AVMA vs Raw Food: Action Alert!
July 25, 2012
REVISED AND UPDATED 7/26/12 – PERMISSION GRANTED TO CROSS-POST
The American Veterinary Medical Association (AVMA) annual convention starts next week in San Diego. At that meeting, the House of Delegates (representatives from every state and affiliated organizations) is poised to vote on a proposed policy that essentially recommends against all raw (or “undercooked”) pet diets, whether homemade or commercially produced. (You should able to acces it online at Resolution #5)
This resolution will be voted on August 3, 2012
The Proposal: The AVMA discourages the feeding to cats and dogs of any animal-source protein that has not first been subjected to a process to eliminate pathogens because of the risk of illness to cats and dogs as well as humans. Cooking or pasteurization through the application of heat until the protein reaches an internal temperature adequate to destroy pathogenic organisms has been the traditional method used to eliminate pathogens in animal-source protein, although the AVMA recognizes that newer technologies and other methods such as irradiation are constantly being developed and implemented.
AVMA has apparently gotten a lot of comments. In response, they have posted this:
We’ve been seeing a lot of misinformation about the proposed AVMA policy on raw or undercooked animal-source protein diets for pets that will be discussed and voted on at the AVMA House of Delegates (HOD) meeting in San Diego in August, so we feel the need to clear things up.
First of all, this proposed policy would be an AVMA policy if approved, not state or federal law. The AVMA cannot, and will not, regulate what pet owners choose to feed their pets. If you already feed raw food to your pet, that’s your choice. This proposed policy is about mitigating public health risks, not about restricting or banning any products. Our policies are intended to present the scientific facts, which in this case are: 1) Scientific studies have shown that raw and undercooked protein can be sources of infection with Salmonella, Campylobacter, Clostridium, E. coli, Listeria monocytogenes, and enterotoxigenic Staphylococcus aureus. These infections can sicken pets and pet owners alike, and can be life-threatening; 2) unless a raw protein product has been subjected to a process that eliminates pathogens that can make pets and people ill, it poses a significant public health risk to both pets and pet owners.
Our policies are based on a thorough review of the scientific literature and are drafted by veterinarians with expertise in relevant fields (in this case, public health). If you’d like to read the proposed policy for yourself, here’s the exact document that will be considered by the HOD.
The Executive Board and the House Advisory Committee have already recommended passing the proposed policy resolution. This makes it very nearly a sure bet–unless they hear something that changes their minds. The HOD is made up of delegates from each state, as well as each state veterinary medical association and other allied organizations.
Now, the AVMA and their friends really only want to hear from its active members. But that certainly doesn’t mean nobody else can comment! In fact, I hope that as many people as possible will let the AVMA know what they think of this proposed policy: non-AMVA member veterinarians, as well as technicians, groomers, guardians, and animal lovers all all kinds.
To contact the AVMA:
1931 North Meacham Road, Suite 100
Schaumburg, IL 60173-4360
1910 Sunderland Place, NW
Washington, DC 20036-1642
General Email: firstname.lastname@example.org (include in the subject line: AVMA Council on Public Health and Regulatory Veterinary Medicine)
This move appears to be politically and financially motivated, as Hill’s, Purina, and others are major donors and sponsors of AVMA and its charitable arm, AVMA Foundation. The history of the road that led to this remarkably tactless and possibly illegal proposal, its links to the Delta Society and pet food mega-maker Purina, as well as recent developments, can be found on Susan Thixton’s wonderful blog, Truth About Pet Food.
I’ve updated this post with the new info from AVMA, and including the references AVMA used in their “thorough review of the scientific literature”–all six papers. Oddly, those references do not support their position; and of course, they are only a small fraction of the actual scientific literature on the subject.
WHY AVMA SHOULD NOT IMPLEMENT A POLICY AGAINST RAW DIETS FOR PETS
1. AVMA has a financial Conflict of Interest
According to the AVMA itself, this policy is the result of a suggestion by the Delta Society (now “Pet Partners”), which banned the feeding of raw-meat based diets to therapy dogs in its programs in 2010. Delta Society’s ban appeared to be instigated by a board member who, at the time, was in charge of Marketing for Nestlé Purina. Additionally, Purina donated $400,000 to the Delta Society (the largest donation ever received by Delta Society. Purina also promotes Delta Society on its website. The Delta Society’s vests (those worn by therapy dogs) was reportedly redesigned to include the Purina logo.
Many believe that the proposed policy is financially and politically motivated. And indeed, pet food companies provide a great deal of funding to AVMA, albeit indirectly; for example, through lecture sponsorships, receptions, exhibitor fees, and “goodies” at the annual AVMA Convention. They also donate directly to the AVMA Foundation.
