The Truth Behind the Growing Raw Pet Food Recalls

commercial raw pet food

Story at-a-glance -

  • The FDA continues to turn up the heat on commercial raw pet food companies, and many are implementing additional methods to eliminate foodborne pathogens
  • One method is high pressure processing (HPP), which is a nonthermal preservation and pasteurization technique
  • HPP has one big drawback — many raw food advocates don’t believe food that has been high pressure processed is truly “raw”
  • Two other pathogen control methods used by raw pet food producers are bacteriophages, and fermentation
  • If you’re a raw feeder or considering feeding raw, rest assured that reputable raw pet food producers have been and continue to focus on providing safe, nutritious diets for pets

By Dr. Karen Shaw Becker

You may have noticed an increase recently in the number of raw pet food recalls for potential pathogen (typically salmonella) contamination. The amount of products recalled in each instance is typically insignificant, but it certainly appears that many raw pet food companies are receiving extra "attention" from the FDA.

FDA Is Turning Up the Heat on Commercial Raw Pet Food Producers

With the implementation of the Food Safety Modernization Act (FSMA) a few years ago, the FDA's role switched from reactive (removing tainted product from the market after reports of illness) to proactive, and they kicked things off by specifically targeting raw pet food producers.

In mid-2015, the agency — with its new zero tolerance policy on pathogens in hand — announced it would conduct large scale testing of raw diets (but not processed pet food) for E. coli, salmonella and listeria.1 Many viewed this move as clearly biased targeting of raw pet food companies, especially since historically, it is processed pet food that is routinely recalled for pathogen contamination.

The problem with the FDA's zero tolerance policy is that it's simply an unrealistic and impractical goal when you're dealing with raw meat intended for consumption by cats and dogs, who have evolved with a much higher tolerance than humans for foodborne pathogens (dogs and cats naturally harbor these strains of bacteria in their GI tracts).

In fact, the FDA doesn't even have a have a zero tolerance policy for USDA-inspected meats headed for supermarkets for human consumption (which are the same meats used for most raw pet foods). It's frustrating that the standards for raw pet foods exceed those of meat destined for human consumption.

However, in response to increased scrutiny by the FDA and the need for an FDA-approved Food Safety Plan per the FSMA, many raw pet food producers have begun investigating methods beyond the steps they were already taking to eliminate pathogens in their raw products.

Historically, companies that make raw food for pets have primarily used two methods to ensure 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.

High Pressure Processing Is Used by Some Raw Pet Food Companies to Control Pathogens

One of the newer methods several raw pet food producers have begun using is high pressure processing (HPP). Here's how Virginia Tech's Department of Food Science & Technology defines high pressure processing:2

It's a non-thermal preservation and pasteurization technique

Hydrostatic pressures between 100 and 1,000 MPa are applied to food products

HPP makes food safer and extends shelf life

HPP-treated food retains its original qualities and healthy attributes

Flavor-alternating additives or special processes are not needed

Meets consumer demand for freshness without the negativity associated with other methods like irradiation

HPP works by applying high hydrostatic pressure, which is pressure exerted by a liquid, through a water bath that surrounds the product. The pressure is uniformly applied from all sides and throughout the product, which keeps the food from being crushed.

According to HPP proponents, the process does not cause the foods to undergo significant chemical transformation, but does successfully eliminate all pathogenic microbes from the food, including bacteria such as listeria, salmonella and E. coli. High pressure pasteurization is USDA-approved, touted as being a 100 percent natural process and is allowed for use on organic and natural products in both the human and pet food markets.

Potential Issues With HPP

Many raw advocates believe HPP is a method of processing whole living food into a modification of whole living food, and that we shouldn't confuse truly unadulterated raw food with raw food that has been high pressure processed.

Depending on the amount of pressure used, research has demonstrated that proteins do denature, and beneficial bacteria are obliterated during HPP processing. There is also some concern about the risk of pets ingesting plastic contamination residues (phthalates) as a result of high pressure processing.

For these reasons, some raw feeders don't feel pet food companies selling HPP-treated diets should call them "raw," and question how safe the procedure is for the long-term health of pets, including the gut microbiome. Feeding sterile food to dogs and cats isn't natural, nor beneficial for supporting or maintaining a healthy microbial balance long term, in my opinion.

I've personally seen two unfortunate issues unfold with the increased use of HPP within the commercial raw food industry. First, many HPP advocates believe all raw foods on the market should be treated with HPP as a way of gaining acceptance by the traditional veterinary community and pet parents who want to feed raw, but need reassurance the food is initially bacteria-free and don't believe HPP is the only option for producing safe, raw pet foods.

Additionally, HPP has been found to be most effective in managing bacteria in pre-cooked foods. In fact, uncooked foods (raw) that have undergone HPP may have more potential bacterial proliferation once the container is opened than non-HPP'd foods. So it's possible HPP may actually increase the risk for growth of pathogenic bacteria, especially once the package is opened or in the event of manufacturing or packaging defects.

Number two, a certain percentage of the general public may assume the increased use of HPP is due to issues or problems stemming from unadulterated raw food diets, which is simply untrue. Most manufacturers of unadulterated (non-HPP) raw pet food use high-quality USDA-inspected meats.

They also test their products for proper nutrient levels and batch test for bacterial contaminants, which is why raw meat diets have substantially less potential for high loads of toxins and are historically not the subject of pet food recalls. In contrast, most mass-marketed dry foods, which are regulated by the FDA, not the USDA, use rendered and 4-D meats (meats from dead, dying, disabled and diseased animals).

