Today I’m so excited to be joined by the one and only Susan Thixton. She’s the creator of the website The Truth About Pet Food, and she runs the Consumer Association for Truth In Pet Food, which holds advisory positions on two AFCO Committees, the Pet Food Committee, and The Ingredient Definitions Committee.
Amanda: I’m really excited to talk about all of this! Tell us a little bit about yourself. How did you get started and how did you become “The Caped Crusader for Safe Pet Food”?
Susan: Well, it’s a sad story, and I’m going to tell you how I got started. It was 25- 26 years ago, and a dog of mine almost overnight had a tumor pop up on her pelvic bone. This dog was my soulmate. I mean, we just had mutual worship. I take her to my vet, who that vet back then knew more about pet food than most vets do today told me that this was bone cancer, that I had a couple of weeks to tell her goodbye. He said it was caused by a chemical preservative in the pet food.
It was used to extend the shelf life. At that time I really didn’t even know what shelf life was, didn’t understand really what it meant, and I called the pet food company, the largest in the US, and I asked them, that was my first call to a pet food company, asked them what the shelf life was for this dog food. They very proudly told me the food would stay fresh for 25 years.
S: That moment changed my life. It was devastating to me to lose her and the thought of me giving her the food that caused her cancer. It just changed me. From that moment on, my vet at that time gave me the nutrition books that he had, and then, this is really dating myself, this was pre-internet, so later with the invention of the internet, you can access almost anything online. So then I had friends dare me to start the website, and I did, and here we are today.
A: What an amazing journey. I mean it’s such an unfortunate beginning into it, but obviously, she was your inspiration, and she came to you for a reason, to start you on this journey to help thousands, hundreds of thousands of other pets.
S: She’s with me today. I know she is. She I guess gave her life so that it would nudge me to help others.
A: So let’s talk a little bit about how pet food is regulated in the States and why there are some potential shortcomings with that regulation.
S: Pet food is regulated on two levels, on a federal level by the FDA and on a state-by-state level by each State Department of Agriculture. That would make you think wow, federal law and state law, it’s safe. It’s highly regulated. But that is not the case. There are laws. The laws that should regulate pet food on a federal level are the Federal Food, Drug and Cosmetic Act and in that act, those set of laws, it directly says a diseased animal or an animal that has died otherwise than by slaughter is a violation of the law.
They’re adulterated, and they cannot be used in any food. But the FDA right on the FDA website says, blatantly say, well no, we’re not going to enforce that law so diseased animals and non-slaughtered animals, and an example of a non-slaughtered animal is a cow that dies in the field, it laid there for three days. A truck comes and picks it up. They take that decomposing animal carcass, grind it up and put it in pet food.
The FDA blatantly says these things, we’re going to allow it even though it is a direct violation of the law. The states do the exact same thing. There are 14/ 15 states that have state law specific animal feed, cattle feed, pet food all fall under the umbrella of animal feed, that say the same thing, but it’s specific animal feed.
Florida, my state, is one of those states. Florida will not enforce the law. I had a meeting with Florida several years ago, and I recorded it. In the state of Florida, you can record a state authority without their knowledge, and this person from the Florida Department of Agriculture kept saying, “We’re not going to do it. We’re not going to do it.” I’m going, “But wait, it’s law. It’s state and federal law.” All he would tell me is, “We’re not going to do it.”
A: Why do you think that is? Why are there these laws that are in place and then they’re not being enforced?
S: Well, there’s no place to put all this waste and in confinement farming of animals, of livestock animals, they become human food, there are a lot of fatalities because animals are not meant to be raised in confinement type situations. Just the same way there’s a lot of disease in humans, a lot of illness in our pets, there’s also a lot of disease in livestock animals, and all of those hearts that maybe are cancerous or a liver that’s not functioning properly and they can tell during the slaughter process, all that condemned material, it has to be disposed of.
It would be a tremendous expense to the farming industry for these farmers to have to deal with that expense. Plus, if the farmer didn’t want to do the expense and just decided to make a pile or dig a hole for dead livestock, dead cows, their decomposing carcasses could contaminate waterways, it could contaminate the air. There’s a lot at risk, so everybody just decided well, let’s put it in pet food, and it’s just a waste disposal system, unfortunately.
