Dogged Blog

FDA gets sued for mandatory recall

If like me you hailed the FDA's new power to force a recall on contaminated food for humans and pets as marking a revolution in food safety, you might want to hold off before throwing the confetti.

From food safety watchdog Marion Nestle -- pretty much the only human health writer who understood the implications of the 2007  pet food recall -- at her Food Politics blog, news that Del Monte is suing the FDA and the state of Oregon for a recall the agency ordered last March. You can review the testing epidemiology and details of the lawsuits in her post, but if nothing else, take her warning to heart:

Public health agencies doing their jobs to protect the public now have to defend against lawsuits like this?  Putative cause is no longer enough to order recalls?

U.S. courts are not famous for understanding epidemiology or other aspects of public health and I’m wondering what effect this suit will have on public protection against foodborne illness.  What standard of proof will the courts require?

Lawsuits are chilling.  Congress has just granted the FDA the authority to order recalls.  Food producers were not happy about that provision.  This is one way to get around Congress and the FDA.

Read the rest here. Then, you know, weep and rend your garments and stuff. Because the FDA is already a timid agency, and the last thing they need is additional chilling.

Photo: Marion Nestle, right, and me in San Francisco in 2009.

Senate strikes compromise deal on food safety

The House of Representatives passed a food safety reform bill back in July of 2009, but  the Food Safety Modernization Act stalled in the Senate. Today, the Senate Health Panel announced a bipartisan compromise on the bill had been reached, although no date for actually voting on the bill has been set.



The compromise doesn't address Sen. Dianne Feinstein's (D-Calif.) desire for the new law to ban bisphenol-A (BPA) from food and beverage containers, nor does it exempt small farmers and those who sell at farmers'  markets from its provisions as sought by Sen. Jon Tester (D-Mont.).



It does, however, include mandatory recall authority for the FDA as well as increased ability to inspect facilities where food is handled and the records of food manufacturers.



And, presumably thanks to the thousands of pets sickened and killed by the 2007 melamine contamination of dog and cat food, the AP reports it would also " require importers to verify the safety of their foreign suppliers and would require businesses that manufacture and process food to have in place plans to prevent adulteration."



From TheHill.com:

The compromise was worked out between six senators who have been working on the issue: Health, Education, Labor and Pensions (HELP) Committee Chairman Tom Harkin (D-Iowa) and ranking member Mike Enzi (R-Wyo.); food-safety bill authors Dick Durbin (D-Ill.) and Judd Gregg (R-N.H.); and lead co-sponsors Chris Dodd (D-Conn.) and Richard Burr (R-N.C.).



[....]



"Any 100-year-old-plus structure — like our nation’s food safety system — needs improvements," the six lawmakers said in a statement.



"With this announcement today, we aim to not just patch and mend our fragmented food safety system, we hope to reinforce the infrastructure, close the gaps and create a systematic, risk-based and balanced approach to food safety in the United States.



"The FDA Food Safety Modernization Act will place more emphasis on prevention of food-borne illness and will provide new tools to respond to food-safety problems. We look forward to working with our respective leaderships to take up this bipartisan legislation as soon as possible."

Some additional background here from Pet Connection BFF Marion Nestle.

Feline ' s Pride expands recall

Via the ever-alert Therese Kopiwoda at PetSitUSA.com, an FDA notice that Feline's Pride has expanded their earlier recall:

Feline’s Pride is expanding its July 1, 2010 voluntary recall of Feline’s Pride Raw food with ground bone for cats and kittens, Natural Chicken Formula, Net Wt. 2.5 lbs. (1.13 kg., 40 oz.) produced on 6/10/10 to include the product produced on 6/21/10, because it may be contaminated with Salmonella. People handling raw pet food can become infected with Salmonella, especially if they have not thoroughly washed their hands after having contact with the raw pet food or any surfaces exposed to the product.



When consumed by humans, Salmonella can cause an infection, salmonellosis. The symptoms of salmonellosis include nausea, vomiting, abdominal cramps, minimal diarrhea, fever, and headache. Certain vulnerable populations, such as children, the elderly, and individuals with compromised immune systems, are particularly susceptible to acquiring salmonellosis from such pet food products and may experience more severe symptoms.



