Explaining the FDA Zero Tolerance Policy: Can't Our Pets Handle Bacteria?
|
Time to read 3 min
If you’ve been feeding raw or have done some research, you’ve likely come across discussions of pathogen risks in raw foods. The FDA takes a zero-tolerance stance and does not allow pathogens such as Salmonella spp, Listeria monocytogenes, and E.coli O157:H7to be present in any pet food regardless of whether it's dry, canned, or raw.
This zero tolerance policy is clearly more of a challenge for raw food companies and in response, some raw pet food brands point to how our pets’ digestive systems are better equipped to deal with bacteria or point to a double standard for pathogens being allowed in human food (raw chicken at the grocery store) but not pet food. Although these arguments do have merit, let’s take a look at why the FDA still sets a zero-tolerance policy for pathogens in pet food. This is our interpretation based on working with our inspectors & regulators over the years and doesn’t represent an official FDA opinion.
Why Different Standards Exist for Raw Meat for Human Consumption vs. Pet Food
The answer to this question starts with a brief explanation of our food regulatory system. The USDA regulates and inspects all raw meat processed for human consumption and the FDA regulates pet food amongst other product categories.
The USDA does not have a zero-tolerance policy for pathogens in raw meat and as an example, up to 25% of poultry products can test positive for pathogens like Salmonella spp.before a processing facility is required to take corrective actions.The reason for this is because USDA expects anyone who buys raw meat to later cook it and kill any bacteria present and besides, these pathogens are naturally found within livestock. This is why recalls for pathogens do not happen for raw meat and packaged raw meats all come with a label for “Safe Handling Instructions” for cooking. The exception to this is E.coli O157:H7will be recalled if it’s found in raw ground beef and that’s why both us and our suppliers test for this.
Pet food, on the other hand, is considered “Ready-to-Eat” and no additional cooking or “kill-step” is applied before feeding. This “Ready-to-Eat” distinction is the main reason why it falls under a zero-tolerance policy similar to other foods you would serve directly from the package like deli meats, cheese, salads etc. The challenge here is that even though many reputable raw pet food manufacturers are sourcing USDA inspected protein ingredients, there’s likely a low level of pathogens present in the raw materials but the final product must be pathogen-free.
Aren’t Our Pets Able to Handle Some Bacteria?
The argument here is that carnivores have evolved a digestive & immune system better equipped to handle pathogen loads in their food - after all, wild carnivores are eating their meals as-is. This is likely true but the regulatory perspective is that there is no way to establish a safe threshold for these pathogens in food especially since our pets live in “close human contact”.
Let’s say the goal is to establish a threshold for how many pathogen cells it would take to cause disease. If a food falls below this threshold, it should be considered safe. The first challenge is that pets have different susceptibilities to the same pathogens due to differences in their immune system or health and it’d be extremely difficult as well as ethically challenging, to conduct enough testing to find a threshold that would be safe. Even if a safe threshold is established, pathogen cells can easily multiply depending on the conditions they are held in, so even if a product tested below the threshold at one point in time, storage or handling conditions could cause growth to an unsafe level.
The second concern is that our pets live closely alongside us and if there were pathogens present in their food, people in the household could come in contact with the bacteria by handling the food or bowls and become sick. People have an even more varied range of tolerances to pathogens (i.e. immunocompromised, elderly, children) and the regulatory safety concern is just as much for our pets as it is for the humans that take care of them. As a result, the only justifiable position FDA can take is a zero-tolerance policy since safety cannot be guaranteed at other levels.
The Takeaway
At the end of the day, the zero-tolerance policy is the legal requirement and we’re committed to following all regulatory guidelines for our industry. At Viva, we’ve always believed in putting the quality of our products first and food safety is a critical aspect of that. Our safety program is ever-evolving and involves sampling our products every few minutes for pathogens, rigorous environmental testing & sanitation, and using pathogen eliminating probiotics (click here if you’d like to read more on this). Our commitment to producing pathogen-free food has led us to constantly improve the quality of food we’re making.
