It’s Publication Day!

Calling All Pets
(and Pet Parents, Too)

Five years after the idea for a book on the pet food industry first took hold of me during a walk on Carmel Beach, I am proud to announce the official launch of TOXIC. From Factory to Food Bowl, Pet Food Is a Risky Business.

If you share your life with a companion animal—especially a dog or cat—you owe it to your pet to educate yourself about the practices that take place behind the scenes in the factories and kitchens where raw, canned, and kibbled pet foods are manufactured.

The reality behind the appetizing package labels and enticing website advertising may shock you. It will certainly disillusion you, as it did me.

The stories and investigations described in TOXIC are drawn from interviews with pet owners, public records, published articles, and FDA inspection reports.

FULL DISCLOSURE: My husband and I are very fortunate to share our home with our 7½ year old Australian Cobberdog, Rutlands Shalom. She thrives on a home-cooked diet that I prepare for her myself.

Word On the Street

As part of the run-up to the publication of TOXIC, I supplied Advance Review copies to a number of colleagues in the writing community. Several of these individuals have already posted their reviews, and I am proud to share a few of their comments here. If you wish to read a complete review, please click on the reviewer’s name or handle.

“As the former global pathogen product manager at a major testing manufacturer, I found this book a fantastic companion to Tainted by Phyllis Entis.” – George Nagle (Amazon USA reviewer)

“TOXIC provides an eye-opening look at the pet food industry’s failures.” – Amy M. Reade (Amazon USA reviewer)

“Well, wow! As with Entis’s first book, TAINTED, this new installment is frighteningly eye opening.” – PeaceLoveHope (an Amazon USA Vine Voice reviewer)

“My thanks to the author for this meticulous insight – would that it weren’t necessary to hold those responsible constantly to account, but it is … and this book does that with aplomb.” – MeandtheMutts (Amazon UK reviewer)

A Peek Inside the Book

If you have read this far, please let me entice you further with a short excerpt from Chapter 9: Pentobarbital’s Pervasive Presence. I interviewed Mark Johnson via email for this story.

Mark was a California cattleman and his dogs were his workforce. He maintained a string of Border Collies and Australian Shepherd mixes to help with herding. Mark first purchased Gravy Train canned dog foods in 2015, using the products as supplemental feedings and as rewards for his dogs. In January 2018, when disaster struck, Mark owned thirteen dogs, ranging from ten months to approximately seven years old. One of his six female dogs was pregnant.

Typically, Mark purchased five cases of dog food weekly, patronizing the local Walmart and Big Lots stores for his supplies. In early January 2018, he replenished his supply of canned food with a purchase of two Gravy Train varieties: Chunks in Gravy with Beef Chunks, and Chunks in Gravy with T-Bone Flavor Chunks. On or about January 12^th, all thirteen dogs fell sick within hours after eating the Gravy Train dog food. He took all of the dogs to his local veterinarian. Within two days of having consumed the dog food, all thirteen dogs were showing signs of kidney failure and were euthanized at the veterinarian’s recommendation.

Although the veterinarian performed a necropsy on one of the dogs, neither he nor Mark reported the dog deaths to the FDA. According to Mark, the veterinarian died shortly after the incident, and Mark was unable to retrieve his files. As of November 2018, Mark was still searching for replacement herding dogs that were in need of a good home.

How To Order TOXIC

TOXIC. From Factory to Food Bowl, Pet Food Is a Risky Business is available in digital format from all major ebook retailers, and can be purchased in paperback on Amazon.

Alternatively, you can have your favorite bookstore order a copy of TOXIC for you.

If you prefer to borrow your reading material from a local library, please consider asking your librarian to add TOXIC to the library’s collection.

It is time to rebuild the US food safety system

Several weeks ago, food safety advocate Bill Marler launched his campaign to “Get the ‘F’ out of the FDA.”

Marler proposed that Congress split the Food and Drug Administration into two separate agencies—one with responsibility for food safety and human nutrition, and the other for drugs, cosmetics and medical devices.

While I agree with the need for a separate agency to oversee food safety and human nutrition, I believe Marler’s proposal does not go far enough.

It is time to consolidate all food safety activities at the federal level under a single umbrella.

Here’s why.

Split jurisdiction

At present, responsibility for overseeing food safety is split between two main federal agencies: the FDA and the Food Safety and Inspection Service (FSIS) of the US Department of Agriculture (USDA).

The USDA is responsible for the safety of meat and poultry, catfish, and egg products.

The FDA is responsible for the safety of all food products that do not contain meat or poultry, for intact eggs, and for all fish other than catfish.

This division of responsibility by commodity has led to some strange and confusing situations.

canned foods containing meat or poultry come under FSIS jurisdiction, while all other canned foods are FDA-regulated.
pizzas containing more than 2% meat are the responsibility of FSIS; less than 2% meat, and the FDA takes over.
open-faced sandwiches containing meat are overseed by FSIS; closed sandwiches are the responsibility of the FDA, whether or not meat is present.