Pets with Salmonella infections may be lethargic and have diarrhea or bloody diarrhea, fever, and vomiting. Some pets will have only decreased appetite, fever and abdominal pain. Infected but otherwise healthy pets can be carriers and infect other animals or humans. If your pet has consumed the recalled product and has these symptoms, please contact your veterinarian.



The product is packaged in plastic containers and sold frozen to private consumers nationwide. Once thawed, the pet food has a shelf life of about 1 week. The firm manufactures the pet food by an as-ordered basis. This expansion of the recall affects those orders placed and shipped from June 21 through June 26, 2010 (produced on 6/21/10).

You can read the full release here on the FDA website, because it's still not on the Feline Pride site. Fail.

On a YouTube channel near you: The FDA ' s ' Melamine Story '

The FDA's take on the history of the 2007 pet food recall is on  their YouTube channel (no, really, they have one) now:







Their description:

In 2007, pet food that was contaminated with melamine and related  compounds made many pets sick. At first, no one knew what caused the  problem. An intense and sophisticated search for the cause was begun. In  many ways, the work done by scientists in government and the pet food  industry was groundbreaking. In this video, Dr. Renate Reimschuessel of  the Food and Drug Administration explains what it took to uncover and  confirm the presence of the adulterants in pet food.

Check it out, and see how it matches with how you lived it...

Proctor & Gamble recall Iams canned cat foods

Proctor & Gamble announced a recall of all varieties of Iams ProActive Health canned Cat and Kitten Food in 3 oz and 5.5 oz cans, dated 09/2011 to 06/2012 on the bottom of the can:

Diagnostic testing indicated that the product may contain insufficient levels of thiamine (Vitamin B1), which is essential for cats.  Cats that were fed these canned products as their only food are at greater risk for developing signs of thiamine deficiency.



[....]



Early signs of thiamine deficiency may include loss of appetite, salivation, vomiting and weight loss.  In advanced cases, signs may include ventroflexion (downward curving) of the neck, wobbly gait, falling, circling and seizures.  Contact your veterinarian immediately if your cat is displaying any of these signs.  If treated promptly, thiamine deficiency is typically reversible.



Consumers who have purchased canned cat food with these codes should discard it.  For further information or a product refund call P&G toll-free at 877-340-8826 (Monday - Friday, 9:00 AM to 7:00 PM EST).

Interesting that last fall, Diamond cat foods were recalled for problems with thiamine levels. Unlike that recall, however, P&G actually used the word "recall" and linked to the announcement from the front page of their website.



And worth noting, P&G was the company who had good enough product tracking systems in place to identify the problem with Menu Foods in 2007, and enough care for their brand to tell Menu to announce a recall or they'd do it without them.



And they didn't announce the recall on Friday at midnight after it had been rumored around the Interwebz for a week, either.



Still gotta wonder, are they using the same vitamin mix source as the earlier Diamond recall? If so, how did this happen again? And if not, what's going on with the vitamin mixes?



Many questions, to which we'll hopefully get some answers now that this has happened again.



Gina update: I was at the local Target when Iams contacted us. Buying cat litter, in fact. I walked down the aisle took a picture of the product on the shelves. And yes, I told them it was recalled. I wonder if I can get the same picture tomorrow?

Congressional report: Fix our broken food safety system yesterday

Breaking news: Government report says our food safety system is broken.



Okay, this is only "breaking" if you're, I don't know, a mole in the deep dark tunnels of Washington, DC, or something. It seems to be the exact same conclusion reached by every thoughtful observer since 2007, including us lowly pet bloggers here on Pet Connection.



But anyway, it's official now. From a U.S. News and World Report story on a Congressional report issued yesterday by the Institute of Medicine (IOM) and the National Research Council:

The U.S. Food and Drug Administration (FDA) isn't equipped to handle problems with the food supply and is in need of a major revamping....  Among other things, the report recommends giving the FDA authority to issue mandatory recall of food products and to delegate responsibility for inspections to states, which already handle about 60 percent of this task.



