How Can Raw Pet Food Contain No Bacteria?

Analysis by Dr. Karen Shaw Becker

Story at-a-glance -

  • While the FDA’s zero-tolerance pathogen policy for dog and cat food makes little sense for raw diets, raw diet manufacturers have stepped up to meet the challenge
  • Some of the processes that pet food producers use to ensure bacteria-free products include high-pressure pasteurization, UV light, ozone, bacteriophages, batch testing, and fermentation
  • If you feed raw food to your pets, consider passing this information along to all the naysayers and fear mongers out there who continue to insist feeding raw diets is dangerous
  • It's also important to realize the raw meat used in many commercially available raw pet food diets is human-grade, USDA-inspected, and no different from the raw meat you buy for human family members

The FDA's Food Safety Modernization Act (FSMA), which was signed into law in 2011, requires that all human and pet food manufacturers maintain a written Food Safety Plan that puts into effect a zero-tolerance policy on potentially pathogenic bacteria in food for people and feed for animals.

With the implementation of FSMA, the FDA's role switched from reactive — removing tainted food products from the market after reports of illness — to proactive, with the goal of preventing tainted food products from reaching the marketplace.

Five Years Ago, the FDA Decided to Target Commercial Raw Pet Food

In mid-2015, with its new zero-tolerance policy in effect, the FDA began conducting large-scale testing of commercially available raw pet food (but not processed pet food) for E. coli, salmonella and listeria.

Interestingly, the decision to target raw diets wasn't due to customer complaints or ill pets, and it wasn't due to a massive recall or discovery of contaminants such as pentobarbital (a drug used to euthanize dogs and cats) which has been found in ulta-processed pet food.

In my opinion, it was an offensive strategy to pursue the fastest growing segment of the pet food industry to try to find a problem to highlight, to cast doubt and generate fear, potentially steering people back towards highly processed foods.

Unless the kibble manufacturers who run the pet food industry begin producing raw foods to compete in the marketplace — which means acknowledging their dry foods are not biologically appropriate — their only option is to attempt to affect sales of competing categories like raw diets by creating consumer doubt and trust issues.

The FDA’s Zero-Tolerance Policy Applied to Raw Pet Food Makes No Sense

The problem with the FDA's zero-tolerance policy is that it's an unrealistic and impractical goal when you're dealing with raw meat intended for consumption by carnivores (cats) and scavengers (dogs). Cats and dogs have evolved with a much higher tolerance than humans for foodborne pathogens.

Even more concerning is that the FDA has no policy in place to discern pathogenic from non-pathogenic strains of E. coli and salmonella. There are hundreds of different strains of these commensal organisms.

Many of them are naturally found in pets’ gastrointestinal (GI) tracts and the FDA has made no provision in the FSMA to differentiate potential pathogens that could harm humans from the naturally occurring bacteria found in dogs and cats around the world, regardless of the food they eat.

In addition, the FDA doesn't even have a zero-tolerance policy for USDA-inspected meats headed for the supermarket for human consumption, which are ironically the same quality of meats that the vast majority of raw pet food manufacturers use. It's frustrating that the standards for raw pet foods exceed those of meat destined for human consumption.

Fresh pet food manufacturers are using a variety of processes to ensure their raw food products are safe, so the next time you hear someone say commercial raw pet diets are "dangerous" or your veterinarian warns against feeding raw foods because they’re harmful, feel free to correct them.

High-Pressure Pasteurization/Processing (HPP)

One pathogen control method many raw pet food manufacturers are using is high-pressure pasteurization/processing (HPP), which creates sterile raw food devoid of all bacteria. HPP is an FDA-approved process that is used extensively in the human food industry.

Unfortunately, HPP also eliminates beneficial probiotic bacteria, which is why its critics don't like it. The process works by applying a very high hydrostatic pressure up to 80,000 pounds per cubic inch to eliminate all potentially pathogenic microbes.

Critics of HPP believe it's a fairly extreme method of processing whole foods because, depending on the amount of pressure used, research has demonstrated that proteins in the food can denature, and beneficial bacteria are obliterated. There is also some concern about the risk of pets ingesting plastic residues called phthalates as a result of high-pressure processing. Of course, you could be ingesting them as well if you're eating human foods that have been HPP'd.