These arbitrary distinctions mean that many food processing plants must answer to two separate federal agencies.

Conflict of interest

The USDA operates under a double mandate.

On the one hand, it is responsible for certifying that the food products under its jurisdiction are safe for human consumption.

On the other hand, the USDA also is charged with promoting US agricultural products both domestically and to overseas markets.

This is akin to having the quality assurance department of a food company report to the head of the marketing department.

We have seen the consequences of this conflict most recently in the FSIS draft proposal to allow as much as one Salmonella per gram of chicken in raw, breaded stuffed chicken products.

An immodest proposal

It is time to demolish the current ineffective, wasteful, and conflicted system and build a new one, centered on a new Food Safety and Nutrition Agency (FSNA) with a seat at the Cabinet table.

The FSNA would take over all of the food safety and nutrition program activities currently performed by the FDA. In addition, all responsibility for meat, poultry, egg products and catfish would fall under the FSNA umbrella.

The USDA would retain responsiblity for certifying the fitness of livestock for slaughter and certifying the fitness of their meat for human consumption.

At the moment meat or poultry leaves the slaughterhouse, jurisdiction would shift to the FSNA.

This approach would have the benefit of eliminating the conflict of interest inherent in the USDA’s double mandate. It would also unscramble the arbitrary and confusing overlap of jurisdictions between the FDA and the FSIS.

The consolidation of all food safety responsibilities within a single, independent agency is not a new idea.

The Canadian Food Inspection Agency (CFIA) was created in 1997 by consolidating into a single agency the food safety components of the Health Protection Branch (then the Canadian equivalent to the FDA), the Department of Agriculture, and the Department of Fisheries and Oceans.

Other countries, including the United Kingdom, Australia, and New Zealand have followed a similar path.

The bottom line

Congress created the current dysfunctional structure over a span of many decades.

Therefore, it is up to Congress to deconstruct this broken system and build a new one that will work to the benefit of the public it has been elected to represent.

TAINTED formats 3 — “Reads like a true crime novel” – Food Safety News

Interested in learning more about food safety and the history of foodborne disease outbreaks and investigations?

Click on the link to listen to a short excerpt, then follow the buy links to add a digital, print or audio copy to your personal library.

Chapter 6. Birth of a Pathogen

TAINTED is available in digital format from all major on-line retailers. Press the button to go directly to your preferred digital bookstore.

Amazon

Apple

Barnes & Noble

Kobo

Smashwords

Chapters/Indigo

Sunday Supplement: Proposed new FDA food structure leaves pet food out to dry

IN MY OPINION

The proposed new US Food and Drug Administration (FDA) organization structure leaves the Center for Veterinary Medicine (CVM) sucking on a hind teat.

Never a major player in the FDA heirarchy, the CVM has been formally excluded from the Human Foods Program, with only a dotted line connecting it to the Office of the Deputy Commissioner.

Although the CVM will report directly to the Office of the Commissioner of Food and Drugs, its relatively small budget and political profile will leave this essential element of food safety and nutrition with little voice or influence at the table.

Why does this matter?

The CVM is responsible for oversight of animal feed, pet foods and veterinary medicines.

If animal feeds are not properly regulated and supervised, animal nutrition–and ultimately human nutrition–suffers.

If veterinary medicines are not properly regulated and supervised, the health of livestock and the safety of the human diet suffers.

If pet foods are not properly regulated and supervised, the health of companion animals suffers.

Pet health matters

Pets play an important role in the mental and physical health of their human companions.

Those of us who have lost a dog, cat, or other pet to illness, accidents, or simply old age, understand the grief that this loss entails.

In addition, if an animal develops a gastrointestinal illness such as salmonellosis as a result of contaminated pet food, this illness can be passed along to people in the same household.

This is not speculation.

Kibble, raw pet foods, and pet treats contaminated with Salmonella have caused several outbreaks of human illness large enough to attract the attention of the US Centers for Disease Control and Prevention (CDC).

Without a strong voice at the budget table, the CVM will not have the resources to oversee the pet food industry.

We have seen what has happened in the past when a pet food manufacturer has been allowed to operate on a “voluntary compliance” basis. More often than is healthy, the emphasis is on voluntary, and compliance falls by the wayside.

Can this be fixed?

I realize that the CVM has elements both of food and of pharmaceuticals in its regulatory portfolio.

Nevertheless, every component of the CVM’s mandate–animal feed, animal medications, pet food–indirectly supports the safety and nutriton of human or animal food.

I would propose that the scope of the proposed new directorate be expanded to include the CVM, and that the word “Human” be dropped from the title of the new Deputy Commissioner.