"The agency's approach now is too reactive and lacks a systematic focus on prevention," Dr. Robert Wallace, chairman of the committee that prepared the report and professor of epidemiology and internal medicine at the University of Iowa College of Public Health, said at a Tuesday news conference. "The time has come to modernize the FDA's food safety program focusing on the development of an integrated, risk-based system."



A leading consumer group applauded the report.



"A distinguished panel of experts has concluded that FDA has neither the resources nor the powers it needs to keep our food safe," Jean Halloran, director of food policy initiatives at Consumers Union, said in a prepared statement. "The report recommends that Congress act to give FDA the power to order recalls of tainted food, which amazingly, it still lacks. The report further urges that Congress require all food processors to register with the FDA, to act proactively to prevent foodborne illness, and tell the FDA when they discover adulterated products. FDA needs all these powers as well as a mandate to inspect high-risk processors at least annually. While the House passed a bill last July that would give FDA much of what it needs, the reform legislation remains stalled in the Senate. The time is now for Congress to act."

The time was three years ago for Congress to act. I'm just saying.



Another change recommended in the report: a single agency overseeing food safety, instead of the weird, dysfunctional, patchwork USDA-FDA buddy system that is, hello, not working. (Okay, that's a paraphrase.)



I'm glad to see the report. I'm glad to see the FDA issued a statement agreeing with it and its conclusions. I'm glad the House, if not the Senate, has passed a food safety bill, and I'm glad that this report might push the Senate to act soon.



But I'm tired tired tired that we're still needing reports to fix a problem that anyone with a brain and a cat identified years ago.

Talking about pet food at Chez Panisse

Sometimes being a pet writer kind of sucks, because when a girl's out with a bunch of other journalists, well... we don't get no respect.



But sometimes we get to eat at Chez Panisse. That's what happened to me when I interviewed Marion Nestle and Mal Nesheim about their new book -- "Feed Your Pet Right" (Simon and Schuster Free Press, May 2010) -- over one of the best lunches I've ever had -- goat cheese salad and a beautiful Moroccan chicken from Soul Food Farms.



And cherries and cappuccino for dessert. I mean, this is why I went to journalism school.



The fact that we had a fantastic free-range discussion of "Feed Your Pet Right," their experience researching it, and some of the aftermath of its publication was just  the (totally organic) icing on the (sustainably produced) cake.



Marion told me this book was originally supposed to be a chapter in her book "What to Eat," which took shoppers on a tour of a supermarket's aisles and helped them understand food labels, health claims and, well... what to eat.



But the book was already getting too long, so the chapter didn't make it. And it was a good thing, too, because when Marion looked at the labels on the pet food in the grocery store, her Ph.D. in human nutrition was absolutely no help to her in understanding them. For that, she turned to her partner, Mal Nesheim, who has a Ph.D. in animal nutrition. From my column today in the San Francisco Chronicle/SFGate.com:

If it strikes anyone as odd that even a Ph.D. human nutritionist had to consult a Ph.D. animal nutritionist to understand a pet food label, there's a reason for that. "Compared to the human food industry, the pet food industry is is much, much less transparent," Nestle says. "They are awash in secrecy."



She adds, "It's an enormously profitable business with no organized consumer base in the way that you have with human food. After all, their food is fed to dogs and cats, who can't pick up the telephone and call the companies."



Most pet owners, Nestle says, are no more able than she was to understand a pet food label.



"They don't know what the whole 'complete and balanced" thing means, or what most of the information on the label means," she says. "It's all inexplicable to them."



That's not all, Nesheim says. "There are all these products out there, and pet owners don't realize just how many of them are being made by the same companies, but sold under different brand names. Nestle, Purina, Mars -- these companies make dozens and dozens of brands, and the lists of ingredients are just not that different from each other -- although the prices, and the marketing campaigns, often are."



The lack of transparency made "Feed Your Pet Right" a much harder book to research than its human counterpart. For instance, many pet food manufacturers refused to let them into their facilities.



