The U.S. Food and Drug Administration (FDA) has recently issued a warning letter to Woody’s Pet Food Deli, a pet food manufacturer located in West Saint Paul, Minnesota, following an inspection of their facility. The inspection, conducted from August 29 to September 12, 2023, revealed significant concerns regarding the safety and manufacturing practices at Woody’s Pet Food Deli, particularly concerning their raw pet food products. This article delves into the details of the FDA’s warning letter, highlighting the key issues and what it means for pet owners.
FDA Inspection and Findings at Woody’s Pet Food Deli
The FDA’s inspection was a follow-up to a previous Untitled Letter issued to Woody’s Pet Food Deli on September 2, 2022, indicating a history of regulatory concerns. During the recent inspection, FDA investigators collected a sample of Woody’s Pet Food Deli Raw Free Range Turkey with Supplements pet food for dogs and cats. Laboratory analysis of this sample revealed the presence of Salmonella Reading and Listeria monocytogenes, both of which are pathogenic bacteria that can pose serious health risks to both pets and humans.
Salmonella and Listeria Contamination
The detection of Salmonella and Listeria in Woody’s Pet Food Deli’s raw pet food is a significant concern. Salmonella is known to cause salmonellosis, an infection that can lead to symptoms like diarrhea, fever, and abdominal cramps in humans and similar gastrointestinal issues in pets. Listeria monocytogenes can cause listeriosis, a more severe infection, especially dangerous for pregnant women, newborns, older adults, and individuals with weakened immune systems. In pets, listeriosis can manifest as fever, muscle aches, and in severe cases, neurological signs.
The FDA deemed the contaminated pet food lot to be adulterated, meaning it contains a poisonous or deleterious substance that may be injurious to health. Woody’s Pet Food Deli voluntarily disposed of the implicated lot of Raw Free Range Turkey pet food.
CGMP Violations and Pathogen Control
Beyond the contamination finding, the FDA investigators also identified significant violations of the Current Good Manufacturing Practice (CGMP) requirements for animal food. These regulations are designed to ensure that animal food is produced in a safe and sanitary environment to minimize risks.
A key violation noted was the inadequacy of Woody’s Pet Food Deli’s pathogen control measures. The company uses a solution containing peroxyacetic acid (PAA) and hydrogen peroxide as a method to eliminate pathogens in their raw pet food. However, the FDA’s sample, taken after this treatment, still tested positive for Salmonella and Listeria, indicating that the current method is not effective in preventing adulteration.
The FDA emphasized that this is not an isolated incident. Past inspections have also revealed Salmonella contamination in Woody’s Pet Food Deli products, including:
- Woody’s Pet Food Deli Raw Cornish Hen Homemade Cat and Dog Food with Supplements (November 2021): Salmonella enteritidis.
- Woody’s Pet Food Deli Raw Chicken Homemade Cat and Dog Food (August 2019): Salmonella Infantis and Salmonella Kentucky.
This recurring issue highlights a systemic problem in Woody’s Pet Food Deli’s manufacturing process regarding pathogen control.
Unapproved Use of Peroxyacetic Acid (PAA)
Another critical point in the FDA warning letter is the unapproved use of peroxyacetic acid (PAA). Woody’s Pet Food Deli uses a PAA-based solution as an antimicrobial treatment. While PAA is approved for certain uses in human food production under specific conditions, there is no FDA regulation that approves its use as a food additive in animal food. Furthermore, the FDA is unaware of any data establishing PAA as Generally Recognized as Safe (GRAS) for use in animal food.
Under the Federal Food, Drug, and Cosmetic Act, an unapproved food additive is considered unsafe, and food containing such an additive is deemed adulterated. Therefore, Woody’s Pet Food Deli’s use of PAA in their pet food products constitutes another violation.
Details of the FDA Warning Letter to Woody’s Pet Food Deli
The warning letter issued by the FDA is a formal notification of these violations and demands corrective action from Woody’s Pet Food Deli. It emphasizes the seriousness of Salmonella contamination in pet food, referencing past outbreaks of salmonellosis in humans linked to contaminated pet food, including a 2019 outbreak involving Woody’s Pet Food Deli’s Raw Free Range Turkey and Salmonella Reading.
