Accountability and Validation for Pet Food Safety is Everybody’s Job in Our Industry

Written by Dr. Bradley Quest , DVM

If you are associated with the pet food industry or even if you are a savvy pet parent, you have no doubt read about Highly Pathogenic Avian Influenza (HPAI) H5N1, also known as bird flu. We have written extensively about recent outbreaks in birds, cattle and isolated cases in other species such as cats. The current outbreaks in birds and dairy cattle are not new, as H5N1 has been around for a long time; however, what is new is the increased frequency of domestic cats affected. As we’ve discussed previously, of all the domesticated species, cats seem to be the most susceptible to serious illness and even death from H5N1, although dogs can be at risk for illness, too.? In most cases of serious illness or deaths in cats, the source of infection has been traced back to raw dairy products or raw pet food.

The raw and freeze-dried pet food market has been steadily growing for the past several years and has become a notable part of the overall pet food landscape. But “raw” pet food can actually mean many things. Some pet foods claiming to be “raw” are completely unprocessed or uncooked. Other “raw” products are processed either by high pressure, freeze drying, low temperature “gentle cooking,” or even made by mixing uncooked ingredients in with cooked ingredients to make a final product. “Raw” is not an identified regulatory term but is used widely by many different brands and products in the pet food industry as a marketing claim.

The purpose of this article is not to debate the pros or cons of feeding any product with the claim of “raw,” but rather to ensure all products marketed to feed pets are produced using safe manufacturing, testing, and quality control processes—particularly in light of the current H5N1 outbreak. ?

Mitigating the Virus

Recently, we wrote about the pet food manufacturing processes we know will inactivate H5N1 and bacterial pathogens such as Salmonella. These methods include extrusion cooking (kibble), retort cooking (can, trays, and pouches), and baking (biscuits and some treats). These processes will reach temperatures at least 165° F, which is the minimum recommended inactivation temperature for a virus such as H5N1.

Having said this, other processes such as high pressure pasteurization (HPP)—with and without acidification or irradiation—may also be satisfactory to kill pathogens including H5N1. However, these alternative processes have additional dependencies for pathogen control. HPP requires sufficient time and pressure to inactivate the virus. Irradiation requires sufficient time and radiation dosage. The viability of both of those methods is also highly dependent on the amount of virus actually present in the raw meat or dairy product being processed.

Companies can also mitigate pathogen risk by only procuring raw ingredients from sources and states where H5N1 has not been reported in poultry flocks or dairy herds. This still requires other methods, as more and more states have seen reports of affected flocks and herds. Preemptive testing for H5N1 in raw pet food ingredients may also be a potential tool; however, at this time, pet food ingredient testing is not a widespread practice.

No Longer Optional

Within the past few days, the US Food and Drug Administration Center for Veterinary Medicine (FDA-CVM) has recognized that H5N1 is a pathogen that pet food manufacturers need to address similarly to other pathogens, such as Salmonella, in their food safety plans. This means they are required to acknowledge that, if they inventory at-risk? ingredients such as raw poultry, raw meat, raw dairy, or raw egg, they need to have substantiative processes in place to ensure they are producing and distributing a safe product as per the Food Safety Modernization Act Preventative Control for Animal Food (FSMA).

As a pet parent you are probably asking yourself: how does this affect me, my pet, and my pet food buying decisions? Up to now, H5N1 mitigation in pet food was not a required consideration in any given company’s food safety plan. With this FDA-CVM update, it is now officially a pet food safety plan requirement for a manufacturing facility to ensure risk mitigation processes for H5N1 specifically.?

We’ve previously recommended that pet parents contact the manufacturers of pet food products they purchase to ask how they are mitigating H5N1 in their facilities and supply chains. Now, it is actually a requirement of all pet food manufacturers. ?

In previous articles, we have mentioned that more research is needed for evaluating alternative pet food manufacturing processes compared to extrusion, retort cooking, or baking, specifically as it relates to pathogen mitigation. We also believe pet food manufacturers should utilize experts, like those at BSM Partners, when building their food safety plans to help them achieve the best risk mitigation for their particular product. BSM Partners also has experts ready to answer pet parents’ questions about this concerning topic and other pet health matters.?

About the author

Dr. Bradley Quest , DVM is the Principal Veterinarian at BSM Partners. He has practiced clinical veterinary medicine, developed and tested hundreds of pet food and health products, performs extensive animal health research and helps navigate pet food ingredient approval for clients.

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