Toxic: From Factory to Food Bowl, Pet Food Is a Risky Business

Agencies and Countries

CDA — Colorado Department of Agriculture

CDC — US Centers for Disease Control and Prevention

CDPH — California Department of Public Health

CFIA — Canadian Food Inspection Agency

CORE — Coordinated Outbreak Response & Evaluation Network, US Food and Drug Administration

CVM — Center for Veterinary Medicine, US Food and Drug Administration

DoJ — US Department of Justice

EU — European Union

FDA — US Food and Drug Administration

FSA — Food Safety Agency, United Kingdom

FSIS — Food Safety and Inspection Service, US Department of Agriculture

ILDoA — Illinois Department of Agriculture

MDARD — Michigan Department of Agriculture and Rural Development

NRC — US National Research Council

PADoH — Pennsylvania Department of Health

PDA — Pennsylvania Department of Agriculture

PHAC — Public Health Agency of Canada

RASFF — European Union Rapid Alert System for Food and Feed

UK — United Kingdom

US or USA — United States of America

USDA — US Department of Agriculture

Vet-LIRN — Veterinary Laboratory Investigation and Response Network

WSDA — Washington State Department of Agriculture

WVDA — West Virginia Department of Agriculture

Miscellaneous Abbreviations

AAFCO — Association of American Feed Control Officials

AVMA — American Veterinary Medical Association

BARF — Biologically Appropriate Raw Food (or Bones and Raw Food)

COA — Certificate of Analysis

CUCVM — Cornell University College of Veterinary Medicine

cGMP — current Good Manufacturing Practice

DCM — Canine dilated cardiomyopathy

FD&C Act — US Food, Drug, and Cosmetic Act

FEDIAF — Fédération Européenne de l’Industrie des Aliments pour Animaux Familiers

FSMA — Food Safety Modernization Act

g — gram

GRAS — Generally Recognized As Safe

HACCP — Hazard Analysis and Critical Control Points

HPP — High hydrostatic pressure pasteurization

IU — International Units

kg — kilogram

KSU — Kansas State University

LACF — Low-acid canned foods

ppb — parts per billion

ppm — parts per million

SOP — Standard Operating Procedure

STEC — Shiga toxin-producing E. coli

Acknowledgments

Writing is usually portrayed as a solitary activity. Indeed, the process of translating a thought into words onto a screen or a sheet of paper can only be undertaken by the person in whose mind the thought resides.

That said, a writer does not work in a vacuum.

This book would not have seen the light of day without the encouragement and support of my husband, Michael Entis. He is my sounding board and my reality-checker. He never hesitates to tell me when he thinks I’m going off-track and, as frustrating as that can be, he is usually right.

I am beholden to the anonymous worker bees within the US Food and Drug Administration, the US Department of Agriculture, and various state agencies for their conscientious efforts in filling my many Freedom of Information Act and Public Records Query requests. Without their commitment to their jobs, I would have been unable to piece together most of the stories contained in this book.

My thanks, also, to the spokespeople in the FDA’s Center for Veterinary Medicine (you know who you are) for tracking down the answers to many of my questions.

As always, I am grateful to my beta-readers, Barbara Bloomfield, Michael Entis, and Alison Henderson, who read all or part of an early draft of my manuscript and flagged a plethora of problems for me to address. Thanks also to Alison Henderson for taking the time from her own writing (yet again) to perform a careful copy-edit of my manuscript.

My cover owes its impact to Hilary Quint, who freely gave of her time and talents to help make the cover worthy of the content. I couldn’t have done it without you, Hilary. You are a star!

Finally, my thanks to my friends and followers in the food-safety and pet pawrent communities for encouraging me to undertake this project, and for cheering me on when the task appeared too daunting. I hope the final product meets with your approval.

Preface

The idea for TOXIC was born on Carmel Beach. My husband and I were strolling the beach, as we often did when we lived in Carmel-by-the-Sea, California, watching the antics of our Australian Cobberdog, Shalom, as she explored the masses of seaweed and sections of driftwood that had been washed up by the tides.

The year was 2018, and I was recounting the latest pet food recalls. As we discussed the various contaminants and adulterants that had been found in dry, canned and raw pet foods, a bulb lit in our heads.

Why not present the issues surrounding the pet food industry using a similar approach to my 2007 book, Food Safety. Old Habits, New Perspectives ?

I began to research this exciting new project as soon as we returned home. However, I must confess that TOXIC has traveled up and down my priority list in the ensuing years. I wrote and released two other books since beginning work on TOXIC.

In 2019, I undertook a major revision and update to Food Safety , and released the new edition in 2020 under the title TAINTED. From Farm Gate to Dinner Plate, Fifty Years of Food Safety Failures . I also wrote and released the sixth book in my Damien Dickens Mysteries series (yes, I write mysteries, too).

And, just when I was about to return to TOXIC , I was urged by several people (including my husband) to narrate an audiobook edition of TAINTED .

