In early April, Bravo Packing, Inc., an animal food manufacturing company based in Carney’s Point, N.J., agreed to halt all sales, manufacturing, and distribution of raw pet food to be compliant with the Federal Food, Drug, and Cosmetic Act.
FDA issued a warning letter to Bravo Packing after inspections of its facility in 2019 and 2021 that revealed evidence of significant food safety violations including grossly insanitary conditions and the failure to follow CGMP regulations for animal food. During the inspections, FDA collected samples of finished raw pet food that tested positive for Salmonella, while other samples tested positive for Listeria monocytogenes.
“The food we give our pets should be safe for them to eat and safe for people to handle,” said Steven Solomon, DVM, MPH, director of FDA’s Center for Veterinary Medicine, in a statement. “The FDA has taken this action to protect public health because, despite multiple inspections, notifications of violations, and recalls, this firm continued to operate under insanitary conditions and produce pet food contaminated with harmful bacteria. We will not tolerate firms that put people or animals at risk and will take enforcement actions when needed.”
This was the first example of FDA cracking down on a pet food company for violating standards under the FSMA Preventive Controls for Animal Food, which went into effect in September 2017.
Interestingly, a similar pet food problem was a factor in the creation of FSMA, after a 2007 widespread recall of many brands of cat and dog foods due to contamination with melamine and cyanuric acid.
The melamine pet food recall was a situation in which there was a significant uptick in reports to FDA of unanticipated deaths of both cats and dogs, and as many as 3,600 animal deaths occurred as a result of the contaminated food.
David Acheson, MD, founder and CEO of The Acheson Group, who was associate commissioner for foods at FDA at the time of the recall, says that FDA investigated the claims and learned that many of the pet food manufacturers involved had recently changed their supplier for one of the ingredients—wheat gluten.
“The perpetrators got cheap and started to use cheap melamine, which was contaminated with a breakdown product of melamine called cyanuric acid,” he says. “The quirk to this is that melamine alone isn’t particularly toxic to dogs and cats, and cyanuric acid alone isn’t toxic, but when you put the two together, these molecules formed crystals in the [animals’] kidneys, and they died.”
It took FDA weeks to discover what was happening and an investigation revealed that two China-based businesses were doing this deliberately, and the agency put a stricter regulatory lens on imported products. This led to part of FSMA being much stricter on the requirements on imported food.
“During the development of FSMA, it was clear that protection of animals was completely absent in regulatory authority,” Dr. Acheson says, adding the pet food industry worked with FDA to ensure that it was included, and it forever changed the regulation of pet food.