Refrigerated and Frozen Pet Food: Estimating Risk Factors and Analyzing Regulatory Authority
Ashlee-Rose Ferguson
AFRPS Coordinator, Washington State Department of Agriculture (WSDA)
International Food Protection Training Institute (IFPTI) Fellowship in Food Protection
Abstract
Due to several expansive pet food recalls on melamine and cyanuric acid adulteration resulting in an estimated 39,000 pets becoming ill and over 3,500 pet deaths, pet parents are increasingly seeking fresher, more natural diets. However, these more perishable diets involve different risks and so require additional controls such as temperature control needed to limit bacteria growth. Additionally, there is no pathogen kill step specifically with raw pet food. An analysis of selected hazards and the authority of regulatory agencies was conducted to determine the pet food regulatory landscape and the prevalence of certain risks. This analysis was achieved with a survey distributed to pet food regulatory agencies throughout the country and a field-based survey completed by inspectors at establishments that handle this type of pet food within Washington State and several other states. Results indicated that there is a gap in the regulation of refrigerated and frozen pet food. Most agencies have some type of enforcement authority mainly on the products themselves, but a very low percentage can enforce correction of retail facility violations which could be a root cause of adulteration. Analysis of the risks showed that even in the small number of field-based surveys received, improper temperatures and inconsistent or no handling instructions on product labels were observed. Therefore, more education, training, and enforcement authority is needed.
Keywords: raw pet food, TCS, dog, cat, meat, fresh, limited ingredient, refrigerated, frozen, temperature control, regulatory authority, risks, animal, feed
Background
An enormous pet food recall affecting over 150 brands that began in 2007 was one of the main reasons that motivated pet owners to seek other options for their pet’s diet. Banfield Animal Hospital, one of the largest veterinary hospital chains throughout the nation estimated that over 39,000 pets became ill and over 3,500 pets dies as a result of consuming the adulterated product. FDA received over 13,000 consumer complaints related to this incident (U.S. Senate, Committee on Appropriations, 2007).
Subsequently, pet parents became increasingly concerned with the food they’re feeding their pets and began seeking other natural options (Schlesinger & Joffee, 2011). This increase in concern paved the way for fresher, less processed products being on the market such as refrigerated fully cooked, lightly cooked, or frozen raw pet food. Raw pet food is not intended to be cooked and thus exhibits an inherent risk since there is no kill-step for pathogens (Fauth et al., 2015; Schlesinger & Joffee, 2011; Weese et al., 2005). This risk can also be seen in the amount of recalls associated with raw pet food. Of the 66 animal food recalls since 2016, 46% have been from pathogens in raw pet food (FDA, 2019). Additionally, with the perishable nature of these products, proper storage and handling becomes important to control the growth or spread of pathogens (FDA CVM, 2018). If adulterated food is ingested, pets typically do not show symptoms but commonly become carriers with bacteria transmission likely to humans; thus, the public health risk lies more with pet-human interactions (Selmi et al., 2011; Morse, Duncan, Estep, Riggs, & Blackburn, 1976; Joffee & Schlesinger, 2002; LeJeune & Hancock, 2001; Greene, 2012; Freeman, Chandler, Hamper, & Weeth, 2013; Byrne, Aird, Jorgensen, Kaindama, & Jenkins, 2018; Baede et al., 2017). However, there have been cases linked to pet illnesses or deaths after consumption of pathogen contaminated product or a higher potential for infection (Fauth et al., 2015; Kim, An, Kim, Lee, & Cho, 2017; Morley et al., 2006; Stone et al., 1993; Stiver, Frazier, Mauel, & Styer, 2003). In addition, cross contamination can occur since due to storage in the refrigerator or on kitchen surfaces; shared utensils; and improper handwashing after handling, especially since 97% of people do not wash their hands correctly (USDA FSIS, 2018). Pathogens can proliferate in any perishable pet food products if not held at the proper temperature or if the food comes into contact with surfaces that were not properly cleaned and sanitized (USDA FSIS, 2016; USDA FSIS, 2017).
The regulation of pet food is generally conducted by animal feed programs that are housed within state departments of agriculture. Manufacturing facilities are given priority over inspections of pet food retail establishments which are mostly only visited for the purpose of collecting samples or label checks. Retail food protection is housed in other divisions or more frequently within departments of health, whether at the state or local level.
On the Federal level, the definition of “food” is articles used for food or drink for not only man but also animals (U.S. Code Title 21, 2010). Conversely, the FDA Model Food Code, which is used by state and local agencies, only references food for human consumption (FDA, 2017). Therefore, state and local agencies may devote few resources to ensuring the safe handling of refrigerated and frozen pet food.
