinese pet treat facilities have been inspected by CFIA veterinarians. I hope you find this information useful.”

So, Canada is NOT recording or tallying illness reports on chicken jerky treats, is NOT testing chicken jerky treats, and does NOT regulate pet food and pet treats. But have no fear, because “due diligence is being done.”

I pursued the issue further. “Was CFIA in communication with FDA on this issue?” I asked.

“CFIA is aware that the FDA is testing chicken jerky originating from China,” was his reply. “To date, nothing definitive has been determined.”

If CFIA does not regulate pet food and pet treats, what was the regulatory authority for CFIA’s policy entitled Import of Pet Food, Treats and Chews Containing Animal Products and By-Products? Why the heck was CFIA inspecting Chinese pet treat facilities? And what was meant by the reassurance that “due diligence is being done?”

I posed these questions (politely, of course), and was told that the legal framework for CFIA’s Import of Pet Food, etc. policy is the Health of Animals Act and Regulations. Animal by-products are regulated under this Act, and “…most pet food begins as an animal by-product.” Dr. Rudat added that CFIA has the authority to prevent “diseases of concern” from entering Canada. He did not elaborate on his “due diligence” statement.

Sounds to me as though pet food is regulated when CFIA finds it convenient, but not otherwise.

The situation on the US side of the world’s longest undefended border is quite different. FDA has taken a lead role in trying to find the source of the chicken jerky problem, and is continuing to pursue the issue assiduously. Unfortunately, as FDA Spokeswoman Laura Alvey reminded me, the agency cannot take regulatory action unless a contaminant has been detected and there is evidence that a product is adulterated.

I expect that FDA eventually will find the answer to this mystery. Presumably, once FDA comes up with a solution for the problem, Canada will gladly accept the fruits of a free ride.

Since January 1st, 2012, FDA has received 184 reports of pets who became ill after being fed chicken jerky dog treats. That’s on top of the 353 reports lodged with the federal agency in calendar year 2011, according to information provided  to eFoodAlert by FDA Spokesperson Laura Alvey.

Most of the 2011 reports – 283 of them – were filed after FDA issued an updated warning to dog owners on November 18th, 2011.

As I reported last November, FDA continues to warn pet owners that chicken jerky products imported from China may be associated with the development of Fanconi-like syndrome in dogs who eat the treats on a regular basis. Similar problems have been reported in Canada, according to the Canadian Veterinary Medicine Association.

Unfortunately, neither FDA nor the Canadians have been able to identify an ingredient or contaminant in the chicken jerky dog treats that would account for the illnesses. “Testing is ongoing,” Alvey reported to me yesterday by email. “We have tested samples from all over the country for microbial pathogens (salmonella) and chemical toxicants and so far, nothing has come back positive,” she added.

FDA is encouraging consumers to submit illness-linked samples of pet treats to them for analysis. “[w]e would most certainly want to try to obtain a sample of a consumer’s pet product if they still had it and they were reporting it in association with a pet illness to the FDA,” Alvey stated.

Unfortunately, unless and until FDA can determine the presence of an adulterant (microbiological or chemical) in the pet treats, the agency is unable to request a recall. As always, suspects – including pet treats – are innocent until proven guilty.

Mollie Morrissette has been following this story closely, and has written several informative articles, which can be found on her Poisoned Pets blog site.

FDA is warning pet owners that chicken jerky products imported from China may be associated with the development of Fanconi-like syndrome in dogs who have been fed the treats on a regular basis.

In the last 12 months, FDA’s Center for Veterinary Medicine has logged an increase in the number of complaints filed by dog owners and veterinarians.

FDA first reported a potential association between the development of illness in dogs and the consumption of chicken jerky products – also described as chicken tenders, strips or treats – in September 2007. The first illnesses were noted in 2006 (6 reports). The number of illness reports peaked in 2007 (156 reports), according to FDA Spokeswoman Laura Alvey, dipped to 41 incidents in 2008, and have fluctuated ever since.

In June 2011, the Canadian Veterinary Medicine Association (CVMA) notified CVMA members by email that several veterinarians in Canada had reported dogs with Fanconi-like symptoms that could be associated with the consumption of chicken jerky treats manufactured in China. The email included the following warning:

Recently, several veterinarians in Ontario have reported cases of dogs that have been showing signs similar to Fanconi syndrome. All dogs in the reported cases had been fed chicken jerky treats that were manufactured in China.