In 2008, AVMA created a four-year “AVMA Platinum Partner Program” with Hill’s Pet Nutrition. The AVMA got more than $1.5 million from Hill’s, in exchange for promotional favoritism. This relationship is a clear conflict of interest with the proposed policy. Moreover, it may violate laws governing non-profit organizations.
2. It is not the AVMA’s role to create a policy dictating how to practice medicine, or what foods veterinarians sell or recommend to their clients.
If AVMA wishes to educate veterinarians about the risks/benefits of any diet (or pharmaceutical or procedure), a JAVMA editorial would be appropriate, but a policy that specifically vilifies a large segment of the pet food industry comprising dozens of companies is injudicious, not to mention potentially libelous. No other AVMA policy targets a specific company or group of companies by recommending that vets not use or recommend specific products.
Hundreds, if not thousands, of veterinarians use and recommend raw diets for their patients, and have done so for many years. Many veterinarians consistently find that animals’ health improves on such diets. In fact, a researcher for a large pet food company once told me that the company had studied raw diets, and cats do much better on raw meat than on cooked or processed diets.
For AVMA to create a policy that makes a significant number of their members wrong appears to be a political stab in the back to those conscientious practitioners who have studied the issue and chosen raw diets as the best option for their patients. Moreover, it directly interferes in the sacrosanct veterinarian-client-patient relationship.
3. AVMA’s policy is redundant and unnecessary.
The FDA has already published a guidance document for industry concerning raw food diets. Raw diet manufacturers are also required to comply with the exact same AAFCO guidelines and the exact same manufacturing standards as any other pet food.
4. AVMA correctly states that it is not “banning” or “regulating” raw pet foods—but it is using its influence a highly political and unethical manner.
AVMA has about 80,000 members, and it is doing its best to segregate and drive out those with a holistic mindset. This is just another nail in the coffin AVMA is building for holistic and integrative medicine, to satisfy its largest donors: Big Pharma and Big Pet Food.
5. Despite AVMA’s professed support of evidence-based medicine, this policy is completely unsupported by the evidence.
AVMA cites just six studies, and even those hand-picked studies—apparently the best AVMA could find–don’t actually support their position. Let’s take a look:
AVMA’s claims of “facts” #1”
1) Scientific studies have shown that raw and undercooked protein can be sources of infection with Salmonella, Campylobacter, Clostridium, E. coli, Listeria monocytogenes, and enterotoxigenic Staphylococcus aureus. These infections can sicken pets and pet owners alike, and can be life-threatening.
The U.S. meat supply is contaminated with many bacteria. Uncooked meat does, carries a risk of bacterial contamination.[i] We are not arguing that point; in fact, we gladly stipulate to the fact that a lot of meat has a lot of organisms that can and frequently do contaminate it.
But which, if any, of these organisms presents a real risk to pets, people, or both?
Let’s take the bad guys named by AVMA, one by one:
Salmonella. The first study cited by the AVMA states that “Salmonella was isolated from 80% of the BARF diet samples (P < 0.001) and from 30% of the stool samples from dogs fed the diet (P = 0.105). Dogs fed raw chicken may therefore be a source of environmental contamination.”[ii] However, this is not the whole story. This study looked at only 20 dogs (10 raw-fed, 10 control), and of the three positive stool samples, only 1 was from a dog whose food contained the same serovar; another was from a dog whose food contained a different serovar, and the last was from a dog whose food tested negative. No dog or human illness was reported, despite confirmed contamination of the food. This has consistently been the case with nearly every analysis of raw foods: they contain pathogens, but nobody is getting sick.
The second AVMA-cited study states that 95% of human Salmonella cases are due to eating contaminated food. The authors speculate that some number of these could be due to contact with dogs or dog food, and cites data from 1987, which estimated that 1% of human salmonellosis could be due to contact with pets (but not pet food). The authors conclude, “To date, raw pet foods have not been associated with salmonellosis in humans.”[iii]
The literature supports the fact that zoonotic transmission of Salmonella from pets to people is extremely rare. A 2011 review found only a single U.S. case of transmission of Salmonella from a dog to a human since 1974.[iv] (In that case the human had let the dog eat broth that had been standing, unrefrigerated, for days.)
Research suggests that up to 36% of dogs and 18% of cats are asymptomatic carriers of Salmonella.[v] The possible source of the organism was not discussed, but may include the environment as well as diet, which of course was most likely to be heat-processed pet food.
