Same product (jerky treats imported from China), same illegal drugs found in the treats, yet one company recalls and the other doesn’t. The ins and outs of product pulls and recalls.
It was frustrating (to say the least) to see that the FDA had not posted the various jerky treat recalls on their website. One week after Waggin’ Train, Milo’s Kitchen, and Cadet brands of jerky treats (imported from China) were found to contain residues of illegal antibiotic residues, the FDA only posted the Milo’s Kitchen recall notice. Plus, with the results that NY Department of Agriculture found in these treats, many wondered if the FDA had ever tested for illegal antibiotics during the five year investigation of the treats. So I sent the FDA some questions, which led to more questions.
Has the FDA ever tested for antibiotic residue in the treats and if so, what drugs were the treats tested for?
FDA response: You had asked about FDA?s testing for antimicrobials in jerky pet treat. FDA contracting laboratories have screened for but not detected reportable antibiotics. We are communicating with New York to more fully understand their testing protocol and methodology.
UC Davis used the Exactive LC MS analysis for detection of antimicrobials. The current method includes screening for the following antimicrobials.
Amoxicillin
Ampicillin
Ceftiofur
Cephapirin
Cloxacillin
Enrofloxacin
Flunixin
Gentamicin
Monensin
Penicillin G
Quinocetone
Sarafloxacin
Sulfadiazine
Sulfadimethoxine
Sulfamerazine
Sulfamethazine
Sulfapyridine
Sulfaquinoxaline
Sulfathiazole
Tylosin
Yohimbine
Why hasn’t FDA posted all of the jerky treat recall notices?
FDA response: With regard to the notices from Del Monte and Nestle-Purina, The Milo’s Kitchen release is now posted on the FDA website at http://www.fda.gov/Safety/Recalls/ucm335621.htm.
As a general rule, FDA only requires press releases for Class I recalls. FDA classifies recalls as dictated by the Regulatory Procedures Manual (you can access the complete RPM at: http://www.fda.gov/ICECI/ComplianceManuals/RegulatoryProceduresManual/default.htm).
Class I is a situation in which there is a reasonable probability (strong likelihood) that the use of, or exposure to, a violative product will cause serious adverse health consequences or death.
Class II is a situation in which the use of, or exposure to, a violative product may cause temporary or medically reversible adverse health consequences or where the probability of serious adverse health consequences is remote.
Class III is a situation in which the use of, or exposure to, a violative product is not likely to cause adverse health consequences.
The actions taken by Del Monte and Purina (and now IMS Trading, which has also withdrawn Cadet jerky treats from the market (see http://www.imspet.com/recallchickentreats.htm) were not Class I recalls. However, all the companies have posted press releases describing their actions and FDA has linked to them from its CVM Update.
This response from FDA brought up more questions.
Because drug residues are such a big issue and especially illegal drug residues – key word illegal – why wouldn’t all of the jerky treat product withdrawals or recalls (depending on the company press release) be considered a Class 1 recall? And further, I’m still puzzled why – if as you stated Milo’s Kitchen was a Class 2 recall, why did FDA post this recall? And further again, if the same drugs were found in all of the treats why again did the Milo’s Kitchen recall notice get posted when the others did not?
Who makes the determination of Class of Recall? Is it FDA or is it the manufacturer? Specifically in this instance, did Purina tell FDA this was a Class 2 recall or did the FDA make this determination? Same question with the other manufacturers – who makes the decision of what class a recall falls into?
FDA response: FDA does not believe that the antibiotic residues at the level found in these treats are likely to cause a health concern. Therefore, they do not rise to the standard of a class I recall. (Personal note: I disagree. Though I’m not a veterinarian or scientist, myself and especially Mollie Morrissette of PoisonedPets.com have found some significant scientific evidence that shows there very well could be a connection to these antibiotic residues found in the jerky treats to the pet deaths and illnesses linked to the treats. For more information, Click Here to read my story, Click Here to read Mollie’s)
When a company makes the decision to withdraw a product from the market for a non-safety issue, that company can decide to supply FDA with information about the removal of the product from market or it cannot supply FDA the information. If FDA receives the information they review it and make a decision on whether it supports a recall and if so classifies the recall. If FDA does not receive information regarding the removal from market it has nothing to base a decision on regarding a recall. (As you remember, in this case it was NYSDAM that tested the products, not FDA). In this case Del Monte and Cadet supplied the FDA District Office with information and it supported a class 3 (lowest level) recall. Purina did not, but withdrew the product from the market. In both cases the product was no longer available to the consumer and FDA was satisfied with the outcome.
So, as it turns out, per FDA, Purina/Waggin Train did not provide FDA information about what prompted the company to ‘withdraw’ the treats from store shelves. Milo’s Kitchen did. Purina/Waggin Train considered their action a “Withdraw” – Milo’s Kitchen considered theirs a “Recall”.
Is it fair that a pet food/treat manufacturer (or in this case treat importer) is allowed to sidestep FDA and not provide FDA with all information known? Is it fair that Purina/Waggin Train and all the other brands that are ‘withdrawing’ the jerky treats from store shelves are not branded with a ‘recall’? Especially when illegal drug residues are found?
In my opinion – no it’s not fair – not one tiny bit. Pet food/treat product pulls, pet food/treat product withdrawals are far from “voluntary” as skillfully crafted press releases indicate. What product pulls and withdrawals do is offer a manufacturer the statement – ‘we’ve never experienced a recall’ or ‘we care about pets so we removed the product out of precaution’ or similar. But to consumers (petsumers), pet food/treat product pulls, or pet food/treat product withdrawals are just another way we (petsumers) get taken advantage of. Product withdrawals can silently remove treats from store shelves without much needed warnings to petsumers that already have those products at home – possibly waiting to sicken or kill another pet. If a food is adulterated (such as illegal drug residues), recall should be the only option.
It is not known what information Purina/Waggin Train could have (but didn’t) provide to FDA. Regardless to whether this information could prove to benefit FDA investigation of the treats or not, shame on you Purina/Waggin Train. As a worldwide recognized brand (Purina), it would seem appropriate for you to fully cooperate with regulatory authorities.
Thank you to Milo’s Kitchen and Cadet brand for providing FDA all information. And Thank you to Publix who told me they “recalled” their private label brand out of precaution (no testing was done on the Publix treats prior to recall – stated to me from Publix media relations). Biggest Thank You to New York Department of Agriculture; without you, who knows how long this jerky treat madness would have continued.
Wishing you and your pet(s) the best,
Susan Thixton
Pet Food Safety Advocate
Author, Buyer Beware
Co-Author Dinner PAWsible
TruthaboutPetFood.com
PetsumerReport.com
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