A: Yeah, that is very unfortunate. So let’s talk in terms of regulation, how are regulations different for kibble versus raw? They’re not supposed to be different, but in reading your website and doing some research, they clearly are enforced very differently.
S: They are. With kibble pet food, the diseased animals and non-slaughtered animals are welcome. They’re in FDA compliance policies, which are not law, but their compliance policies are sort of directives from the top people at FDA to the people in the field saying this is how we’re going to act on this specific law. So there are compliance policies allowing kibble and canned food to used diseased or non-slaughtered animals.
For the raw pet food industry, it’s completely opposite. The compliance policy for raw pet food says if they want all the meat to be USDA inspected and passed, and it’s condemned in kibble or canned, but for raw they want it to be USDA inspected and passed, which is what they all should be. They all should be what they’re trying to hold raw pet food too.
A: So why are they trying to hold raw to a higher standard? Is it because it’s newer to the industry or is there something else going on?
S: Well, there is no if, and’s, or buts about it, a pathogenic bacteria like for example salmonella can make people sick, okay? It probably won’t make the pet sick, but it definitely can make humans sick and it could kill humans. So their approach is more on the human end of it than the pet food end of it. It’s probably not going to make the animal sick. If it is it’s not going to kill the animal more than likely. Maybe an immune compromised animal, yes, but they’re doing this out of the protection of humans.
FDA has a zero tolerance for any pathogenic bacteria in any pet food. For one, the only type of pet food they are testing is raw. They are not testing kibble. We’ve had massive billions of pounds of salmonella-contaminated recalled kibble foods, but they haven’t tested a kibble. We haven’t had a recall at least for a kibble food since 2015.
That’s three years, and the only reason we’re not having it is that they’re not testing it. Then the other issue is that’s FDA’s opinion on it. USDA takes the stance, they do officially have a zero tolerance, but USDA’s position and USDA regulates meat, USDA has the position of let’s be careful. You know, you have to consume a certain amount of bacteria in order to get sick, so let’s be real careful. Wash your hands, let’s handle it properly, educate consumers on how to handle the raw meat properly, then we should be okay.
They do issue recalls if the bacteria is high enough to make someone sick, but they don’t go overboard like FDA. So we have two federal agencies with different jurisdictions that are handling issues very, very differently, and that’s a concern too because a consumer can go to the grocery and buy a roast and bring it home, and as long as they handle it properly, it’s fine. But you can go to a pet food store and buy ground, balanced, complete and balanced raw beef pet food and it’s regulated completely different because they don’t think we are capable of washing our hands and handling it properly.
A: Okay, so let’s talk a little bit about Rad Cat. I’ll give everyone who doesn’t know a little bit of background. So for anyone who doesn’t know, Rad Cat is a raw food company located in Portland, Oregon that’s run by Janice and Tracey Hatch-Rizzi. On October 15, 2018, Rad Cat announced that after two very large recalls they were financially out of options and they were forced to make the decision to stop production and shut down their company.
The shutdown was obviously a big blow to a lot of their customers who were very loyal, and a lot of them probably didn’t really know the whole story of the shutdown until Susan released her article I think a day later called “Rad Cat Didn’t Die, It Was Murdered”. So can you summarise what happened?
S: Well, the first recall they found all on their own, okay? I believe I’m correct on this, and they contacted regulatory authorities, and they recalled the product. But after that, regulatory authorities, Ohio Department of Agriculture and Colorado’s Department of Agriculture directly violated handling procedure of a sample, which caused the destruction of Rad Cat.
With any pet food, a sample is taken from a pet food store, if it’s a frozen product it has to remain frozen and the testing agency, whether it’s FDA or a state Department of Agriculture is required to provide that pet food company with a split sample. They take a pound of pet food. They are required to give say a quarter of a pound to Rad Cat or whoever it is that they’re testing. That’s only fair because it can confirm the regulatory body’s test results or it can bring into more questions. We didn’t get a positive. What’s the deal now?
So Ohio refused to give Rad Cat their split sample. Colorado gave it to them, but the sample that was noted on lab documents that the sample was received thawed. The Colorado Department of Agriculture representative put the sample of frozen pet food, on the seat of his car in July in Colorado and thought that was okay. He had a cooler in his car. He just decided not to use it.