Dogs and cats themselves appear to be quite resistant to illness due to this ubiquitous bacteria. There has been only one report of illness in cats possibly linked to Salmonella, although in that case one cat was positive for a different serotype than the one in the food, and Salmonella was not proven to be the cause of either cat’s illness. Owner neglect was clearly the primary factor in their deaths.[vi]
The evidence clearly shows that Salmonella, as the most feared pathogen of raw meat diets, is not a significant threat to human or animal health.
Campylobacter. AVMA’s reference on Campylobacter examines the public health risks of feeding raw diets to dogs.[vii] As evidence, this review cites a Hungarian study that included free-roaming dogs with access to aborted livestock fetuses and raw poultry that were found to be contaminated with Campylobacter. One person became sick, but it is unknown whether or not he handled infected tissues.
Campylobacter is a common pathogen of wildlife, livestock and poultry, is also zoonotic. However, research suggests that only a “small proportion of human infections are acquired from dogs…usually [from] puppies that are themselves suffering from diarrhoea. Only four infections associated with cats (all kittens with diarrhoea) have been reported.” The study concluded that dogs and cats are unlikely to be the source of human infections.[viii] Phylogenetic analysis of cases, which are strongly seasonal, suggests that most human cases of campylobacteriosis are most likely due to water contamination.[ix]
One study on Campylobacter states that “…if a person and a pet have concurrent campylobacteriosis, the veterinarian must consider whether they both obtained it from some other common source (for example, food or water) or if the pet obtained it from the human being.” The authors conclude that dogs and cats are unlikely to be the source of human infection.[x]
The evidence clearly shows that Campylobacter, as the next most common pathogen of raw meat diets, is not a significant threat to human or animal health.
Toxoplasma. Regarding this protozoal parasite, which may encyst in raw meat, researchers concluded that, “Because of their fastidious nature, the passing of non-infective oocysts, and the short duration of oocyst shedding, direct contact with cats is not thought to be a primary risk for human infection.”[xi] Given that about 41% of U.S. cats are allowed outdoors where they can readily hunt and consume prey, it is unlikely that raw food diets significantly increase the risk.[xii] The primary cause of human toxoplasmosis comes from humans themselves consuming raw or undercooked meat, milk, or shellfish.[xiii] Having 3 or more kittens was also a risk factor, but a sick litter of kittens also implies an outdoor cat–and irresponsible owners.
In Canada and other countries, Toxoplasma is a common contaminant of pork. However, raw diet proponents do not recommend feeding uncooked pork, and no raw diet studied to date has contained pork.
The evidence shows that Toxoplasma in raw meat diets is not a significant threat to human or animal health.
Clostridium perfringens. These bacteria, commonly found in decaying vegetation, are common and contagious causes of gastroenteritis in dogs and cats. Infections are usually self-limiting. The study cited by AVMA to support its claim that Clostridia in meat is a significant health hazard states, “the exact relationship between C perfringens infection and gastroenteritis in dogs is not clear.” It also states that if anyone handled that meat–and did not wash their hands–they probably would have become infected. Another study reported, “No associations between C. difficile, MRSA or VRE and consumption of raw meat were detected.”[xiv] So not only is C. perfringens not a serious issue, but neither is the more pathogenic C. dificile.
Therefore, the evidence shows that C. perfringens in raw meat diets is not a significant threat to human or animal health.
E. coli. The U.S. meat supply, particularly beef, is highly contaminated with E. coli. The organism is also ubiquitous in the environment. People commonly carry it. In the vast majority of cases, E. coli is a harmless commensal of the gastrointestinal tract. A study that looked for a pathogenic strain, E. coli O157, in raw-meat fed dogs and their environment found none. [xv]
The evidence shows that E. coli in raw meat diets is not a significant threat to human or animal health.
Listeria. The literature reports listeriosis in one dog, source unknown. Virtually all human listeria is due to consuming contaminated foods such as meat, cheese, and milk. However, contamination occurs during processing of these foods for cold cuts, hot dogs, and similar products. There is no evidence that any human or pet has ever has contracted Listeria from fresh, raw meats.
There is no evidence to suggest that Listeria in raw meat diets is a significant threat to human or animal health.
Staph aureus. The AVMA-cited study on this topic states, “Dogs are also susceptible to illness caused by Staphylococcus aureus and Bacillus cereus.
These toxin-producing organisms can be found in raw meat and commercially prepared foods and may proliferate and produce toxins if the food is allowed to incubate before feeding. Many idiopathic digestive upsets of dogs may be related to bacterial growth in moist foods put out for dogs and left for many hours before they are eaten.[xvi] Many people mix water, broth, or other liquids with dry foods. This is clearly risky.