"Although the ones that let us in were all right," says Nesheim. "Hills, Bravo -- they impressed us. The Waltham plant in England (owned by Mars) was wonderful. The dogs spend their days interacting with the staff, and there are people on the payroll whose entire job is to play with and walk the dogs."



I ask if he assumed the companies that wouldn't let them in -- which included Purina and Procter and Gamble -- had something to hide. "Either that, or they were afraid of animal rights groups," he says. "There are lots of questions being asked about animal testing, including on pet food, and I think a lot of them are frightened of that."

Read it here -- including what they think about home-prepared and raw diets.



Photo: Marion Nestle and Mal Nesheim at Chez Panisse.

FDA, NIH launch food safety reporting site -- pets included

The FDA and National Institutes of Health (NIH) rolled out their food safety reporting portal yesterday. And just like the Ark, the animals were on board.



The new website allows consumers, veterinarians as well as members of industry, government or the human public health system to report food safety problems, as well as problems with animal drugs.  In fact, it implies it's our patriotic duty to do so:

The Safety Reporting Portal (SRP) streamlines the process of reporting product safety issues to the Food & Drug Administration (FDA) and the National Institutes of Health (NIH).



Whatever your role, (manufacturer, health care professional, researcher, public health official, or concerned citizen), when you submit a safety report through this Portal, you make a vital contribution to the safety of America's food supply, medicines, and other products that touch us all.

I honestly have no idea if this is going to improve food and drug safety in the United States. But I have to say that not only the fact that food and drugs for animals are included in such a matter-of-fact way, but that the connection of the human and animal food systems is clearly acknowledged, is encouraging.



Go kick it around, tell us what you think!

Liveblogging Marion Nestle and Mal Nesheim in San Francisco

I'm at Omnivore Books in San Francisco, liveblogging Marion Nestle and Mal Nesheim's reading of their new book, "Feed Your Pet Right."



Reminder about liveblogging: This is really live, so there will be typos. Only things in quotation marks are direct quotes; everything else is a paraphrase or close approximation. I'll come back later and add links.



I've also created a Twitter hashtag for the event, #feedyourpet. You can watch that for my Tweets and probably other people's, too.



This is being done in real-time, so hit refresh to see the newest material. When I'm done I'll go back and tuck this all behind a jump, so as not to mess up the blog.



Here we go!







Marion starts out talking about her book on what humans eat, "What to Eat," and how it wasn't really about what to eat, but how to think about what to eat. She said she did a lot her research in supermarkets, going aisle by aisle, trying to answer any question she could think of about the products.



As she'd walk through the store she'd see the pet food aisle, 120 feet long, dog food on one side, cat food on the other, shelves 6-7 feet high. Astonishing amount of real estate in the stores.



Foods are not in markets by accident -- manufacturers pay to be in stores. And she was astounded at how much money must be represented by that amount of real estate.



Said she'd pick up bags and cans and pouches and couldn't understand the labels. What are these ingredients? What is the guaranteed analysis?



Her partner Mal Nesheim had taught animal nutrition at Cornell and he understood them and explained them, and she decided to do a chapter on pet food in "What to Eat." But the book was already extremely long so that didn't happen.



She said she asked Mal to write a book on pet food with her, and they figured out it wouldn't destroy their relationship. (Laughter.)



Signed book deal in Feb of 2007 -- then came the pet food recall.



That shocked them. They had no idea one company in Canada was making 70+ brands of pet food. Said the pet food recall opened up lines of research they would never have thought about without the recall.



It's very hard to study food in an academic way -- even human food. NYU, where she teaches, is one of the few places. But writing about pet food takes even more explaining, but the pet food recall somewhat changed that. "If pet food was suffering from a gap in our food safety system like this, then the food safety system in our country was in real trouble.... and this was even before the spinach recalls."



Said it turned out pet food manufacturers didn't even know what was in their products. And pet food, human food and animal feed are tightly linked, as pet and animal foods "soak up" the leftovers of human food production.



They ended up writing about things that interested them. A real curiosity about pet food.



