
The FDA has issued a directive to pet food producers to ensure that their food safety plans address H5N1 influenza contamination issues. It’s in response to multiple cases of H5N1 avian influenza in domestic and wild cats fed contaminated raw diets containing poultry. Infection was fatal in many of these cats, and this also puts humans at risk of exposure from both the infected cats and handling the contaminated diets. The severity of disease in cats and the potential public health concerns with H5N1 flu in animals means action is needed to reduce the risk of infections. The FDA notice is directed at any manufacturers that use raw poultry or beef ingredients, but is most relevant for manufacturers of raw diets, since cooking during canned or dry diet production will kill influenza virus before it reaches the consumer or pet. Here’s what the first part of the notice says:
- “The U.S. Food and Drug Administration has determined that it is necessary for manufacturers of cat and dog foods who are covered by the FDA Food Safety Modernization Act Preventive Controls for Animal Food (PCAF) rule and using uncooked or unpasteurized materials derived from poultry or cattle (e.g., uncooked meat, unpasteurized milk or unpasteurized eggs) to reanalyze their food safety plans to include Highly Pathogenic Avian Influenza virus (specifically H5N1) as a known or reasonably foreseeable hazard. Furthermore, the FDA is issuing this update to ensure that cat and dog food manufacturers are aware of information about the new H5N1 hazard associated with their pet food products, which is an additional reason that manufacturers must conduct a reanalysis of their food safety plans.”
Manufacturers covered under rule mentioned in the notice have a standard requirement to reassess their food safety plan when the FDA determines there’s a need to respond to a new hazard, as they have here. The notice also encourages producers to minimize H5N1 transmission through practices such as “… seeking ingredients from flocks or herds that are healthy, and taking processing steps, such as heat treatment, that are capable of inactivating viruses.”
Will the FDA notice achieve much?
That’s a tough question. It won’t likely have an immediate direct impact, as it’s reliant on the companies taking effective action themselves. It’s a directive to consider changing their food safety plans, not a directive to actually do something specific to mitigate risk. Presumably, that’s because there are limits to what the FDA can require; getting into very granular actions (e.g. “you have to do this specific thing”) is likely beyond what the FDA can or would do in a situation like this. The impact will vary between manufacturers, but even if it won’t make everyone do something useful, it should help.
The good, more mainstream raw diet manufacturers are already likely taking the necessary steps to prevent H5N1 flu contamination in their products. Most of these companies use high pressure pasteurization (HPP), which is a useful risk reduction step (although it’s not guaranteed to eliminate risk of all pathogens). I assume the first cases of H5N1 in cats from raw diets already sparked a review of what they are doing and what they can do to reduce the risk of using contaminated meat in the first place.
The all-too-common dodgy raw diet producers usually ignore (or deny-and-deflect) infectious disease issues with their products, and some have been doing the same with H5N1 flu. They will likely continue to do so. Their “reanalysis” might be akin to “yep, we thought about it and we’re good. Go away.”
As is typical, the manufacturers in the middle might be the group where this could have the most potential impact. They may not know much about the issue or understand how serious it is. They also may be at a loss about what they can and should do to mitigate the risk. They probably don’t have much expertise in house to be proactive about emerging issues, and a notice like this helps to ensure it’s on their radar, emphasize the importance, raise some liability concerns (that might be the biggest driver of action for some – getting sued is a big motivator), force at least some consideration of the problem, and point them in the right direction in terms of what to do. It might also be another nudge to introduce better overall practices like high pressure pasteurization and better supply management.
What else can be done to reduce the risk of pets getting H5N1 flu from raw diets?
It would be nice to have more consumer-facing education about the risks and how to reduce them to help help consumers protect themselves. It could also help drive better manufacturing practices, if educated consumers start spending their pet food dollars on products produced in safer ways.
What can people do about the risk of H5N1 flu if they are adamant they want to feed a raw diet to their pet(s)?
- Avoid poultry-based diets (and probably also beef in the US).
- Use diets that are high-pressure pasteurized, and ask companies about if how the effectiveness of their HPP method is tested (not all HPP is equally effective).
- Ask companies about their food safety plan and what pathogens they consider in their plan.
- Use good food handling practices in the home to avoid cross-contamination of human food and other surfaces.
- Report any illnesses in pets (or people) that might be linked to the diet.
For more general information about food safety and raw diets, check out the Worms & Germs and OAHN Raw Meat Diets infosheet, available on the Worms & Germs Resources – Pets page.