This story by Phyllis Entis first appeared in Food Safety News and is reposted here with permission

On February 7, 2019, in a move announced only via email to its direct customers, Arrow Reliance, doing business as Darwin’s Natural Pet Products (Darwin’s), recalled 11.7 tons of raw dog food.

The recall was first divulged to the public on March 26, 2019, by the US Food and Drug Administration (FDA) via a news release cautioning pet owners to avoid feeding the recalled products.

According to the FDA Enforcement Report issued on April 3, 2019, the recall encompassed:

•  Natural Selections Turkey and Vegetable Meals for Dogs, frozen, raw dog meals, packaged in 2 lbs. thermo-formed sealed plastic package, divided into 8 oz. portions. Lot #5339, manufactured on 10/26/18 (listed as 5339(11)181026 on the label)
• Natural Selections Chicken and Vegetable Meals for Dogs, frozen, raw dog meals, packaged in 2 lbs. thermo-formed sealed plastic package, divided into 8 oz. portions. Lot # 5309, manufactured on 10/19/18 (listed as 5309(11)181019 on the label)
• •Natural Selections Chicken and Vegetable Meals for Dogs, frozen, raw dog meals, packaged in 2 lbs. thermo-formed sealed plastic package, divided into 8 oz. portions. Lot # 5375, manufactured on 11/6/18 (listed as 5375(11)181106 on the label)

Although Darwin’s claimed to have notified all of its affected customers via email of the Salmonella contamination, Food Safety News has learned that at least one customer did not receive the initial notification.

When FDA is concerned as to the effectiveness of a company’s recall action, the agency has the authority to request distribution information in order to audit the recall, as detailed within the agency’s Investigations Operations Manual.

According to a Product Information Update posted on the company’s website on March 27, 2019, Darwin’s declined to furnish distribution information to FDA, citing their customers’ right to privacy.

Darwin’s ships its products directly to end users, and does not use third-party distributors, wholesalers or retailers.

In its March 27th update, Darwin’s further claimed that FDA’s March 26th news release was in retaliation for the company’s refusal to share customer contact information.

When asked to respond to this allegation, an FDA spokesperson told Food Safety News, “The FDA’s first priority is to protect public health. In accordance with this mission, we want to ensure that anyone who may have purchased or used violative product is informed of the issue and the health risk, so that they can take appropriate steps to protect themselves and their pets. In the absence of an adequate public notification by the firm, or confirmation from the firm that it has promptly and effectively communicated the recall to all customers, the agency may issue its own public notification.”

Commenting on Darwin’s characterization of the company’s message to its customers as a warning, not a recall, the spokesperson added, “The FDA considers the actions taken by Arrow Reliance to remove the violative product from the marketplace to meet the regulatory definition of a recall.”

Finally, Darwin’s reiterated a past claim that Salmonella is not a concern for healthy animals, citing “information from experts” on FDA’s website.

The citation in question was a research article that concluded, in part, “This study suggests an overall decline in the prevalence of Salmonella-positive dogs and cats over the last decades and identifies consumption of raw food as a major risk factor for Salmonella infection.” (emphasis added).

The same study determined that almost half of the Salmonella-positive animals did not suffer from diarrhea.

Salmonella-infected animals are still capable of passing the bacteria in stool and infecting their human companions or other animals.

Salmonella-contaminated pet foods have caused illness in both pets and humans in the past. Most recently, a raw turkey meat pet food was linked to cases of Salmonella illness that were part of a nationwide outbreak of multidrug-resistant Salmonella Reading infections.

FDA recommendations to consumers

•  If you have Darwin’s Natural Pet Products Natural Selections Chicken Recipe with Organic Vegetables for Dogs (5309(11)181019 and 5375(11)181106) or Darwin’s Natural Pet Products Natural Selections Turkey Recipe with Organic Vegetables for Dogs (5339(11)181026), stop feeding it to your pets and throw it away in a secure container where other animals, including wildlife, cannot access it.
• Consumers who have had this product in their homes should clean refrigerators/freezers where the product was stored and clean and disinfect all bowls, utensils, food prep surfaces, pet bedding, toys, floors, and any other surfaces that the food or pet may have had contact with. Clean up the pet’s feces in yards or parks where people or other animals may become exposed. Consumers should thoroughly wash their hands after handling the recalled product or cleaning up potentially contaminated items and surfaces.
• People who think their pets have become ill after consuming contaminated pet food should first contact their veterinarians. Veterinarians who wish to have pets tested for Salmonella may do so through the Vet-LIRN Network if the pet is from a household with a person infected with Salmonella.
• The FDA encourages consumers to report complaints about pet food products electronically through the Safety Reporting Portal or by calling their state’s FDA Consumer Complaint Coordinators.

Incident timeline

•  December 27, 2018, FDA received a pet illness complaint from a consumer, citing Darwin’s product. FDA obtained three intact packages of Darwin’s raw dog food from the consumer and found Salmonella in all three.
• On or about the week of January 28, 2019, FDA notified Darwin’s of their findings and recommended a voluntary recall. Darwin’s notified by email those customers who had received product from one or more of the contaminated lots but declined to issue a public recall notice.
• February 7, 2019, Darwin’s posted a Product Information Update on their website, acknowledging the incident.
• March 26, 2019, FDA issued a caution to pet owners, informing the public of Darwin’s Salmonella contamination.
• March 27, 2019, Darwin’s issued a second Product Information Update, rebutting FDA’s public statement.