Critics of HPP also believe it’s 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. 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.

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.

With all that said, there is certainly room for sterile food in the marketplace. In theory, HPP’d food is the safest food on the market because it's sterile. This is something that about 90% of the veterinarians I meet don't realize.

So if you come across veterinarians who says things like, "All raw food contains bacteria that could be harmful to your animal,” make sure to either send them this video or inform them that up to 40% of commercially available raw food diets on the market are sterile because they've undergone this particular processing technique. HPP’d raw foods are devoid of all bacteria and that's something that no kibble in the world can claim.

If you have young kids in the house or an immunosuppressed individual, sterile raw food may be a great option for you. This is also my recommendation as a food choice for pets that have had recent GI surgery and need a very clean food choice during recovery.

Ultraviolet (UV) Light

Many raw pet food manufacturers use HPP, but others use ultraviolet (UV) light technology that creates antimicrobial conditions in addition to the germicidal properties of UV. This makes it possible for portions of the manufacturing process such as grinding, patty-making and packaging to be accomplished without risk of environmental contamination, because pathogens are systemically destroyed in the environment when this technology is operating.

There are three varieties of UV light, separated by wavelength (UV-A, UV-B, and UV-C). UV-C has the shortest wavelength and is the type used for food production. According to the FDA, UV-C at 200 to 280 nanometers is within the germicidal range that is proven to reduce or eliminate E. coli, salmonella, listeria, and other foodborne pathogens.


Ozone is another method that some raw pet food producers use to manage potential bacteria. Ozone is a form of oxygen recognized as a broad-spectrum biocide against viruses, bacteria, biofilms, fungi and protozoa. None of these pathogens can build up a tolerance to ozone because is disinfects by oxidation processes. Instead of poisoning microorganisms, it actually destroys them through oxidation.

Ozone gas is pumped into cold water, and then the ozonated water is used as a rinse, mist, spray, or bath for the meat. The ozone survives for only a matter of minutes before decomposing into ordinary oxygen, making it entirely non-toxic.

Bacteriophages (Phages)

Bacteriophages, aka “bacteria eaters,” are benign viruses that target specific bacteria, infecting and killing them. Phages are ubiquitous — they’re found everywhere on earth. They're inside our bodies and our pets’ bodies, on our skin, in the soil, and even in the ocean.

Phages are very specific in that they can only infect their targeted bacteria. They have no effect on any human, animal, plant, insect, or other cells. Unlike other methods used to kill pathogens, bacteriophages don't affect the color, taste, texture, or odor of ingredients. It's 100% 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.

Batch Testing

Batch testing is another way that raw pet food manufacturers manage potentially pathogenic bacteria. Samples of finished products are tested for harmful bacteria, and if none is found, the batch is shipped to market. Pretty easy. This is the oldest and most tried-and-true method approved by the FDA to evaluate meat for human consumption.

A potential 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.


Fermentation is a method of inoculating raw ingredients, which enables beneficial bacteria, including lactic acid bacteria to produce an antimicrobial substance called bacteriocin that protects the food against pathogenic bacteria blooms through manufacturing, distribution, and storage, all the way to your pet's bowl.

As you can see, raw food manufacturers use a variety of methods to manage potential pathogenic bacteria in their products.

If you’re curious about the raw pet food you purchase, you can research the company’s website or call the customer service line to find out exactly what method is being used to comply with the Food Safety and Modernization Act.

That being said, it's important to keep in mind that the raw meat used in many commercially available raw pet food diets is human-grade, USDA-inspected, and virtually no different from the steak and chicken purchased for human consumption from your local grocery store.

Obviously, raw meat for your pet should be handled with the same safety precautions you use when you prepare meals for your family. It's all the same meat, so if you're cutting meat on your kitchen counter, whether it's destined for your pet’s bowl or your dinner plate, you should disinfect your bowls, counters, cutting board surfaces, and utensils.

Another challenge for every pet food producer is managing recontamination risks, since implementing pathogen kill steps in the manufacturing process doesn't eliminate the potential for recontamination after production.

If the pet food you buy is made outside the U.S., safety protocols are still voluntary, so it's extra important to call the company and ask a few questions. Any company practicing transparency will be more than happy to answer questions. If a pet food company can't or won't answer your questions, I suggest you shop elsewhere.