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Veterinary Forum February 2008 (Vol 25, No 2)

Expert Summit on Pet Food Part II

    Veterinary Learning Systems, publisher of Veterinary Forum, recently brought together key players in the field of pet nutrition to talk about labeling, education, regulations and the effects of last year's pet food recall. In part two, we discuss labeling, consumer marketing, raw-food diets and pet food regulations.

    Kathryn E. Michel, DVM, MS, DACVN, Moderator: Marketing trends in commercial pet foods favor such terms as "natural" or "organic" and "human grade." Are any regulations being considered for the use of terms that describe ingredients and content?

    Philip Roudebush, DVM, DACVIM: AAFCO now indicates that the term "human grade" cannot be used anymore. However, the term continues to be on websites, in brochures and on some labeling.

    Michel: It is certainly still a part of the marketing strategies. Another favored term is "holistic."

    Roudebush: The AAFCO manual defines organic as a formula feed or a specific ingredient within a formula feed that has been produced and handled in compliance with the requirements of the USDA natural organic program. So, as far as I can tell, AAFCO has defined natural, organic and human grade. There are clear regulations regarding those three areas. Holistic, however, is a tough one to define or to regulate.

    Sean Delaney, DVM, MS, DACVN: Why is there interest in organic and natural by the consumer? Is there a perceived benefit? Is there something that they feel they don't have in other foods? That they are inferior?

    Roudebush: From consumer research, the five most important nutrition benefits that the "natural" consumer seeks are: Number 1, will it help my pet stay healthy? Number 2, will it help my pet live longer? Number 3, does it have wholesome high-quality ingredients? Number 4, does it provide superior nutrition? And number 5, does it offer complete and balanced nutrition?

    Michel: Do you think certified organic foods have any advantage or benefit over foods that are made with conventionally raised ingredients?

    Delaney: I find there's a growing body of clients who believe that somehow it's more wholesome and doesn't have residues, but it's also about what clients believe is the treatment of the source animal. We have clients who are interested in vegetarian foods because of that. You're starting to see some small niche products with labels that say something about certified humane handling. You know, people are concerned about the impact on the environment. It's not just about what's going into their animal, it's the issues linked to or associated with the ingredients.

    Leighann Daristotle, DVM, PhD: It definitely mirrors the trends in human food consumption. Clients say, "Well, I buy organic milk for my children, and my dog is like one of my children so I'm going to buy organic pet food." Without being able to articulate what the benefit is, clients think they're doing something better.

    Michel: What are some other key points that practitioners should talk to clients about in terms of alternatives to commercial pet foods or conventional commercial pet foods? For example, what should practitioners discuss regarding raw-food and home-prepared diets?

    Daniel McChesney, PhD: From a safety standpoint, raw diets present a significantly greater risk for owners and their family than commercial diets because they are open to Salmonella contamination. If a client is going to feed a raw diet, it is more important to handle the food correctly, wash hands, clean up the counters, wash utensils and probably cook the product.

    Lisa M. Freeman, DVM, PhD, DACVN: What I would like veterinarians to know is that there are no proven benefits linked to raw diets, yet there are multiple studies showing nutritional imbalances, both in commercial and homemade raw diets, and multiple studies showing contamination in the vast majority of raw diets. There is a risk for the people in the household but also for the pets themselves. So, in terms of raw-food diets, the risks far outweigh any potential benefits.

    Dorothy P. Laflamme, DVM, PhD, DACVN: We might want to separate the perception of the widespread use of raw-food diets from the reality of their widespread use. When we did a survey a couple of years ago, of 18,000 phone calls, just about 1,000 pet owners completed the survey and about 100 dog owners said they included some raw food, such as a raw bone, periodically in the diet. Only a small percentage of the total fed raw foods with any regularity, and a vast majority of those feeding raw foods lived in Australia, not the United States. So although the number of people who are feeding homemade raw diets in this country is growing, the percentage represents a small group.

    Maybe we need to distinguish commercial raw-food diets versus raw-food home-prepared diets. One of the questions I have is: Is the risk different if it's a commercial product? Have some of the foods that are sold as raw-food diets been lightly cooked or maybe sterilized? We have to consider the risks, as was pointed out, the potential benefit, if any, and compare and maybe contrast those with other homemade diets because there are times when a homemade diet is right for a particular pet.