Their first question was, "Is commercial pet food any good and can it be trusted?" Which is basically what the book is about. What do the labels mean, how do you decode them? What do premium, natural, organic mean for pet food? What about health claims? How do you tell how much your pet should be eating? Vegetarian, vegan, grains, raw, cooked? Should I believe my vet's advice about what foods to buy?



Set out to answer those questions.



Using Google Books and libraries, looked at what pets ate before commercial pet food.



Reading from that section:



"Mice are an excellent source of nutrition for cats." Dogs did well on varied diets of leftovers of human food. Plus, dog owners and breeders understood that their animals' diets needed to follow basic principles.



1858 guide to dog care pointed out that while wolves ate meat, and natural food of the dog is flesh, but said most dogs should eat oatmeal with offal, leftovers, and milk. Also, liver and horsemeat.



1850 book recommended veggies like carrots and cabbage. Kennels fed a lot of oatmeal and horsemeat.



In 1900 a how-to book about dog health recommended sheep heads, meat and "coarse scotch oatmeal." Also bones, which are "of great value to him." "One should always be allowed at least once or twice a week."



Great relationship with a butcher assumed.



She reads recipe for puppy diet with sheep's head. She said it would be very nutritious but "seems rather inconvenient for the modern kitchen."



Pet food industry as we now know it began early 20th century.



Mal takes over reading. "Marion didn't exactly have to twist my arm to write this book." PhD in animal nutrition at Cornell. Taught courses in nutrition to veterinary students. Is not a veterinarian.



Then he got into human nutrition which is how he got to know Marion. "But that's another story altogether." (laughter)



Went to many meetings, including Global Pet Expo in San Diego, 11 football fields of pet products. And went to Pet Food Forum. Tried to visit as many pet food manufacturers as possible.



Hills allowed him to go to Topeka plant and research facilities. They were very helpful.



Purina "wouldn't let us near the place." "We did go to an open cat nutrition meeting they had that honored Quinton Rogers, who I've known for many years."



Proctor and Gamble also "wouldn't let us near the place."  A testing facility near Ithaca wouldn't let them in, either.



Were able to go to Mars' Waltham facilities in England. Marvelous, modern, pets well taken care of, people whose job is just to play with the pets.



Began to write and talked about, as Marion said, all these issues about what they need, what's in the food. And about veterinarians, their relationship to the pet food industry, and how pet food companies try to influence veterinarians, and how there is little research and much of it is not made public.



He's reading "Conclusion" chapter:



Had not known pets formed corner of US economy that accounted for 17-18 billion dollars. Until melamine recalls, had not realized how tightly pet food and people food industries were linked. Believe that, coupled with how people treasure our pets, make this an area deserving of research.



"No one method is best for feeding dogs and cats."  Like people, they can flourish on a wide variety of diets. "It's extremely difficult to induce a nutritional deficiency in an animal or person eating a sufficient variety of foods."



"The way you feed your pets should match the kind of dietary preferences and beliefs you have. If this surprises you, it's because no one would ever know it from surveying books on this subject." Most believe only in commercial pet food or only raw or only home cooked or only some alternative. People don't eat that way and pets don't need to, either. "Any of these methods, singly or together, are good ways to feed pets."



Someone asked how to deal with feeding variety causing diarrhea or throwing up.



(Note from Christie: I have something to say about that, LOL.)



Mal said: Find what works for your pet. Talked about how how different foods affect stool.



Question about pet food recall. What regulatory changes occurred, and is there consumer group overseeing the pet food industry?



Marion said, "Significant reform is an oxymoron." There were some reforms right after, "but there has been backsliding." FDA's Center for Veterinary Medicine oversees pet food, a little known and under-funded branch of FDA. They mean well but their hands are tied. FDA has no budget. Pass the Food Act!



Congress passed a law but it was all voluntary. (Rolled her eyes.)



"Industry is fond of saying pet food is better regulated than human food, but we don't believe it. Or as we say, we have our doubts."



Thinks animal, human and pet food should be regulated together. And FDA is looking at that, also changing labels on pet foods.