In Washington State, the Washington Department of Agriculture (WSDA) has the authority to inspect all facilities that handle animal food in any way but does not have sufficient enforcement authority related to retail establishments. For instance, if product becomes adulterated due to refrigeration not in working condition, the agency can remove the animal food from market but does not have the authority to require corrective action by the retail establishment to fix equipment that may be the root cause of the adulteration. Retail establishments and very small businesses are exempt from certain federal regulations, so these areas not regulated, or not prioritized by states, are also not regulated by Federal authority. Because of these challenges and lack of authority, there appears to be a large area of the industry that is not being regulated in Washington State and possibly nationwide, especially one that has a significant public health impact.
Problem Statement
The degree of regulation in the U.S. and proper controls of refrigerated and frozen pet food is unknown.
Research Questions
Do regulatory agencies have the authority to inspect retail establishments that hold refrigerated or frozen pet food?
Do regulatory agencies have the authority to enforce corrective actions for facility violations at pet food retail establishments?
How well do pet food establishments that hold refrigerated or frozen pet food control the risks associated with the product?
Methodology
The study population included agencies that regulate pet food and establishments that handle refrigerated or frozen pet food. There were two parts to this project, spanning a period of three months. The first part included a seven-question survey on the regulatory authority for pet food sent to all state departments of agriculture throughout the country. The second part was a ten-question survey documenting certain risks at establishments that handle refrigerated or frozen pet food, including retail pet food establishments, grocery stores, department stores, manufacturers, distributors, etc.
The risk survey was voluntarily conducted by inspectors of the WSDA Animal Feed Program and other agencies throughout the country. These surveys were pilot-tested and distributed via the Association of American Feed Control Officials (AAFCO) email distribution list.
Thirty (30) regulatory surveys were received and twenty-eight (28) risk surveys from six (6) states (Washington, Minnesota, Missouri, Illinois, West Virginia, and New York) were received. The results were analyzed to determine the regulatory landscape of pet food and if the identified products are stored or handled properly.
Results
The majority of the regulatory authority surveys (26 of 30) were received from state agencies that have authority to regulate pet food (Table 1) and inspect retail establishments. However, overall only a small percentage (39%) of the agencies have authority to require corrective actions on facility violations from retail establishments.
Table 1
The majority of the agencies that have authority assign the risk category of pet food retail establishments at “low” (36%) or chose the “other” option (46%). Descriptions included: “don’t place risk levels to retail locations,” “retail only sites are not assigned an official risk ranking regardless of the products sold,” “don’t currently have a formal risk ranking system for facilities” and “unless the retail firm is also making/manufacturing a product, this may make the risk higher. However, for the most part, retail firms are low risk.” The highest percentage of inspection frequency of retail establishments was “only as time allows” (25%) and “other” (36%) with descriptions such as “retail locations are visited on a seasonal basis for sample,” and “We inspect the products multiple times throughout the year as part of our Regulatory program, but we do not inspect the retail location unless they manufacture pet food or animal feed.” Since these products require temperature control, one of the questions asked was if inspectors are issued thermometers. Only 26% of the state agencies and none of the other agencies issue thermometers to their inspectors.
The majority of the risk surveys (N=28), were conducted at pet food stores (54%); followed by grocery only stores (18%), department stores (14%), commercial manufacturers (7%), and “other pet food related locations” such as agricultural supply stores (4%). Three of the establishments did not hold refrigerated or frozen pet food onsite. Of the establishments that did hold these products, 84% held refrigerated and 68% held frozen, split almost equally between raw and fully cooked pet food, with some partially cooked. All of the establishments that handled raw products stored them properly.
One of the questions on the risk survey asked who is responsible for the maintenance of coolers or freezers, the answers being mostly the business owner, followed by pet food brand, and other answers such as lease by a food supply company and varying responsibility depending on the unit. Most of the establishments do not keep temperature logs but a few did have some form of temperature log. The establishments were also asked if they had a food safety plan; most said they did have some sort of plan for food safety and how they handle recalls (Table 2). Readings from temperature measuring devices of 58 units were documented with three freezers above 0°F but were within 2°F. One cooler was above proper cold holding temperature of 41°F at 50°F. Two other units did not have temperature measuring devices.
Table 2
The majority of establishments (92%) where products were examined were within their expiration dates with two exceptions. Two establishments had products with no expiration date or lot codes found. All of the products examined had good package integrity with no indication of leaking. At 24 of the establishments, all products examined had some sort of handling instructions on their label, whereas at six establishments, only some products had handling instructions. Some inspectors commented: “none had handling instructions related to human safety” and “safe handling instructions are on all of the frozen pet food. It was not seen on the refrigerated food.”
