FDA Zero-Tolerance policy
Shortly after passage of FSMA, FDA declared a zero-tolerance policy for Salmonella in all pet foods, citing mainly the risk to human health, especially for immune-compromised people who might handle contaminated pet food. And indeed, some Salmonella outbreaks in humans from handling pet food have occurred, including rather significant ones in 2008 and 2012 (both dry pet food).
In November 2013, the FDA Center for Veterinary Medicine (CVM) released results of a two-year study on the presence of Salmonella and Listeria monocytogenes in several categories of pet food products, showing a higher incidence of both pathogens in raw pet foods. According to FDA, there was only one other instance of Salmonella present, in a dry cat food; no other products outside of the raw category had either pathogen. (Independent researchers have also found a higher incidence of pathogens in raw pet foods. Of the 196 raw pet food samples analyzed, 15 were positive for Salmonella and 32 were positive for L. monocytogenes (see the Table below “Number and type of pet food samples that tested positive for Salmonella and Listeria monocytogenes (Years 1 & 2)”).
As FSMA continues to roll out, states are being urged by FDA to up their enforcement efforts and there are more frequent inspections of brands in the raw diet category. This is confirmed in practice as shown by recent recalls. Over the 10 months from June 2017 through April 2018 there were 23 recalls from 18 different brands with in 13 cases Salmonella, 5 cases Listeria, 4 cases with both Salmonella and Listeria and 1 recall for E-coli O128. 5 brand even had 2 recalls over this period.