Signs of Fanconi syndrome can include decreased appetite, decreased activity, vomiting, and increased water consumption and/or increased urination. Blood tests may show increased urea nitrogen and creatinine. Urine tests may indicate Fanconi syndrome (increased glucose). The problem is that this can be confused with diabetes.

The CVMA also notified the American Veterinary Medicine Association (AVMA), which transmitted the advisory to US veterinarians. At the time of the notification (June 17, 2011), AVMA had not received any reports from its members of similar incidents of Fanconi-like syndrome associated with chicken jerky treats.

That situation has changed.

FDA has received a total of 70 reports of Fanconi-like syndrome associated with chicken jerky treats from pet owners and veterinarians so far this year – up from 54 reports in all of 2010. “FDA,” Ms. Alvey reported to me by email, “is actively investigating the matter and conducting analysis for multiple different chemical and microbiological contaminants. We have tested numerous samples of chicken jerky products for possible contaminants including melamine. The complaints received have been on various chicken jerky products but to date we have not detected any contaminants and therefore have not issued a recall or implicated any products. We are continuing to test and will notify the public if we find evidence of any contaminants.”

There does not appear to be any rhyme or reason to the source or timing of the reports – there is no indication that the problem is clustered in a particular state or region – or to the monthly number of complaints, Alvey reported in response to my questions. She suggests that part of the upsurge may be due to increased awareness on the part of US veterinarians and pet owners as a result of the Canadian advisory.

Alvey emphasizes that “no causal link” has been established between the illnesses and the consumption of chicken jerky products. No one has yet been able to find any component in the chicken jerky treats that could account for the illnesses. Nevertheless, at least one recent report offers epidemiological evidence that regular consumption of chicken jerky treats may be behind the illnesses. Veterinarians Hooper and Roberts, writing in the Journal of the American Animal Hospital Association, described four illnesses in small-breed dogs. This is the Abstract of their published report (emphasis added):

Four small-breed dogs were diagnosed with acquired Fanconi syndrome. All dogs ate varying amounts of chicken jerky treats. All dogs were examined for similar clinical signs that included, but were not limited to, lethargy, vomiting, anorexia, diarrhea, and altered thirst and urination. The quantity of chicken jerky consumed could not be determined; however, based on the histories obtained, the chicken jerky treats were a significant part of the diet and were consumed daily by all dogs. Extensive diagnostic testing eliminated other causes of the observed clinical signs, such as urinary tract infection and rickettsial disease. Glucosuria in the face of euglycemia or hypoglycemia, aminoaciduria, and metabolic acidosis confirmed the diagnosis of Fanconi syndrome. All dogs received supportive care, including IV fluids, antibiotics, gastroprotectants, and oral nutritional supplements. Three dogs exhibited complete resolution of glucosuria, proteinuria, and the associated azotemia; however, one dog remained azotemic, resulting in a diagnosis of chronic kidney disease.

There have been two prior clusters of Fanconi-like syndrome in dogs. The 2007 cases were linked to melamine contamination of treats that were manufactured in China. And in 2009, a number of cases in Australia were linked to the consumption of chicken treats or dental chews made with corn, soy and rice.

FDA has published following information and advice for pet owners:

Chicken jerky products should not be substituted for a balanced diet and are intended to be fed occasionally in small quantities.

FDA is advising consumers who choose to feed their dogs chicken jerky products to watch their dogs closely for any or all of the following signs that may occur within hours to days of feeding the products: decreased appetite; decreased activity; vomiting; diarrhea, sometimes with blood; increased water consumption and/or increased urination. If the dog shows any of these signs, stop feeding the chicken jerky product. Owners should consult their veterinarian if signs are severe or persist for more than 24 hours. Blood tests may indicate kidney failure (increased urea nitrogen and creatinine). Urine tests may indicate Fanconi syndrome (increased glucose). Although most dogs appear to recover, some reports to the FDA have involved dogs that have died.

FDA, in addition to several animal health diagnostic laboratories in the U.S., is working to determine why these products are associated with illness in dogs. FDA’s Veterinary Laboratory Response Network (VLRN) is now available to support these animal health diagnostic laboratories. To date, scientists have not been able to determine a definitive cause for the reported illnesses. FDA continues extensive chemical and microbial testing but has not identified a contaminant. 

The FDA continues to actively investigate the problem and its origin. Many of the illnesses reported may be the result of causes other than eating chicken jerky. Veterinarians and consumers alike should report cases of animal illness associated with pet foods to the FDA Consumer Complaint Coordinator in their state or go to http://www.fda.gov/petfoodcomplaints.