Posted by: foodbuglady | March 30, 2015

A Birth Announcement

Phyllis Entis, former FoodBugLady, is pleased to announce the birth of her debut novel, THE GREEN PEARL CAPER. Weighing in at thirty-five chapters, and available on as a Kindle ebook, the detective story is the first in a series to feature the adventures of Damien Dickens, Private Investigator.

The story is set in Atlantic City in the summer of 1979 and begins with this Prologue:

I killed Celine. A couple of teenagers found her body last Sunday morning, half-hidden under the Boardwalk, a single bullet hole through her chest. The bullet came from my Smith & Wesson 29, the gun found on the beach not far from where Celine lay.

It wasn’t my finger that pulled the trigger. I wasn’t there when she died. Even so, I killed her. She came to me for help; I had bailed her out of a tight spot in the past, and she trusted me. But, this time, I let her down. I didn’t believe she was really in danger. I screwed up, and Celine paid the price. She was murdered, and it’s my fault.

Celine walked into my office on July 16, 1979. Less than one week later, she was dead.

Posted by: foodbuglady | January 8, 2015

Still Shocked and Saddened

I’m sorry, Susan Thixton, but I don’t buy your arguments ( Let me respond to a few points and then I’ll shut up and allow readers to draw their own conclusions.

1. Let me begin by acknowledging that aflatoxin levels are, indeed, quoted in parts per billion. I should have made that clear. Fumonisins guidelines, on the other hand, are quoted in parts per million. See FDA document 7303.001 for this information.

2. The use of “qualifying pathogens” in the context of this pet food report is out of context with FDA’s purpose in establishing this list. The “qualifying pathogens” list was established in order to establish priorities for encouraging “…the development of new antibacterial and anti fungal drugs for the treatment of serious or life-threatening infections.” The term is not a commentary on the risk to human or animal health posed by these microorganisms when present in the environment or in a food product, whether human or animal.

3. The entire genus Staphylococcus and the entire genus Streptococcus are not qualifying pathogens. Only certain species within these two genera are mentioned in the FDA Final Rule. This is akin to reasoning that because a hawk is a bird and a hawk is a predator, therefore all birds are predators. Just because methicillin-resistant Staphylococcus aureus and vancomycin-resistant Staphylococcus aureus are on the qualifying pathogens list, that does not mean that ALL Staphylococcus are “qualifying pathogens,” even assuming the relevance of the designation to this pet food testing project.

4. In saying that a pathogen such as Acinetobacter is mainly associated with hospital-acquired infections, this does not mean that Acinetobacter is mainly or only found in hospitals. Rather, it means that most infections caused by Acinetobacter are hospital-acquired. Acinetobacter are widely found in the environment, in soil, and even on human skin.

5. I am not disputing the capabilities of Dr. Gary Pusillo as a veterinary nutritionist. Nor have I made any comments on the nutritional testing portion of the study, because veterinary nutrition is outside of my area of expertise, just as microbiology is outside of the expertise of Dr. Pusillo. Similarly, Dr. Purejav’s degrees are in the area of animal science, according to his LinkedIn profile. Would you ask a gastroenterologist to diagnose a neurological problem or read and magnetic resonance images of the brain? Of course not. Why, then, should one expect a veterinary nutritionist and an animal science expert to be the most appropriate individuals to develop, oversee and interpret the results of a microbiology testing program?

6. With all due respect to the reputation and status of Baylor University, the more closely I look at the microbiology findings -especially from the canned foods – the more skeptical I become as to the protocol used during testing. Canned foods should be sterile, with the possible exception of a few spores of highly heat-resistant bacteria. Yet a significant number of the canned food samples were found to contain a long list of microbes that are not especially heat-resistant. It takes special training and equipment and a highly controlled and sterile environment to conduct a reliable microbiology test on a canned food. Contamination of the sample by the lab analyst can occur all too easily. Not all labs are equipped for this level of testing, and not every lab technician or microbiologist has received the necessary training to perform the testing correctly. Baylor’s Microbiology program is housed within its College of Medicine, whereas this type of testing is more commonly taught in a food or pharmaceutical microbiology setting.

7. There is no such thing as searching for “all bacteria” in a food sample. Either a lab is provided with a list of bacteria to search for, or the lab will be asked to isolate and identify as many different bacteria from the sample as possible. Bacteria that are faster or more robust in their growth, or that are present at higher concentrations may outgrow and mask the presence of other bacteria in a sample. If the lab was provided with a list, then that list should have been included in the report.

Finally, Susan, we do not live in a sterile world. There are bacteria in and on just about everything with which we and our pets come into contact. Some of these bacteria are helpful – such as those that ferment milk or those that are used to produce beer or wine; some of them are benign – neither helpful nor harmful in most circumstances. And some – the minority – are pathogens, capable of causing infections in humans or animals. That is the world we live in.

