We chatted recently with our local MA paper about pet food safety in light of another company's salmonella recall.  The newspaper article can be found here.  The full conversation follows.  

Recently three people were sickened by salmonella that was found in an Essex-county-made brand of dog treats. [That company's] products were pulled from store shelves and the Massachusetts Department of Public Health advised the public to stay away from their products as all three varieties (“chicken chips,” “beef liver,” and “sweet potato chips”) tested positive for the bacteria.

That small, Georgetown company joined the ranks of national brands: FreshPet, Natural Balance, Bravo, Earthborne Holistic, Sportsmix, Meow Mix, and others all who recalled pet products for salmonella in the last 12 months, according to the FDA.

In light of this news, we talked with another local pet food and treat maker to find out what might have gone wrong, and to learn how pet parents can make informed pet food choices that keep their human and furry family members safe.  

Goodness Gracious, a Marblehead, MA based pet food manufacturer which sells their products locally, is licensed and inspected to make human food. They just make their products for pets.  We learned that there can be a world of difference between “Human Grade” manufacturers and other pet food makers.  Our conversation with their CEO, Amy Renz, follows.

Q: Why is salmonella in pet food or treats such a risk.

A:  “While healthy canines usually have a GI tract that can process bacteria like salmonella without becoming acutely ill, salmonella represents a serious public health hazard, especially for the elderly, children, and immune-compromised.  In your home, it can spread on contact surfaces like from packaging to countertops to your fingertips, and it can ultimately infect you by contact with your mouth. 

Salmonella is frequently present on the raw chicken you buy in a grocery store, but home chefs understand this and follow basic food safety steps in their kitchens.  The expectation when you open a bag of ready to eat food – be it for you or your pet – is that the food has been processed in some way to destroy food borne bacteria.  So you don’t wash your hands after you feed that food to Fido. 

The risk of human infection with salmonella is why the FDA and Massachusetts Department of Public Health take such a hard stance on salmonella in pet food.  Their interest is not in protecting your pet from salmonella or really any other food hazard. ”

Q:  But doesn’t the FDA regulate and guard the safety of my dog’s food?

A:  “This is a loaded question, and frankly the truth of it is often unbelievable.

The FDA’s Food Drug and Cosmetic Act was written to protect the safety of all human and animal food equally.  The FDA, however, has written compliance policies and exercised enforcement discretion to the extent of allowing unslaughtered 4-D (dead, dying, diseased or disabled) animal tissues into pet and animal feed.  They also permit ingredients unfit for human consumption – because of contamination with filth, excreta, chemicals, toxins, or microbiological or foreign substances – to be used in feed for animals including pets.   These facts are indisputable.

The FDA has an ‘understanding’ with AAFCO.  AAFCO is a private association charged with writing animal feed regulations including those for pets.  These regulations are protected by copyright.  As a consumer, you have no legal right to read those regulations.  

Furthermore, to the best of my knowledge, of the 21 voting members on AAFCO’s 2021 pet food committee, only three people possess a degree in animal science.  Yet the job of this group is to set the nutritional and food safety standards for your pet. 

When you also consider that the $42 Billion US Pet Food market is dominated by just two companies – Mars Petcare and Nestlé Purina Petcare whose combined revenues equal $33.5 Billion – you may begin to speculate how much sway Big Industry could have in a privately-run association like AAFCO, your pet’s nutritional health and wellbeing, and the narrative around healthy pet food choices.  Mars makes money on our pets’ dietary-related woes to the tune of 25 million office visits annually across their multi-billion-dollar network of veterinary hospitals VCA, Banfield and Blue Pearl.

AAFCO regulations are interpreted and enforced at the discretion of each US state’s department of agriculture.  Most states require pet food makers to submit product labels to them to ascertain compliance with their labeling laws.  But let’s face it, there are thousands of pet food and treat products on the market.  Pet food makers and distributors are often on their honor to register their products with each state’s DoA.  And each state’s DoA is often understaffed and overwhelmed with regulating not only animal feed but fertilizer and other things.  These officials cannot regulate what they are unaware of.

All these things alarmed me several years ago when I was hunting for nutritionally sound food for my puppies.  They motivated me to start Goodness Gracious in 2009.  

Q:  So who is looking out for the safety of our pets’ food?

A:  The answer hinges on one question: are you feeding your pet Human Grade pet food or are you feeding ‘pet feed’? 

‘Human Grade’ pet food is intensely regulated.  This food uses only human-edible ingredients, and it is made in a licensed and inspected human food facility following the FDA’s current Good Manufacturing Practices.   Human Grade is the gold standard in pet food and the most meaningful thing you can find on a pet food or treat label.  

Goodness Gracious can legally call its products Human Grade.  We are a registered human food manufacturer.  We are licensed and inspected by the MA Department of Public Health.  Furthermore, we prove through extensive documentation to each US state in which we wholesale our products that every ingredient we use is safe for human consumption, and that our label complies with their state’s unique requirements.   With Human Grade pet food, regulatory authorities protect the safety of that food.

Every other pet food or treat brand that does not meet these requirements is regulated as animal feed.   If it is not Human Grade, then there is no regulatory difference between the safety and efficacy of what you feed your dog or cat, and what farmers feed their hogs or chickens or cattle. These pet food products should really be called ‘pet feed’.” 

Q:  How can a pet parent make safe and informed food choices for their dog or cat?

A:  “Websites are unregulated – they can say anything.  ‘Made with human grade ingredients’ or ‘made in an FDA-inspected facility’ is not enough.  The FDA inspects pet feed plants, so using this language could be a marketing gimmick.  Also, if you process those ‘human grade ingredients’ in an unsanitary pet feed facility, or with other inedible ingredients, the entire product becomes adulterated. 

The best thing to do is to read the product label looking for the words ‘Human Grade’.  In our experience, there is consistent enforcement of this regulation – assuming the pet food manufacturer has registered themselves with the state.  You can call the Massachusetts Department of Public Health to verify the manufacturer has a current license to make human food for distribution.  For manufacturers located outside of MA you would need to call their state’s public health department.

Another excellent resource for pet parents, is to follow the advocacy efforts of Susan Thixton on her website TruthAboutPetFood.com.”

Q:  How do you ensure Goodness Gracious chicken jerky is safe?

A:  “Historically, bacteria issues have affected many good companies.  For a manufacturer, ultimately it comes down to knowing where the critical food-safety control points are in your process; rigorously following cleanliness and sanitation procedures; implementing methods for killing food borne pathogens that may have inadvertently arrived in your manufacturing facility; and verifying that you’ve done your job effectively.  You also need an action plan should something bad happen.

As an example, when we make our single-ingredient Hula Lula chicken jerky for dogs we follow steps that use a combination of time, temperature, and humidity to destroy food borne pathogens.  When we make our complete and balanced gently cooked fresh food for dogs, we again use time and temperature to ensure food safety.  These steps are reviewed, proven, and accepted by the MA Department of Public Health. 

We have a recall plan, and forward and backward traceability on everything we make.  Lot numbers on every batch enable us to know exactly what ingredients went into that batch and where that product went – be it to a store, distributor, or an online customer. 

Having our address and website on our packaging, and an email and phone number on our website make us quickly accessible to everyone.  We love hearing from people.  And when their pets are singing our praises in the background, it’s music to our ears.”