    Freeman: There is definitely a place for well-balanced — by an expert — homemade diets. However, studies have found no difference between homemade raw diets and commercial raw diets in terms of nutritional balance or contamination risk.

    Julie Churchill, DVM, PhD: I agree. In fact, if a patient has been eating raw-food diets, our hospital policy is to discontinue that diet during hospitalization because it serves as a risk for other patients as well as the staff. Although the risk may be statistically small, it still does not outweigh the benefits.

    Laflamme: Since the recall — this is not specific to raw foods, but it is specific to homemade diets — more pet owners are feeding homemade diets, and we're starting to receive reports about signs of nutritional deficiency associated with some of the homemade diets. Are any of you experiencing that too?

    Mary B. Tefend, MS, LVT, VTS (ECC): Some reports of chronic vomiting and diarrhea have been made, but we also just had a case of calcium overload because the owner had read that prepared foods are low in calcium, so the pet was receiving calcium supplements. Because the animal is older, we were worried about renal problems that could be associated with hypercalcemia.

    Churchill: I wholeheartedly agree that there is a place for homemade diets when they are complete and balanced. However, I frequently see well-meaning owners make substitutions to the recipe until, over time, "diet drift" occurs, and the diet may no longer resemble the original formulation. Substitutions happen for a variety of reasons: difficulty finding a calcium supplement, desire for variety and so on. At times I've had clients add potentially unsafe ingredients because of ignorance. Owners may not realize that some of the things that are human grade, such as grapes, wine or beer, can be toxic to pets.

    Delaney: In California, we are seeing niche companies offering foods that are grossly deficient. In one case, the labeling was not clear to a client, and the product was basically an all-meat canned cat food with nothing added to it. The cat became vitamin deficient.

    Roudebush: To my knowledge, no AAFCO maintenance feeding trial in a group of animals has been conducted for home-prepared diets of any kind.

    Laflamme: There are no AAFCO studies per se, but two independent studies compared dogs fed commercial pet food with dogs fed homemade diets. The study that I'm most familiar with involved more than 1,000 dogs in three different groups: One group was fed commercial foods, another was fed homemade diets that were vegetarian — because the study was actually done in India, where a lot of the dogs are fed vegetarian diets — and the third group was fed homemade diets made with meat.

    There were significant differences in terms of health problems being greatly reduced by the feeding of commercial pet foods. So, while it's not the same as an AAFCO study, it has probably more impact because it's a home situation.

    Tefend: What was the study?

    Laflamme: It was published as an abstract only in Compendium in 2000 and presented at the 1999 Purina Nutrition Forum . Abdul Rahman was the primary author.

    Michel: In light of what happened last year, are existing regulations sufficient to ensure the health and well-being of companion animals when considering such food safety issues as ingredients, additives and by-products?

    Laflamme: There are issues at all levels: USDA issues in terms of guidelines and inspections, import issues, domestic issues and, of course, pet food companies have their own standards for determining the nutritional value of the ingredients and tests for known contaminants.

    All of the major pet food companies have their own programs set up to confirm that ingredients meet specifications and to look for known toxins, such as aflatoxin and other known problems.

    What happened in the 2007 recall was deliberate contamination of an ingredient from something that we wouldn't even think to look for. There's very little that can be done if somebody wants to deliberately put toxin into a food, whether it's for humans or for pets.

    McChesney: The recent melamine recall has brought to the forefront different ways we think about contaminants. In the past, we've looked at products and said what can likely go wrong with them. So with corn, you look for aflatoxin.

    There are some broad issues: We might consider pesticides or other production mistakes. This is the first time in which strictly economic adulteration was involved, so the lesson we need to now consider is economic adulteration of a product. This surely could have been detected by not looking at total nitrogen content and making it magically turn into a protein number, which is the way products are looked at now. A protein analysis would have easily detected the problem, but that's hindsight.

