By Dr. Becker
According to PetfoodIndustry.com, the FDA’s new Food Safety Modernization Act (FSMA) will require all food manufacturers (human food and pet food) to maintain a written Food Safety Plan that is FDA-approved. For producers of commercial raw pet food diets, this will mean implementing manufacturing processes designed to eliminate pathogens.
PetfoodIndustry.com wonders if the raw pet food industry is up to the challenge.
Killing Pathogens in Commercial Raw Pet Food
Companies that make raw food for pets primarily use two methods to insure the safety of their products. One method is to set up interventions all along the manufacturing process that are designed to reduce the risk of contamination. These include steps taken by both the companies’ raw material suppliers and in their own facilities to reduce the risk of bacterial contamination. These interventions only limit the risk of contamination – they don’t eliminate it.
The second technique involves a test and hold system. Samples of finished product are tested for harmful bacteria and if none is found, the batch is shipped to market. The problem with this method is that pathogens aren’t evenly distributed throughout food, so sampling may or may not pick up the presence of pathogens.
But one raw pet food company believes it has developed a process that, in combination with other technologies, meets all anticipated safety requirements.
Raw Pet Food Producer Patents State-of-the-Art Processing Method
Since 2007 Stella & Chewy’s, a raw pet food manufacturer, has been using high pressure processing (also called high pressure pasteurization, or HPP), to eliminate pathogen contamination in its raw products. According to PetfoodIndustry.com, the company is able to “maintain their raw character with the same effective kill of bacteria that you would find in a pasteurization technology.”
One of the challenges for pet food producers across the board is managing recontamination risk. Having kill steps in the manufacturing process doesn’t eliminate the risk of recontamination after production.
Stella & Chewy’s has met that challenge as well. Per PetfoodIndustry.com, the company:
"Employs a UV technology that creates antimicrobial conditions in addition to the germicidal properties of UV, so that operations like grinding, patty-making and even packaging can be done without any concern of environmental contamination because pathogens are systematically destroyed in the environment when this technology is operating."
This is a state-of-the-art food processing method that when combined with high-pressure processing delivers pathogen-free finished product. Stella & Chewy’s has patented the system.
Is High Pressure Pasteurization the Answer?
According to Marie Moody, president and founder of Stella & Chewy’s, HPP is an excellent solution to anticipated FDA oversight of raw pet food production via the Food Safety Modernization Act. Moody is concerned that some raw pet food companies are spreading misinformation about HPP that could ultimately hurt the entire raw pet food industry. She feels HPP is really the only option to meet new FSMA regulations, and when raw pet food producers market against it, “They're taking our only option and obliterating it."
Moody makes the point that compliance with FSMA regulations will not be optional, but mandatory – a fact that some raw pet food producers may not fully understand. She says:
“We really, I think as an industry, need to make sure that we are all in compliance with the Food Safety Modernization Act, because it's not only the manufacturers that are impacted, it's also the retailers. Because the retailers have put money behind educating people on the benefits of raw food diets, and we need to be a viable and sustainable industry."
According to Dr. James Marsden, professor of food safety and security at Kansas State University, the new FDA initiative will greatly improve the safety of food in the U.S. Marsden says that while raw pet diets pose special challenges, most, if not all of the processed (not raw) pet food recalls have been due to recontamination. So the entire pet food industry is looking not only at ways to eliminate pathogens during processing, but also at how to prevent recontamination of finished product before it is packaged.
Will the Raw Pet Food Industry Survive the Food Safety Modernization Act?
Will the raw pet food industry be able to meet the FDA’s new requirements?
According to Melinda Miller, president of the North American Raw Petfood Association (NARPA), its members are well positioned. They have Hazard Analysis and Critical Control Point (HACCP) plans in place, operate in facilities that produce human food, and use advanced pathogen treatment and testing methods along with test and hold distribution. Per Miller:
"NARPA companies already meet or exceed most of the [Food Safety Modernization Act] requirements, and, by using test and hold distribution for many years now, they have been operating at higher food safety levels than most of the companies producing dry/canned pet foods.”
Ms. Miller distinguishes between NARPA and non-NARPA companies, and makes the unfortunate accusation that non-members are “doing little to nothing in the way of food safety.” She warns that it will be one of these non-NARPA member that is “likely to be involved in some problematic, raw diet ‘event’.”
I’m not in agreement with Miller’s suggestion that any raw pet food producer who doesn’t belong to her organization isn’t interested in the safety of its products. I do certainly hope raw pet food manufacturers understand they must comply with the requirements of the new Food Safety Modernization Act, and I hope the growth of the raw pet food segment continues, as it offers pet parents healthy, species-appropriate alternatives to processed pet food.