It was received at the lab thawed. You can’t regulate a company on a sloppy procedure like that, but they did. It was just horrible. That’s criminal. I so, so hope that Rad Cat sues all the regulatory authorities because they deserve it. They were wrong. If a company’s wrong, that’s fine. If they find it and it’s at levels where it would be dangerous for humans to handle, absolutely. Even with the thaw though, in Colorado, it was received thawed at the lab, it was tested and then refrozen, then that refrozen sample was sent, the split sample was sent to Rad Cat. By the time they got it, it was thawed again and it still tested negative for any pathogenic bacteria. That’s very suspicious. Did Colorado intentionally contaminate that product? It looks that way.
A: Right. That’s definitely really unfortunate. Rad Cat just seemed like such a great company and to see them close over this… They just weren’t able to whether the recalls. It’s obviously expensive to have a recall, but for them to shut down over that, that’s very disappointing.
I wanted to ask you, Susan, so Rad Cat, this kind of closure, it seems to be getting a lot of attention kind of in the raw feeding world and kind of in the pet world in general right now. Do you think that this situation is going to be enough of a spark to hopefully push some change on how raw food is regulated versus how kibble is regulated and hopefully get those things standardized a little more equally?
S: I think the only thing that will stop regulatory is a lawsuit. They could care less. They got what they wanted. They shut down a raw manufacturer. That’s what they want, so they got what they wanted. To me, the only way to stop them is for a pet food company to go, “Uh-uh, and we’re going to file a lawsuit. If you’re not following procedure, you cannot force me to recall and so we’re going to file a lawsuit.”
Regulatory has to clean up their act. Law is law. You can’t look the other way, which is what they do clear across the board. It is selective enforcement and they literally select, “Let’s see. I like this law. We’ll enforce it with this company, but I don’t like this law so we’re going to ignore it totally.” It’s just crazy.
A: It tends to swing in favour of kibble companies it seems like. It definitely doesn’t swing in favour of raw food.
S: Absolutely. Just as an example, a Mars Pet Care Facility, I got (via the Freedom of Information Act), an inspection report from FDA. FDA stated in this inspection report that near the where the food was actually being canned there were “millions of roaches.” That was seen during multiple inspections. Well, roaches carry all type of bacteria, including salmonella. FDA did nothing. Multiple inspections, millions of roaches both times, FDA did nothing to them. Nothing.
A: That’s crazy! So for people who want to do something to help, I know you mentioned obviously a lawsuit is going to be the biggest impact for these regulatory agencies but is there anything people who want to help elicit change on this issue can do?
S: They need to write their State Department of Agriculture and specifically tell them they want uniform enforcement of law and enforcement of all laws. They cannot allow diseased and non-slaughtered animals to be ground up in pet food. I mean, another huge issue in pet food is that for example, chicken. The definition of chicken, what you think chicken is applies to human food, but it’s very different. Chicken in pet food has a completely different definition.
Chicken in pet food, even though it says “Made with real chicken,” on the label could be condemned chicken, or it could be just chicken skin and bones. Pet owners have no access to all of those ingredient definitions, so that’s another thing. Consumers can write their State Department of Agriculture and say, “I want a copy of all these definitions. How can I know what I’m buying if I don’t have access to these definitions?” We just have to keep pushing them.
A: With everything that we’ve talked about I know, there’s going to be people listening to this who are either feeding raw or feeding kibble or feeding canned, and they’re going to be going, “So what do I feed my dog?” So do you have any advice kind of across the board? How do people ensure that they’re feeding their pets a decent, a good quality food?
S; The only way is to know is to feed a human-grade pet food. The only guarantee a consumer has to the quality of ingredients, processing standards being safe is when you see human-grade on the pet food label. You have to ignore all these human-grade claims on websites, but on the pet food label, if it says human-grade, then that means is that pet food contains the same quality of ingredients as human food, which will not include a diseased or non-slaughtered animal and it also means that the manufacturing of that food is to the same safety standards as human food.
With a raw food, the only way, raw foods are not allowed to make a human-grade claim. With raw food, the only thing you can do is call the manufacturer and ask them if the pet food was made under USDA inspection. If it is, that’s the very same thing as a human grade pet food.
A: Perfect. Thank you for that. I think that will be really helpful for people.
Rad Cat’s Go Fund Me Page: https://ca.gofundme.com/how-to-help-rad-cat-after-closure