Conclusions
The research findings suggest that the surveyed agencies have authority over pet food and can inspect retail establishments regardless of the type of product they hold. Nevertheless, pet food retail establishments are a low priority within infrequent inspection rates. Additionally, visits mainly do not consist of facility inspections using current good retail practices (cGRPs) that include such items as verifying proper temperature, approved source, or requiring safe handling instructions. Rather, the visits are for product inspections or collecting samples. As such, only a small percentage of inspectors that regulate these products carry thermometers.
Results indicated that there is a gap in the regulation of pet food. Most agencies have some type of enforcement authority mainly on the products themselves, but a very low percentage can enforce correction of retail facility violations. The fact that refrigerated and frozen pet foods are found in a wide variety of establishments, even in grocery and department stores, could indicate a growing retail trend.
In the cooler and freezer units examined, temperature issues were identified which shows that temperature risk factors should be considered by regulatory agencies. Additionally, this study was conducted in the winter months which could have made mechanical stresses of higher external temperatures less likely. Product packages were in good condition at retail establishments. Furthermore, most of the packages contained some sort handling instructions on the label although comments received from inspectors indicated that the instructions are not consistent nor contain all required information. This inconsistency is an issue because there is no standard to ensure the label explains all risks and advises on how to prevent the risks. As the data shows in this limited study, risk factors were identified in the practice of holding refrigerated and frozen pet food.
Recommendations
Education: Consumer education about the risk of refrigerated and frozen pet food should be considered. AAFCO’s Pet Food Committee while working with all stakeholders should solidify their proposal for standardized requirements on pet food labels that includes an advisory statement and/or safe handling instructions for raw, partially cooked, refrigerated, and frozen pet food product labels. Agencies should adopt AAFCO guidelines once developed, as a requirement. Additional educational campaigns and materials by regulatory agencies should be considered. Agencies should partner with university educators to develop materials for the education of consumers, retailers, manufacturers, and suppliers. One example from a local health agency in Washington is signage at pet food retail establishments required near these products to help educate the consumer on the risks (Title 8 King County Regulations, 2010).
Training: Most raw pet food manufacturers are small businesses and therefore may not be acquainted with or may even be exempt from some food safety regulations. States or AAFCO should develop affordable and accessible training that is targeted and marketed to these small businesses as well as suppliers and retailers. Additionally, animal food regulators could use more training on risk factors and the risk-based approach. Existing training for human food that covers such risks associated with time/temperature control for safety food should be evaluated for applicability to animal food. The developed training for animal food regulators should be added to AAFCO’s recommended training plan for inspectors.
Regulatory Actions: Regulatory agencies should amend their regulations to include authority over retail facilities, not just on the products. Having enforcement authority over the final product is essential to protecting health but this method can be reactive in many ways. Having enforcement authority over a potential contributing factor to product adulteration is needed to prevent the adulteration from happening in the first place. Requiring permits or licenses of all pet food retail establishments may not be practical. Therefore, a voluntary inspection program could be conducted on retail establishments, specifically those that hold refrigerated and frozen pet food. Routine inspections are one of the best ways to educate retail owners and employees and ensure compliance. Animal food regulators are already visiting these locations and since there are not many additional requirements needed, the added time would be insignificant. Additionally, the amount of equipment added for this type of inspection would only involve one thermometer. There should be no fee associated with licensing or permitting and thus not a continued financial burden on the establishments. Fees should only be required if violations are observed which should be an amount that would cover the program’s costs of added time. Model regulation language should be developed by AAFCO. For non-pet food retail establishments such as grocery and department stores that animal food regulators are less likely to visit, the definition of “food” in the FDA Model Food Code should include for the consumption by other animals, especially since there is a human health risk associated.
Acknowledgements
I would like to first thank my program manager, Ali Kashani for allowing me the support to participate in this great experience. I would like to extend my sincere appreciation and thanks to Kathy Fedder, my mentor in the International Food Protection Training Institute (IFPTI) Fellowship Program, as well as Paul Dezendorf, my research mentor for the support, guidance, and understanding throughout the program, and to IFPTI for providing an invaluable education and professional experience. This experience wouldn’t have been as great if it wasn’t for the other Fellows in my cohort. They provided extraordinary support and comradery SGS. I thank the Association of America Feed Control Officials (AAFCO) for assistance with survey distribution and reminders. To all the agencies that submitted surveys and the inspectors that completed risk surveys, I thank you tremendously, as well as all the establishments where surveys were conducted. I would like especially want to thank my significant other and cats for their never-ending support that allowed me the ability to complete the program.
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