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Reporting Pet Food-Borne Illness

David A. Dzanis, DVM, PhD, Diplomate ACVN, Regulatory Discretion, Inc, Santa Clarita, California

Nutrition

|February 2011|Peer Reviewed

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The expert says…

Veterinarians play a key role in detecting and reporting pet food–borne illness. Compared with other sources of poisoning in dogs and cats, foods rank well below drugs, insecticides, plants, rodenticides, and cleaning products in terms of frequency of occurrence.1 However, pet food adulteration (eg, contamination, nutrient deficiency, or other cause of a health problem) does occur.

The most notable example is the unprecedented recall of pet foods contaminated with melamine and related compounds under many different brand and company names in 2007. Although the actual number of products affected constituted less than 1% of the products on the market, the incident revealed significant deficiencies in the safety reporting process.

Government & Industry Responsibilities
The U.S. Food and Drug Administration (FDA) has jurisdiction over all pet foods in interstate commerce. Most states also regulate pet foods distributed within their respective borders.

After hearings held by the U.S. Congress on the melamine contamination incident, the Food and Drug Administration Amendments Act (FDAAA) was signed into law in 2007. Only a small portion of the Act pertains to pet foods per se, but it has had a dramatic impact on both the government and industry.2

Much of the law puts the burden on the FDA to improve its functions covering pet food safety. At the time of the melamine contamination, the FDA did have an adverse event reporting system for animal drugs, but no formal system in place for pet foods. The law mandates:

  • Implementation of an early warning and detection program
  • Improved coordination with the states
  • Better communication with industry and the public

A key requirement under the FDAAA was to establish a Reportable Food Registry, which became active in 2009.3 With some exceptions, within 24 hours of discovery, pet food companies now must electronically report any incident of adulteration when there is reasonable probability of serious adverse consequences to human or animal health. The Reportable Food Registry system is designed to receive reports only from industry and regulatory officials, not veterinarians or the public at large. However, there are other means by which consumers and other parties may report pet food problems to the FDA.

See Table 1. Helpful Information for Reporting Pet Food Complaints

The Veterinarian’s Role
Timely reporting of suspected pet food–borne illness by veterinarians may help curtail a larger outbreak.

Differential Diagnosis
It is not uncommon for pet owners to implicate pet food as the cause of an acute onset of illness. However, because signs of a pet food–borne illness are usually nonspecific, it is prudent to diligently rule out other potential causes of sudden illness. Adverse effects stemming from food adulteration must remain on the differential diagnosis list until that possibility is ruled out or the definitive cause is determined.

Dietary History
Before filing a complaint, a veterinarian who suspects a case of pet food–borne illness needs to collect as much information related to the food in question as feasible (Table 1). In fact, a record of the dietary history of a sick animal is always prudent and may become important if a pattern emerges or a recall is later announced. Pertinent information includes details about the food and its labeling, as well as clinical observations of the animal.

Laboratory Analysis of Food
Collection of food samples for laboratory analysis is often indicated. Proper handling of the sample as legal evidence is important for diagnostic and forensic purposes and may be critical if a subsequent lawsuit or regulatory action is possible.1 Clinical findings should be thoroughly described to the testing facility, along with the likely contaminants or nutrient deficiencies in order to direct the types of analyses conducted.

Table 2. Reporting Suspected or Confirmed Pet Food Adulteration

Agency or Company Contact Information
U.S. Food and Drug AdministrationSafety reporting portal:*
 https://www.safetyreporting.hhs.gov/fpsr/WorkflowLoginIO.aspx?metinstance=9F35D1212952C1BDF187FD112B40A6F9DFD34150
 Alternate contact methods;
 

District office consumer complaint coordinator:

 www.fda.gov/Safety/ReportaProblem/ConsumerComplaintCoordinators/default.htm
 

Local telephone directory "blue pages" (for government agencies)

Pet food company

Toll-free telephone number on product label
 Alternate contact method; Company website
State feed control officialAssociation of American Feed Control Officials state directory:
 www.aafco.org/Directory/MembershipDirectory/tabid/62/Default.aspx
 Alternate contact method;
 Local telephone directory “blue pages” (for government agencies)
 * In addition to the link provided, the portal may be accessed by going to the FDA Center for Veterinary Medicine’s home page (www.fda.gov/cvm), clicking on the link How to Report a Pet Food Complaint, and then selecting Safety Reporting Portal.

Reporting Potential Adulteration
To facilitate receipt of complaints from consumers and veterinarians about pet foods, the FDA has instituted an electronic reporting portal (Table 2). This portal is separate from the veterinary reporting mechanisms that the FDA established for animal drugs and devices, as well as from the reporting systems for vaccines and pesticides as set up by other agencies.

Contacting Pet Food Manufacturer
The pet food manufacturer or distributor should be contacted promptly any time a food is suspected to be adulterated. The company may be able to recognize an emerging pattern if it receives multiple complaints about a product.

Such notification should be done in addition to, not in lieu of, direct reporting to the FDA—even though reports of serious problems to the company should prompt the company to investigate the problem and possibly report it to the FDA using the agency’s Reportable Food Registry. Especially in the case of locally made products, notifying the state feed control official (usually found in the state department of agriculture) is also prudent.

Client Education
Veterinarians can also help disseminate information to clients by downloading the FDA’s Pet Health & Safety Widget (fda.gov/AnimalVeterinary/Resources
forYou/ucm192894.htm
). The application appears on the veterinarian’s website and automatically sends updated alerts on pet food recalls and other safety information.


REPORTING PET FOOD–BORNE ILLNESS • David A. Dzanis

References
1. Food safety. Miller EP, Ahle NW, DeBey MC. In Hand MS, Thatcher CD, Remillard RL, et al (eds): Small Animal Clinical Nutrition, 5th ed—Topeka, KS: Mark Morris Institute, 2010, pp 225-249.
2. New U.S. federal law to affect petfoods. Dzanis DA. Petfood Industry 49:36-37, 2007.
3. Reportable Food Registry and its impact on petfood. Dzanis DA. Petfood Industry 51:50-51, 2009.

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