    The other thing is that pet food and animal feed are regulated under the adulteration provision of the Food, Drug, and Cosmetic Act. So, the presumption is that a company will make a product that is not adulterated or unsafe, and that's a fairly broad definition of adulteration. Even though most commercial pet food companies operate under GMPs and sanitary SOPs, there are no regulations that require them to follow GMPs for nonmedicated feeds, which are virtually all the pet foods.

    Having said that, most companies do, but that's a limitation if you want to take action against someone because of a problem. We're starting to see a rise in Salmonella in commercial diets, which has pretty much been unheard of in the past, by looking for those organisms and for pesticides as part of routine surveillance. I don't have an explanation.

    Michel: So this trend for the rise in Salmonella we are detecting in our surveillance is new?

    McChesney: Yes, and we are seeing Salmonella in dry or bagged product as opposed to canned product. Canned product tends to be opened and used in a relatively short period, while bagged product tends to be opened and fed over an extended period.

    Salmonella, which typically is our major concern, tends not to be equally distributed throughout the product. It's probably not there in high levels if you look at colony-forming units per some unit of size. It's a small amount that's just randomly there.

    It becomes important to talk about sampling — how many samples to take — because that's the power of your testing. The FDA tends to take 10 — we call them sub-samples, but everybody else would call them samples — and look at them by using an enrichment technique.

    The pet food companies we're dealing with now tended to take one sample and use a nonenrichment technique.

    Michel: During the pet food recall, we heard the FDA say that pet foods are regulated and are required to be safe and unadulterated, but what you have just said is that the actual steps necessary to ensure safety are not spelled out for the industry.

    McChesney: That's right.

    Roudebush: Let me make another comment, however, because there is a misperception that regulatory agencies and regulations are only there to protect the consumer, and that isn't the case.

    Regulations are there to protect the companies, too.

    Industry has a critical role. Let me use an example that's totally outside the pet food industry. My brother was vice president of a chemical firm that produced lubricants, and every 5 years, a group that represents industry — airplane manufacturers, the government, academics — comes up with standards for lubricants that are used on commercial and private aircraft. Industry is important. Companies have the technical know-how and share that information, allowing industry as a whole to come up with the regulations that protect the users and also the companies because they know what the regulations are and the standards they have to meet.

    Many seem to think that regulatory agencies are only there to protect the consumer, but they aren't. They're there to help set up standards for industry to follow.

    McChesney: I agree with that. Another point is that AAFCO is always talked about as a regulatory body when in fact it's not. It's an association of state regulatory people, and it was set up as a vehicle to allow commercial trade among the states.

    Laflamme: I'd like to clarify the point further. There is a misperception that pet food regulations have been created by the pet food industry and that AAFCO is an industry-driven group or the Pet Food Institute is a ruling body. We need to bear in mind that while there is an institute that contributes opinions about regulations, it doesn't have the ability to establish regulations. AAFCO is not a regulatory body but is composed of regulatory people from all 50 states.

    One of the benefits of AAFCO is that it facilitates interstate commerce, but that's not the same as saying that the pet food companies have created the regulations for their own benefit.

    I wonder if you could clarify what group, if any, has oversight for the safety of ingredients imported into this country?

    McChesney: The FDA, and we regulate these under the adulteration or misbranding provisions of the Food, Drug, and Cosmetic Act. The FDA does look at about 1% of the products crossing the borders. The wheat gluten protein from China was stopped because it was adulterated. The FDA, however, cannot detect all adulterated product, so it ultimately falls to the company to make a safe product.

    The FDA is different from the USDA. The USDA has a person assigned to all slaughter plants that are making a USDA-regulated product, whereas the FDA is rarely in the food firms it regulates. The FDA has 80% of the food and feed plants and 20% of the resources, so it doesn't marry up particularly well. We count more on our industry partners to do the job correctly.

    Michel: The measures that are taken by companies to ensure the quality and safety of products and the sources of their ingredients are primarily voluntary. How can we educate people to look at the quality-assurance aspects of pet food manufacturing rather than just marketing?

    McChesney: It's difficult because during the pet food recall, we worked closely with the companies and witnessed their processes, but we are not allowed to advertise this information or promote any company or its oversight measures. And when a company projects this information, it sounds self-serving. So the companies were caught in the middle.

