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FDA did a data dump today. The agency has made available for download the results of 5 1/2 years worth of pet treat lab analyses.

This unprecedented release of (relatively) raw lab data by FDA comes on the heels of JoNel Aleccia’s July 13th article on the more than 1,000 pet illnesses and deaths being blamed on chicken jerky pet treats.

When eFoodAlert last contacted FDA’s Center for Veterinary Medicine on this subject in February 2012, the level of frustration felt by the agency was clear in the response we received from FDA Spokeswoman Laura Alvey.

Testing continues and is ongoing,” Alvey said back then in reply to my questions. “We have tested samples from all over the country.”

Among the tests Alvey mentioned were Salmonella, and chemical toxicants such as melamine, melamine analogs and diethylene glycol. Alvey explained that FDA’s regulatory hands were tied until its scientists could detect a contaminant and demonstrate that a product was adulterated. “The regulations don’t allow for products to be removed based on complaints,” she emphasized.

It’s clear from today’s data dump that FDA has not made any further progress in solving the mystery. In my opinion, the absence of progress is due to two factors – lack of resources dedicated to researching the problem, and lack of a systematic approach to the problem.

Since November 18, 2011, FDA’s various District Offices have collected and analyzed a total of 48 samples of various brands and varieties of pet jerky treats in six district and regional FDA labs. That’s roughly one sample per lab per month. Twelve of the samples were tested for Salmonella; 30 were analyzed for the presence of ethylene glycol, diethylene glycol and/or propylene glycol; 12 were examined for melamine and cyanuric acid. An occasional sample was also examined for other microbial or chemical contaminants. Some samples were analyzed for multiple microbiological and chemical contaminants; others were subjected just one microbiological or chemical test.

In fairness, the data released today by FDA may not be complete. They include only those product samples for which the word “Jerky” appeared on the product label or in the product description. A product labeled simply as a “Pet Treat” or “Pet Chew” would not be part of these data.

There is no way to tell what motivated the selection of tests to be run on a given sample; that information is not included in the data dump. Nor do we know why these samples were collected. Were they part of routine surveillance? Were they the result of a consumer complaint or “adverse event” report? Were they taken during a pet food production plant inspection? This information, too, is lacking.

So far, all of the tests results have been negative, except for the finding of undeclared propylene glycol in twelve samples. Propylene glycol is on FDA’s Generally Recognized As Safe (GRAS) list of food chemicals and ingredients, both for human and animal consumption. Thus, even though the ingredient was not listed on the package label, no regulatory action was “indicated” according to FDA.

Propylene glycol is a humectant – it keeps a food soft, moist and chewy. It also is an antifreeze, although it is far less toxic than other common antifreezes, namely, ethylene glycol and diethylene glycol. But propylene glycol, at certain exposure levels, can be toxic to dogs and cats. And I have not been able to find any studies that evaluate the effect of propylene glycol in combination with other possible pet food ingredients.

Furthermore, has anyone at FDA thought to examine the chemical reactions involving propylene glycol that may take place during the manufacture of pet treats? Dow Chemical lists several reactions that could occur under favorable conditions of heat and oxidation. Has anyone investigated the effects of irradiation on propylene glycol? Some manufacturers irradiate their pet treats to ensure microbiological safety. There are, no doubt, several possible avenues of research here.

Come on, FDA! It’s time to pause, breathe, and start thinking outside the treat bag.

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