Unpublished data cultured B. cereus from every dry dog food tested; that study’s author attributes most cases of “garbage gut” to B. cereus, not Staph.[xvii] The AVMA’s source did not separate out the two species.
There is no evidence that Staph aureus in raw meat diets is a significant threat to human or animal health.
AVMA’s claims of “facts” #2:
2) Unless a raw protein product has been subjected to a process that eliminates pathogens that can make pets and people ill, it poses a significant public health risk to both pets and pet owners.
On the contrary, pet foods that have been subjected to a process that eliminates pathogens is far more likely to make pets and people ill. Dry food is heat-processed twice: first, the meat ingredients are rendered (a slow-cooking process that boils animal parts for hours at 250oF), and then again during extrusion (a quick process, but done at extremely high pressure and temperature).
A long record of problems with processed pet food provides more than enough proof.
Salmonella. Since March, 2012, 49 people and uncounted pets have become ill due to Salmonella contamination of their heat-processed dry commercial pet food. The recall of potentially contaminated food has, so far, entangled 14 brands of food.
A recently published review highlights the risks associated with heat-processed commercial pet foods: “There were 11 major pet food recalls in the United States between 1996 and 2010 that were due to chemical contaminants or misformulations: 3 aflatoxin, 3 excess vitamin D3, 1 excess methionine, 3 inadequate thiamine, and 1 adulteration with melamine and related compounds and an additional 2 warnings concerning a Fanconi-like renal syndrome in dogs after ingesting large amounts of chicken jerky treat products.[xviii] (Note that the hundreds of brands and flavors included in the melamine-related recall are included as a single incident.)
But this review, published in March, 2012, is not up to date. Since May 1st, 16 brands of commercial dry pet food have been recalled due to Salmonella, one due to thiamine deficiency, one due to a “strange odor,” and one due to chunks of blue plastic in canned dog food.
Aflatoxin. Heat-processed pet food is to blame for many cases of illness and death in pets. Not only bacteria, but fungal toxins may be present in dry, grain-containing pet food. Several large pet food recalls have involved moldy grain, particularly corn. Only dry foods were involved. In a 1995 recall, dozens of dogs were sickened by vomitoxin in the food. Aflatoxin was responsible for about 25 dog deaths in 1998, and 100 more in 2006. In 2011 alone, 15 different brands of dry dog food were recalled due to aflatoxin. (Source: FDA) Aflatoxicosis has a morbidity rate of nearly 70% in dogs.[xix]
Commercial pet foods are responsible for thousands of deaths and tens of thousands of cases of illness in pets (and dozens of cases of human illness). This, of course, does not include a host of other directly food-caused illnesses such as food allergies and intolerances and obesity (with all its sequelae). In terms of morbidity and mortality, raw meat diets aren’t even on the radar.
Now, let’s look at the positive side of raw meat diets. We won’t belabor the point with the thousands of stories told by veterinariains and pet owners alike of near-miraculous cures when a pet’s diet was changed from heat-processed to raw.
But there are actually multiple studies showing that raw meat diets for dogs and cats are more digestible than heat-processed foods. Here are a few of them:
- Beloshapka AN, Duclos LM, Vester Boler BM, et al. Effects of inulin or yeast cell-wall extract on nutrient digestibility, fecal fermentative endproduct concentrations, and blood metabolite concentrations in adult dogs fed raw meat-based diets.
Am J Vet Res.
- 2012 Jul;73(7):1016-23.
Kerr KR, Vester Boler BM, Morris CL, et al. Apparent total tract energy and macronutrient digestibility and fecal fermentative end-product concentrations of domestic cats fed extruded, raw beef-based, and cooked beef-based diets. J Anim Sci. 2012 Feb;90(2):515-22.
Murray SM, Patil AR, Fahey GC, et al. Raw and rendered animal by-products as ingredients in dog diets. J Anim Sci. 1997;75:2497-2505.
Vester BM, Burke SL, Liu KJ, Dikeman CL, et al. Influence of feeding raw or extruded feline diets on nutrient digestibility and nitrogen metabolism of African wildcats (Felis lybica). Zoo Biol. 2010 Nov-Dec;29(6):676-86.
What should the AVMA do instead?
Good client education and an emphasis on safe meat-handling procedures is adequate to prevent human illness related to raw (or any other) pet diets.
Hundreds of veterinarians recommend raw meat diets, and dozens of companies make them, but nobody recommends abandoning all reasonable safe meat-handling principles when feeding them.
It is absolutely true that raw meat has a high likelihood of bacterial contamination. But using raw meat for pet food carries no more risk than preparing meat loaf for your kids: safe, as long as one uses normal precautions.