    Roudebush: From a standards standpoint, Hill's is owned by a consumer products company, and so pet food is internally regulated similar to any other consumer product. Colgate sets a standard for all products — whether toothpaste or dishwashing liquid or underarm deodorant — and that is what is followed for pet food. But is that approach right for pet food? I don't know. But we need to start somewhere. If a certain number of complaints per 100,000 units produced are made, then that triggers an additional evaluation from quality control.

    Daristotle: Most of the major pet food companies have been fairly vocal about the quality control in place and have quality-assurance programs accordingly.

    McChesney: In the most recent melamine issue, the FDA received about 18,000 calls, but when we asked for records and talked to veterinarians, there was virtually no dietary history. When we asked, "What did you feed?" the answer generally was whatever happened to be in the closet at the time. It may or may not have been related. We probably have 400 or 500 clinical records and pathology results, and after reviewing the information, there was nothing about how long a dog had been on this diet or what it had been eating — nothing on its dietary history. That is not routinely asked or documented in veterinary records.

    We did a lot of work with Banfield, The Pet Hospital, and there was no dietary history in any of those records. Now, Banfield is adding that as a required field. Based on what we've seen, dietary history is rarely asked by veterinarians.

    Roudebush: From what we saw in reviewing records for the recall, there may be documentation — usually an invoice for a therapeutic food dispensed by the hospital — but you're right, documentation of what the animal is eating, including snacks, is lacking. None of that information was asked. It could easily be done by obtaining a dietary history and making that part of the medical record.

    Tefend: Or, veterinarians could use their technicians because typically they spend more time in the exam room with the client than the veterinarian does. We have been talking a lot about educating students and veterinarians but have not mentioned technician education. That needs to be right up in the forefront — educating technicians on how to take a good patient history, including obtaining a dietary history. This could ensure documentation if a product or quality control is questioned.

    Roudebush: The reality is that most of us think if the company is reputable, then it is assumed that quality-control procedures are in place. I never think twice about whether a toothpaste product has undergone strict quality control. I assume that it did.

    Michel: That reasoning is partly why there was outrage, at least among a certain segment in the pet-owning population, about whether the recall could have been prevented last spring. There was concern that no one was minding the store. One of the things I always tell students is that people think that products are a lot more regulated than they are. People assume that the government, even though they don't want big government, is watching out for them. And so they are absolutely shocked and appalled when something does happen, whether it's E. coli in spinach, Salmonella in peanut butter or melamine in dog food, and they are upset that it happened. How could anybody have let this happen?

    Karen Todd-Jenkins, VMD: Which brings up two questions: Do you think that consumers are recovering from what happened? And second, at some point, is food sourcing going to have to be on the label?

    McChesney: Unfortunately, if you tried to include the country of origin on pet food labeling, you'd probably have 30 countries listed.

    Michel: Regarding the first question, absolutely. The Pet Food Institute (PFI) reported that 73% of consumers say they are confident or very confident in the safety of their pet food, according to three rounds of public opinion surveys conducted by PFI. Results also show that nearly an identical percentage say they are staying with their preferred brand of food.

    Laflamme: And that survey was conducted soon after the recall, so the probability is great that those numbers are even higher now.

    Churchill: If we were building a wish list of what we want veterinary professionals to know, it would be the importance of and how to take a dietary history because it's really the cornerstone of practicing sound clinical nutrition.

    Michel: In terms of obtaining a complete dietary history, the veterinary technician could play a prominent role in that. We send clients home all the time with a diet history form and ask them to write down what's in their cupboard. I know that some clinics have put the form on the web so it can be downloaded in advance of an office visit. There are different ways to do it, but it's often not going to happen.

    The bottom line is, in this day and age we're not going to be able to teach the modern veterinary student everything he or she needs to know. The mantra in the veterinary schools has been that we need to teach students to be able to think critically and find the information. All of the companies produce information. The FDA has information on its website, and there are many CE courses, but veterinarians have to actively seek that information.

    Thank you all for coming.

    NEXT: FORUM Fast Stat (February 2008)

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