Recurring Issues and Past Warnings
The FDA explicitly mentions previous communications with Woody’s Pet Food Deli about Salmonella concerns, including the September 2022 Untitled Letter and teleconferences in 2019 and 2021. This history underscores the FDA’s frustration with the continued recurrence of Salmonella contamination despite prior warnings. The FDA criticizes Woody’s Pet Food Deli’s response to the inspection findings as inadequate because it did not propose concrete changes to their process to prevent future contamination.
FDA’s Concerns About PAA Use
Regarding the use of PAA, Woody’s Pet Food Deli’s response indicated they might lower the concentration of PAA used for non-poultry products. However, the FDA found this response insufficient as it did not provide any evidence that the use of PAA in their pet food is considered GRAS by qualified scientific experts, thus failing to address the core issue of unapproved food additive usage.
Wooden Butcher Block Table Concern
In addition to the major violations, the FDA also raised concerns about the use of a wooden butcher block table in Woody’s Pet Food Deli’s production. Wooden surfaces are porous and can be difficult to clean and sanitize effectively, potentially harboring pathogenic bacteria. The FDA recommended replacing the wooden butcher block table with non-porous, easily cleanable alternatives to minimize contamination risks.
Qualified Facility Attestation
The FDA also noted that Woody’s Pet Food Deli, appearing to meet the definition of a qualified facility, is required to submit an attestation to the FDA. While Woody’s Pet Food Deli claimed to have submitted this attestation, they could not provide proof, and the FDA has no record of receiving it. The warning letter urges Woody’s Pet Food Deli to submit this attestation, preferably electronically.
What This Means for Pet Owners
The FDA warning letter to Woody’s Pet Food Deli raises significant concerns for pet owners who feed their pets raw pet food, particularly products from this brand.
Risks of Salmonella and Listeria in Pet Food
The presence of Salmonella and Listeria in pet food poses risks to both pets and humans. Pets consuming contaminated food can develop infections, and even if they don’t show symptoms, they can shed these bacteria in their feces, potentially exposing human family members, especially children, the elderly, and immunocompromised individuals, to illness.
Raw pet food, in general, has been a subject of debate and concern within the veterinary and public health communities due to the inherent risks of bacterial contamination. While proponents argue for the nutritional benefits of raw diets, health authorities emphasize the increased risk of pathogen exposure compared to cooked pet food.
Importance of Pet Food Safety
This situation underscores the importance of pet food safety and the FDA’s regulatory role in ensuring that pet food products are safe for consumption. Pet owners should be aware of the potential risks associated with raw pet food and make informed decisions about their pets’ diets.
What to Do if You Use Woody’s Pet Food Deli Products
If you are currently using Woody’s Pet Food Deli raw pet food products, it is advisable to:
- Monitor your pet for any signs of illness, such as vomiting, diarrhea, lethargy, or fever. If your pet exhibits these symptoms, consult your veterinarian immediately.
- Practice safe food handling procedures when handling pet food, especially raw food. Wash your hands thoroughly after handling pet food, and clean and sanitize food bowls and preparation surfaces.
- Consider discontinuing use of Woody’s Pet Food Deli raw pet food products, at least until the company has adequately addressed the FDA’s concerns and implemented effective corrective actions.
- Stay informed about any potential recalls or further updates from the FDA regarding Woody’s Pet Food Deli.
Conclusion
The FDA warning letter to Woody’s Pet Food Deli is a serious matter that highlights significant deficiencies in their manufacturing practices and product safety. The repeated findings of Salmonella and Listeria contamination, along with the unapproved use of PAA, raise serious questions about the safety of their raw pet food products. Pet owners should take note of these concerns and prioritize pet food safety to protect both their animals and their families from potential health risks. It remains to be seen what corrective actions Woody’s Pet Food Deli will take to address the FDA’s findings and ensure the safety of their products moving forward. Pet owners should look for updates from the FDA and Woody’s Pet Food Deli regarding this situation.