As one study on zoonotic diseases states, “The transmission of pet-borne zoonoses is complex and usually requires close contact between susceptible human beings and animals or their excretions. Such contact frequently involves lack of common sense and gross breach of sound hygienic practice.”[xx]
With specific reference to Campylobacter, but broadly applicable to all potential pet-food related zoonoses, another researcher stated, “The application of simple hygienic measures should prevent such infections.”[xxi]
The AVMA should undertake a campaign that truthfully assesses the risks from all pet diets, and encourage members to fully inform their clients about the risks and benefits of every type of food, with an emphasis on safe handling and general cleanliness.
In conclusion, the proposed AVMA policy is illogical, inappropriate, and not even remotely evidence-based. Clearly, the association has not done its homework. This proposal should get the failing grade it deserves, and get a resounding “No!” from the AVMA House of Delegates.
[i] Freeman LM, Michel KE. Evaluation of raw food diets for dogs. J Am Vet Med Assoc 2001;218:705–709.
[ii] Joffe DJ, Schlesinger DP. Preliminary assessment of the risk of Salmonella infection in dogs fed raw chicken diets. Can Vet J. 2002 June; 43(6): 441–442.
[iii] Finley R, Reid-Smith R, Weese JS, et al. Human health implications of Salmonella-contaminated natural pet treats and raw pet food. Clin Infect Dis 2006;42:686–691.
[iv] Hoelzer K, Switt AIM, Wiedmann M. Animal contact as a source of human non-typhoidal salmonellosis. Vet Res. 2011;42:34.
[v] Sanchez S, Hofacre CL, Lee MD, et al. Animal sources of salmonellosis. J Am Vet Med Assoc. 2002 Aug 15;221(4):492-497.
[vi] Stiver SL, Frazier KS, Mauel MJ, et al. Septicemic salmonellosis in two cats fed a raw-meat diet. J Am Anim Hosp Assoc 2003;39:538–542.
[vii] Hancock DD. Public health concerns associated with feeding raw meat diets to dogs. J Am Vet Med Assoc 2001;219:1222–1225
[viii] Skirrow MB. Campylobacter enteritis in dogs and cats: a ‘new’ zoonosis. Vet Res Commun. 1981 Sep;5(1):13-9.
[ix] Wilson DJ, Gabriel E, Leatherbarrow AJ, et al.Tracing the source of campylobacteriosis. PLoS Genet. 2008 Sep 26;4(9):e1000203.
[x] Bischoff K, Rumbeiha WK . Pet food recalls and pet food contaminants in small animals. Vet Clin North Am Small Anim Pract. 2012 Mar;42(2):237-50.
[xi] Elmore SA, Jones JL, Conrad PA, et al. Toxoplasma gondii: epidemiology, feline clinical aspects, and prevention. Trends Parasitol. 2010 Apr;26(4):190-6.
[xii] Clancy EA, Moore AS, Bertone ER. Evaluation of cat and owner characteristics and their relationships to outdoor access of owned cats. J Am Vet Med Assoc. 2003 Jun 1;222(11):1541-5.
[xiii] Jones JL, Dargelas V, Roberts J, et al. Risk factors for Toxoplasma gondii infection in the United States. Clin Infect Dis. 2009 Sep 15;49(6):878-84.
[xiv] Lefebvre SL, Reid-Smith R, Boerlin P, et al. Evaluation of the risks of shedding Salmonellae and other potential pathogens by therapy dogs fed raw diets in Ontario and Alberta. Zoonoses Public Health. 2008 Oct;55(8-10):470-80.
[xv] Lenz J, Joffe D, Kauffman M, et al. Perceptions, practices, and consequences associated with foodborne pathogens and the feeding of raw meat to dogs. Can Vet J. 2009 June; 50(6): 637–643.
[xvi] LeJune, et al. Op cit.
[xvii] Cullor J. University of California at Davis, Veterinary Medical Teaching and Research Center, Tulare, CA.
Unpublished data and personal communications, 1999-2000.
[xviii] Bischoff, et al. Op cit.
[xix] Bruchim Y, et al.. Accidental fatal aflatoxicosis due to contaminated commercial diet in 50 dogs. Res Vet Sci. 2012;93: 279-287.
[xx] Kahrs RF, Holmes DN, Poppensiek GC. Diseases transmitted from pets to man: an evolving concern for veterinarians. Cornell Vet. 1978 Oct;68(4):442-59.
[xxi] Skirrow, Op cit.
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Created 09/12/12; Updated 08/11/14