As for the study that you commissioned, I applaud your good intentions. But, in my opinion, the outcome is still junk science.

Posted by: foodbuglady | January 7, 2015

Shocked and Saddened

Dear Readers,

On March 31, 2013, I announced that I was “moving on,” and I ended my daily posts on eFoodAlert. Since then, I have been concentrating on my creative writing projects. Nevertheless, I’ve continued to monitor food safety stories, muttering under my breath from time to time about the quality of some of the coverage. But I have not been motivated to comment publicly on any of these stories until today’s release of a pet food safety study carried out under the auspices of The Association For Truth In Pet Food (ATPF). I decided that I could not let this report stand unchallenged and unanswered.

The Association for Truth In Pet Food (ATPF), headed by Susan Thixton, has just released a report that details the results of mycotoxin, nutrient and bacteria tests carried out on a number of brands of canned and dry cat foods and dog foods. According to James Andrews, writing for Food Safety News, the testing program was sponsored by consumers through crowdfunding and coordinated by ATPF.

Susan Thixton, writing in her blog, describes the results of the study as “shocking and sad.” In my opinion, her adjectives are correct, but misapplied. What I find “shocking and sad” is the waste of consumers’ money in a wild goose chase after low-level pathogens of minimal risk to either humans or their pets.

Consider the “qualifying pathogens” reported in the detailed study:

  • Acinetobacter. This is a low-grade pathogen that is mainly associated with hospital-acquired infections (especially in intensive care units), or with community-spread outbreaks in war zones and natural disaster areas.
  • Pseudomonas. These bacteria are present in the environment, in our water, and in food. It is a cause of “swimmer’s ear.” Otherwise, Pseudomonas is an opportunistic pathogen, typically either hospital-acquired or affecting individuals with compromised immune systems or respiratory systems, such as cystic fibrosis patients.
  • Streptococcus. While some species of Streptococcus are pathogenic (eg., Streptococcus pyogenes), others are benign. Some species of Streptococcus are used in the production of fermented dairy products, and are considered to be probiotic.
  • Staphylococcus. While Staphylococcus aureus is associated with food poisoning (via its production of enterotoxins), and with infections, other species of Staphylococcus are either benign or are low-grade pathogens associated with hospital-acquired infections. Staphylococcus epidermidis is a common inhabitant of the skin of humans and animals. Even Staphylococcus aureus is carried on the skin and in the nasal passages of many individuals.
  • Bacillus. Most species of Bacillus are benign and are widely dispersed in the environment. Bacillus is a spore-former and very heat-resistant. It can be found with great frequency in dried foods, including spices, flour, and powdered dairy products. Bacillus cereus is a source of foodborne illness, but it must attain high concentrations before it can cause illness.

In addition to these “qualifying pathogens,” the study organizers decided to troll through the foods for a long list of other irrelevant microbes, including: Anaerococcus, Comamonadaceae, Corynebacteriaceae, Halomonas (another low-risk pathogen associated with contamination of intravenous lines), Cloacibacterium, Bifidobacterium (a probiotic), Pantoea, Gemella, Peptoniphilus, Actinomyces, Sphingobium, Bradyrhizobium, Tumebacillus, Paracoccus, Paenibacillus, Lactococcus, Acetobacter, Chloroplast, and Lactobacillus (a probiotic).

The author of the study provided absolutely no rationale for this selection. Nor was any explanation offered for excluding known human and animal pathogens, such as Salmonella and Campylobacter, from the list. Where was the logic in this? What was the point in throwing money at a laundry list of irrelevant microbes? The funding did not allow species-level identification of any of the bacteria, according to the study report. Yet, without species-level identification, the results of the bacterial testing of the pet foods are worthless.

I also take issue with the presentation of the mycotoxin test results. The results are reported at levels of parts per billion (PPB), whereas these results are usually reported as parts per million (ppm) . By changing the manner of reporting the results, the study makes the data appear more shocking. For example, FDA recommends a limit of 10ppm for fumonisins in grain destined for pet food. This is the same as saying10,000 parts per billion. Even the worst performing pet food sample was well within this guidance level. Furthermore, the comparison table presents an arbitrary set of risk values generated using a proprietary formula developed by Alltech, an animal nutrition company. There is no way to substantiate the validity or the significance of these so-called risk levels.

I have refrained from commenting on the portion of the report dealing with nutritional analysis, as this is outside of my expertise. I sincerely hope that someone else will put this portion of the report under a microscope.

I acknowledge the good intentions of Susan Thixton and the Association for Truth in Pet Food, but I am appalled at the way in which this study was designed and carried out. The portions of the study relating to bacterial analysis and presentation of the mycotoxin results are the epitome of junk science. The pet-loving consumers who funded this study – and their dogs and cats – deserved far better.

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