Once the audiobook was released, I resolved to let nothing else get in the way of completing my pet food project—not even last-minute investigation updates.

Investigations into at least three of the companies covered in TOXIC —Sunshine Mills, Midwestern Pet Foods, and Arrow Reliance (dba Darwin’s Natural Pet Products)—were ongoing as of the end of March 2023. I’ll continue to cover developments in these and other pet food safety stories in my regular blog, eFoodAlert .

As I wrote in my preface to TAINTED , I am a passionate advocate for food safety. That includes the safety of pet food. Our companion animals enrich our lives and our families. They have no say in what we choose to feed them. It is our responsibility to ensure that the food they eat is safe and nutritious.

Phyllis Entis

Victoria, BC, Canada

Chapter 1

In the Beginning

Pathogens and pentobarbital. Flies and filth. Obfuscation and outright lies. For almost as long as commercial pet foods have existed, consumers have been forced to tease out the facts from the flummery when choosing what to feed their four-legged companions.

According to popular legend, it all began on the Liverpool docks.

James Spratt was an electrician, an inventor, and an entrepreneur. Of an English family, but born in Ohio, Spratt settled in England, where he planned to market his latest invention, Spratt’s Patent Copper Lightning Rod. ¹ While walking the docksides of Liverpool and London in the late 1850s, he observed packs of dogs waiting eagerly for sailors to discard surplus hardtack. That was all the inspiration he needed. ²

Spratt did not invent the dog biscuit. He was at least a half-century too late to make that claim. ³ But the hardtack story made for effective marketing.

In 1860, Spratt introduced Spratt’s Patent Meat Fibrine Dog Cakes, made from wheat, vegetables, and beef blood, and the modern commercial pet food industry was born. ⁴

Spratt expanded his business into the United States in the 1870s and dominated the American market for dog treats until 1907, when the F.H. Bennett Biscuit Company introduced a bone-shaped treat, which the company marketed as Maltoid Milk-Bones. ⁵ The National Biscuit Company (Nabisco) purchased Bennett Biscuit in 1931, and became one of the first major food companies to target the companion animal market.

The first canned dog food owed its beginnings to World War I. Although partially mechanized, armies on both sides of the conflict relied on horses to move artillery, ambulances, supplies, and men. Once the war was over, the military’s demand for horses evaporated. At the same time, the rising acceptance of motorcars and the increased use of mechanized farm equipment in the years following the war reduced the civilian market for work horses. ⁶ , ⁷

In 1922, Phillip Chappel, who was a supplier of horses to the US Army, found himself with a surplus of horses and a dearth of customers. He converted a vacant packing house in Rockford, Illinois, to the production of canned dog food, which he named Ken-L Ration. Advertised as containing meats, cereals, and cod liver oil, the dog food was made from horse meat, a fact disclosed in small print on the label. The label also boasted a US Department of Agriculture seal, which read, Inspected and certified by U.S. DEPT of AGR as a normal maintenance dog food. ⁸

Chappel Brothers, Inc. quickly captured 90% of the commercial dog food market. The company expanded into other related products, such as Ken-L Biscuit, Pup-E Ration, Kit-E Ration, and Maro-Meat. ⁷ , ⁸

A victim of his own success, Chappel ran out of horses. In 1928, the company began to round up horses in Montana and ship them by rail to Rockford to supply the burgeoning pet food market. A few years later, the Great Depression, combined with increased competition from beef producers entering the pet food arena, drove Chappel Brothers to the brink of bankruptcy. The company was acquired by the Quaker Oats Company in 1942. ⁷ , ⁹

The US entry into World War II called a temporary halt to the growth of canned pet foods. The diversion to military uses of metal and meat hitherto used for these products caused manufacturers to examine alternative forms of pet food. Dry dog food, first introduced by the Gaines Food Company in the 1930s, moved to center stage. In 1956, Ralston Purina introduced the first extruded dry dog food, taking advantage of the same technology used to manufacture its Chex breakfast cereals. ⁸

Since the 1950s, the market for dry, semi-moist, and canned pet foods increased in lockstep with the dog and cat population. Companies diversified their offerings with specific diets targeting puppies, kittens, adults, and senior companion animals, as well as special diets for pets suffering from various ailments. With government regulation and resources lagging behind the pace of the industry’s growth, pet food manufacturers thrived in a laissez-faire atmosphere.

The 2007 melamine adulteration scandal and other lesser-known misbehaviors on the part of some pet food manufacturers were the inevitable outcome of this lax regulatory environment. Growing consumer distrust of conventional pet food manufacturers led to the introduction of boutique brands, raw pet foods, ‘natural’ pet treats, and other specialty products. And each new product category came with a new set of problems.

Even today, pet food regulation is spotty, at best. In the United States, the US Food and Drug Administration (FDA) is responsible for overseeing the safety of pet foods and animal feeds. ¹⁰ Although the FDA carries out some limited surveillance of retail pet foods in conjunction with state agencies, it relies heavily on complaints from pet owners and illness reports from veterinarians to flag safety issues. Often, this means that a problem is not identified until several pets have been sickened, sometimes fatally.