Question about cancer in pets.



Marion said they wanted to know if pet health is better now than in past, or pets being fed all different kinds of diets... "There is no comparative data at all. These studies simply do not exist."



They can't find data on longevity, either.



Question: Where did the grain-free "fad" come from?



Mal: Melamine was in wheat gluten, so that's part of it. Corn has gotten a bad name -- Michael Pollan gave corn a bad name. (Laughter.)



Look at the foods that are "grain-free," they have other starches. There is no evidence that these forms of starches are any better or even different than starches from grains.



Question about "prescription diets." And if you ask the vet for a home cooked diet that can do the same thing, they say no. Can you talk about that?



Marion: Talked about how similar the ingredient lists of all these foods really are, and then said that they read "Small Animal Clinical Nutrition," which goes on and on and on about how you must never feed a homemade diet and it's so hard no one could do it, and then they give these recipes that are so simple anyone could do it.



"They either think dog and cat owners are stupid, or that no one knows how to cook. But it couldn't be easier."



Mal said that Mark Morris of Hills did do good research on kidney diets, and "there is some research that dogs that are fed these diets may live a little longer." (Dogs with kidney disease.) One problem, he says, is that dogs don't like it and won't eat it.



But he says there is not necessarily research behind all the prescription foods. "You go to a doctor and they give you a sugar pill, and you go to a veterinarian and they give you a prescription diet."



Audience member asked, "Are you having problems with raw food people who are like scientologists?"



Marion laughed and said, "I don't want to go there." Talked about how a lot of raw food people are not happy with them, even though they say it's fine to feed raw. Says that she was honestly surprised that raw diet people think they are against them, and says they are not.



Question: Are we still using ingredients from China?



Marion: Vitamin mixes.



Mal: Some pet food are imported from China. And lots and lots of treats.



Marion: "Pet Food Politics" came out in spring of 2008, and six months later, melamine turned up in infant formula. "So beyond the pale." And they're still doing it. Subtitle of book was "Chihuahua in the Coal Mine," so looks like I was right.



Marion: "The nutrients in minimally processed foods are always best. With pet foods, that means you're cooking -- or NOT cooking -- for your pet." Or buying some of the minimally processed raw or cooked foods that are a specialty market.



Mal: A lot of people just want to tear open a bag of kibble and pour it in a bowl, but others have different things that are important to them.



Audience member: Not all raw feeders have a problem with you. They were talking about this event on the SF Raw list today and saying really nice things.



Marion: Tell them thank you!



Audience member: Advice on buying commercial foods:



Mal: We prefer foods that have been fed in feeding trials, not just meeting AAFCO nutrient profiles. "The melamine problem was discovered because a manufacturer fed it to an animal." "Feeding trials are not perfect but they're better."



After a discussion of the ethics of feeding trials, which is handled extensively in the book, it was a wrap.

Ready, fire, aim: Delta misses with dogmatic decision

I've been trying to pretend the Delta Society, the nation's leading therapy dog organization, hadn't just issued a ban on participation by dogs fed a raw diet. Because honestly, after 24 years of feeding raw meat, eggs and dairy products to my dogs and cats with not a single food-borne illness or nutritional problem, I'm just plain tired of this debate.



And it's not like I haven't written about this topic before.



The person who pried my head out of the sand on this was my longtime friend Lew Olson, who owns and founded the K-9 Nutrition e-mail list. Lew assembled an encyclopedic list of links on the subject of pathogenic bacteria and raw foods. Some of them address the issue of widespread contamination of processed foods, primarily kibble, which will come as no surprise to anyone here. Others have to do with the fact that most dogs and cats who carry salmonella have no symptoms of it -- which is actually a bit off the point of Delta's concern, but interesting.



She even had some studies on humans transmitting salmonella to dogs. Go figure.