Because commercially available raw food diets are grain-free and therefore free of mycotoxins, because raw pet food companies use high-quality meats sourced from healthy animals and because they focus on responsible food processing, there's actually a much lower risk of recalls involving unadulterated raw food than there is with commercial kibble.

Other Pathogen Killing Methods Used by Raw Pet Food Producers

Bacteriophages (phage technology). Bacteriophages (Greek for "bacteria eaters"), as the name implies, are viruses that target specific bacteria, infecting and killing them. Phages are ubiquitous, meaning they're found everywhere on Earth — they're inside our bodies, on our skin, in the soil, on the inside and outside of plants and animals, and even in the ocean. Intralytix, Inc. is a company that creates natural products to kill harmful foodborne pathogens, and describes the viruses this way:

"Typical phages have hollow heads, where the phage DNA is stored, and tunnel tails, the tips of which have the ability to bind to specific molecules on the surface of their target bacteria.

The phage DNA is then injected through the phage tail into the host cell, where it directs the production of progeny phages, often more than 100 in 20 [to] 40 minutes. These 'young' phages burst from the host cell, killing it, and infect more bacteria.

Phages are very specific. They can only infect their targeted bacteria, and they have no effect on any human, animal, plant, insect, etc. cells."3

Unlike other methods used to kill pathogens, for example, irradiation, HPP or chlorine washes, bacteriophages don't affect the color, taste, texture or odor of ingredients. It's a 100 percent natural approach to killing bacteria in raw food. Phage technology is also less expensive and easier to use than other methods. It's applied as a fine mist to ingredients, so raw pet food producers — many of whom are small operators — don't need to purchase highly specialized equipment.

Fermentation. Fermentation is a way of inoculating raw ingredients, which enables beneficial bacteria to protect the food against pathogens through manufacture, distribution, storage, all the way to your pet's bowl. Here's how Roxanne Stone, vice president of Research and Development for Answers Pet Food, a family-owned company that makes raw organic diets for dogs and cats, explained the fermentation process in an interview I did with her:

"What we're doing is inoculating the food and favoring that beneficial bacteria, because fermentation is generally a competition. We don't want to wipe out all bacteria because it can have very negative consequences. If we destroy all the bacteria with processing techniques like pasteurization, and we don't re-inoculate, then obviously that's detrimental to the balanced food micro-ecosystem we want to create. So we inoculate our formulations at cool temperatures.

We use mesophilic-type cultures. What mesophilic means is just [low-temperature] fermentation. They'll ferment down at 50 degrees, so even at refrigeration temperatures, you're using cultures that can still be active down at those lower temperatures, and so we use those types of cultures, a broad spectrum of cultures.

The nice thing about fermentation is that lactic acid bacteria also produce an antimicrobial agent called bacteriocin, which is almost like an antibiotic that is detrimental to bad bacteria, like listeria and E. coli and salmonella. There's a lot of research on this."

Fortunately, there are a number of wonderfully innovative pet food companies like Answers that are coming up with their own means of controlling pathogenic bacteria without using extreme measures that totally obliterate all the healthy bacteria and other nutrients in raw food.

What You Need to Know About All Those Raw Pet Food Health Warnings

When I attended the July 2015 AAFCO meeting, the head of the FDA Center for Veterinary Medicine openly told the group they would be focusing on testing raw foods in the upcoming years.

Interestingly, their decision to target raw foods wasn't due to customer complaints or ill dogs, and it wasn't due to a massive recall or discovery of contaminants (such as pentobarbital). In my opinion, it was an offensive strategy to pursue this fast growing segment of the industry to try to find a problem to highlight, to cast doubt and generate fear.

Unless kibble manufacturers begin producing raw foods to compete in the marketplace (which means acknowledging their dry food products are not biologically correct), their only option is to attempt to affect sales of competing food categories by creating consumer doubt or trust issues.

Thanks to the constant hectoring about the dangers of salmonella in raw pet food (when in fact, the problem has historically been much more prevalent in processed pet food), many pet parents remain concerned about feeding raw foods specifically because raw meat can contain salmonella bacteria.

The fact is that salmonella can be found in up to 36 percent of all healthy dogs and 18 percent of healthy cats regardless of the food they consume. Many pets harbor these bacteria as a part of their normal gastrointestinal (GI) flora and naturally shed salmonella organisms in feces and saliva regardless of what food they eat.

All nontyphoid salmonella species are ubiquitously present in the environment and reside in the GI tracts of many animals, including pets. The majority of human salmonellosis cases are acquired through ingestion or handling of contaminated dry pet foods and treats — not raw meat. Here's what you need to know about foodborne pathogens:

  • Dry food and raw food can certainly harbor salmonella, so awareness is important
  • Regardless of what food you feed your pet, animals can naturally harbor salmonella that can be a risk to humans, especially if you or a member of your family is immunocompromised
  • The raw meat used in many commercially available raw food diets is human-grade, USDA-inspected and no different from the steak and chicken purchased for human consumption from a grocery store. It should be handled with the same safety precautions you use when you prepare meals for your family. It's all the same meat. Your kitchen counters, bowls, cutting surfaces and utensils should be disinfected whether the raw meat is intended for your pet or human family members.

Bottom line, follow the same safe handling precautions regardless of what you feed your pet, and be assured that responsible raw food companies perform due diligence to control potential pathogenic bacteria in a variety of nontoxic ways, including using HPP, phage technology, fermentation and other methods to ensure each batch of product is safe for consumption by your pet.