The situation in other countries is even more haphazard. Canada, for example, requires safety certificates for imported pet food and pet treats, but does not regulate its domestic pet food industry. ¹¹ Only pet foods manufactured in Canada for export to markets such as the USA or the European Union (EU) are subject to any Canadian government oversight. ¹²

In the last two decades alone, commercial pet foods and pet treats have killed hundreds of dogs and cats and injured thousands more, causing heartbreak and financial hardship to consumers who thought they were doing the right thing for their pets.

Household pets are not in a position to decide for themselves what types and brands of food they will eat. Those of us who have chosen to share our homes with one or more companion animals have assumed the responsibility for ensuring that our pets receive a nutritious, biologically appropriate and, above all, safe diet. We cannot rely blindly on the pet food industry to fulfill that responsibility for us.

Chapter 2

A Is For Aflatoxin

Who would have thought that kibble could kill?

Certainly not Susan Patrick, an experienced breeder of Labrador Retrievers, who lost four dogs in December 2005. ¹

The first dog died on December 8, 2005, two days after developing bloody diarrhea. By December 19 th , four previously healthy Labrador Retrievers were dead, and others were showing symptoms of liver disease.

When a necropsy of one of the dogs determined the cause of death to be a poison rather than an infection, the search for the source began.

The first clue came in mid-December, when two sick Golden Retrievers were brought to the same animal hospital that treated Patrick’s dogs. The Goldens were exhibiting the same symptoms as her Labradors.

Dr. Gluckman, the veterinarian who had examined Patrick’s dogs, learned that the Goldens had been fed the same food that Susan had fed her Labs—Diamond Premium Adult dry dog food.

Gluckman contacted Diamond Pet Foods to report his observations and also sent samples of the kibble to the Cornell University College of Veterinary Medicine (CUCVM).

On December 20, 2005, Diamond Pet Foods announced a product recall, advising consumers that the company had discovered aflatoxin in one of its products, which had been manufactured in Gaston, South Carolina. The recall notice gave no indication that any animals had died. ²

On December 23, 2005, the Cornell University Chronicle Online reported that the CUCVM hospital was caring for seven dogs suffering from food poisoning. The university’s Animal Health Diagnostic Center had received and necropsied the bodies of three dogs, finding liver damage in all three. In addition, the Center’s toxicologist had found aflatoxin in samples of Diamond Pet Foods. ³

Cornell was not the only veterinary school to become involved in the investigation. The University of Tennessee Center for Veterinary Medicine also studied a number of sick and dead dogs, performing necropsies on eight that were confirmed to have died from aflatoxin poisoning. ⁴

In all, the FDA was able to confirm reports of twenty-three dead dogs and an additional eighteen ill dogs, all of whom had consumed a Diamond Pet Foods product. ⁵

The actual toll was much higher.

Researchers at Cornell conducted a retrospective case study of the records of seventy-two sick dogs that had consumed the pet food. Forty-six of the dogs identified in the study died as a result of aflatoxicosis. ⁶

The FDA’s response

Once the source of a foodborne outbreak has been determined, the FDA’s first priority is to ensure that the offending food has been recalled from the marketplace and the public warned of the danger.

In 2005, the agency did not have legal authority to order a recall. Fortunately, Diamond was cooperative and initiated a voluntary recall with minimal delay.

On December 21 st , the day after the recall announcement, Harold Blackwood, an FDA investigator, was knocking on Diamond’s door. ⁷

Blackwood reviewed Diamond’s written procedures, which appeared to contain several protections against aflatoxin contamination and substandard ingredients.

According to the written protocols, all incoming batches of corn (a major ingredient in the contaminated products) were tested for aflatoxin, and any shipment exceeding the limit of twentyThe Beauty Queen of Jerusalem: A Novel parts per billion (20 ppb) was rejected. The company also had set specifications for all incoming bulk ingredients, including acceptable concentration ranges for protein, fat, moisture, ash, and fiber. A sample was supposed to be collected from every incoming ingredient shipment and held for later testing, if necessary.

Too often, these protocols were ignored. To make matters worse, some of the tests performed by company employees were carried out incorrectly.

Tests performed by Diamond ’ s personnel on four batches of whole corn delivered to the company between September 16, 2005, and November 21, 2005, found no aflatoxin, and these shipments of corn were used in the manufacture of pet food.

Repeat testing by a third-party laboratory of retained samples from these same batches discovered aflatoxin levels ranging from 90 ppb to 1,851 ppb—well in excess of the 20 ppb limit.

There may have been other contaminated corn shipments accepted on the basis of an improperly performed test. We’ll never know for sure, as more than half of the retention samples that should have been collected between September 1, 2005, and November 30, 2005, had gone missing by the time Blackwood arrived on site.

Diamond also turned a blind eye to its own ingredient specifications for