But without question, this Powerpoint presentation was my favorite of her links. It's a slideshow from the University of Guelph in Canada, purporting to show how scary raw diets are from a deadly pathogen point of view. I have to wonder if they even looked at their own data, though, because, well... you look at it:

Raw fed dogs (40)	Dry food fed dogs (156)
0 for Vanomycin resistant enterococci 1 for Methicillin resistant S Aureus 5  for Clostridium difficile 19 for Salmonella 31 for E Coli	1 for Vanomycin resistant enterococci 8 for Methicillin resistant S Aureus 40 for Clostridium difficile 12  for salmonella 32 for E Coli

Sure, the raw fed dogs have higher counts of salmonella and e. coli, and their numbers are lower so that's even more significant. But MRSA, clostridium, and vancomycin-resistant enterococci are higher in the kibble-fed dogs.



And obviously, perfectly healthy dogs, raw-fed or kibble-fed, can have salmonella and other pathogenic bacteria in their systems.



Now, I know the raw feeding movement is hard for a lot of people to understand. I know that veterinarians are concerned about food safety (although I wish they'd be concerned enough to get their colleagues in large animal practice to get the poop out of the food supply in the first place instead of haranguing us about the food we prepare in our own kitchens, but I digress), and I know that plenty of people with therapy dogs figure that it's better to be safer than sorry and the raw feeders should just take one for the team.



But does the Delta Society, which has fought so hard to get access for therapy dogs to people in hospitals and nursing homes, really want to go down this path? Selectively counting cooties in the dogs' poop?



Do they honestly believe a living creature, let alone one that regularly licks its own butt, is ever going to be sterile?



As Lew said:

My concern is that, in your hurry to label the raw diet as the culprit, and eliminate its use by your volunteers in your program, you are only putting the spotlight on the issue that all dogs can carry pathogens regardless of diet. This could cause all dogs to be banned from any health facility. In essence, I see your new rule as shooting yourself in the foot.  Salmonella is everywhere, including dry dog food, the soil, pond water and even in humans. You are looking at narrow parameters that need a more careful and extensive study on how pathogens are spread and how to use sensible and effective precautions to prevent the spread of disease-causing microbes and parasites.



[That would include] bathing the dogs, insuring therapy dogs are flea and tick free, making sure the dogs are properly exercised (ie pottied) before a visit, and carrying sterilization equipment (bleach, bags and paper towels) in case of an accident.



All research points out pathogens are spread by stool or saliva. That would mean not allowing the dogs to lick the clients, making sure the coats and skin are recently bathed and trusting your volunteers.



Your volunteers are the backbone of your organization, and they do this loving volunteer work without compensation and give the Delta group thousands of volunteer hours. I hope you take this email in the light it was written, in that sometimes, we need to look at any situation with more study and thought, and understand the healing, joy and encouragement dogs give so many people. Being a patient with serious illness and being away from home often stifles recovery. Pets, as you know, bring hope, happiness and support to begin the process of healing.



I hope you rethink your position on this matter, and continue to allow your therapy dog work to bring joy to both your clients and your volunteers.

Of course, Delta can have any rules or requirements they wish; they're a private organization. But what troubles me is the focus not on outbreaks of pet or human illness but on simple bacterial counts.



When I wrote the post about "poop on the food" I linked to above, it was because I saw a vet conference presentation on the impossibility of safely cleaning the bowls used to feed raw meats to our dogs. It seems that research has shown that not even running them through the sanitize cycle of the dishwasher, can remove all bacteria from the dishes.



I asked then, as I ask now, "Then how can I ever make a meatloaf or marinate a chicken?" But I also have to ask this question: So what?



Are the bacterial levels on a dog bowl or mixing dish that once held raw meat or eggs. or the traces left behind on the carpets or other surfaces of a nursing home after the visit of a raw-fed dog, likely to cause any kind of disease outbreak? In other words, yes, the bacteria are there; are they dangerous? Or just present?



Does the presence of dogs who eat raw diets increase the risk of disease or harm over that of dogs who eat kibble (and lick their behinds)?



Can we actually look at that question before banning these trained dogs and their dedicated owners from this valuable and respected program?



Photo: My Deerhound Lillie, who lived to the ripe old age of 12 and a half, outliving all her kibble-fed littermates, while eating a raw diet, drinking out of streams and licking her butt.