We filed a Freedom of Information Act (FOIA) request with the FDA for consumer complaints (adverse event reports) the agency received related to pet foods. It took the FDA four years to provide the information (federal law requires government agencies to provide FOIA-requested documents within 20 business days).
From the FDA’s FOIA request, Blue Buffalo Pet Food was reported to the FDA 84 times over a nine-month period (6/1/20 – 3/3/21); consumers reporting illness, hospitalizations, and pet deaths associated with Blue Buffalo. Click Here to view adverse event reports.
Based on these adverse event reports, we filed another FOIA request with the FDA to learn whether the agency investigated the 84 adverse event reports it received – whether the FDA tested any Blue pet foods Buffalo and whether the FDA inspected the Blue Buffalo manufacturing facility. We waited 9 months for the FDA to provide this requested information.
A recently issued FOIA request did not provide any lab test results of Blue Buffalo pet foods. The FDA has NOT tested any Blue Buffalo pet foods even though the agency received 84 reports of illness, hospitalizations, and pet deaths over a 9-month period – all reported as linked in Blue Buffalo pet foods.
The FDA did conduct an inspection of Blue Buffalo’s pet food manufacturing facility, however the inspection was classified as a routine inspection; “CGMP/PC Surveillance inspection“. The FDA website tells us that this inspection classification is: “Surveillance inspections are conducted to monitor the manufacturing process and the quality of FDA-regulated products on the market. The agency uses the inspection to check whether a manufacturer is following quality manufacturing practices.”
IF the agency inspects a pet food plant based on reports of sick, hospitalized, and dead pets – the inspection would be classified as a “inspection for reason“. “For-cause inspections are triggered when the agency has reason to believe a facility has quality problems, to follow up on complaints or to review corrective actions taken to address past deficiencies. violation.”
Thus, this Blue Buffalo inspection was not conducted because the FDA received 84 consumer complaints reporting illness, hospitalizations and pet deaths in the past nine months. This inspection is a standard pet food inspection, similar to what would be performed at any pet food manufacturer. An inspection to ‘check’ Blue Buffalo, to make sure the manufacturer is ‘adhering to quality manufacturing practices.’
So…what is involved in an FDA inspection to evaluate a pet food manufacturer, to determine if the manufacturer is following required manufacturing practices? Not much.
First, the FDA did not do the inspection. Instead, they sent the Missouri Department of Agriculture to conduct the inspection on behalf of the FDA.
The inspection took place over three days. Two of the three day inspections were conducted “almost“. The virtual inspection “including a complete review of the food safety plan, training records, risk analysis“.
Note the inspection report states that the regulator ‘reviewed’ Blue Buffalo’s food safety plan, reviewed training records, and reviewed the pet food manufacturer’s risk assessment. Emphasis on ‘verified’ – nothing seems to have been proven.
Statements from the inspection report confirm the lack of verification; (bold added)”Company personnel looks qualified to perform their duties.” had no evidence the inspection staff actually talked to the employees to confirm that the staff was qualified.
Regarding employee training, the inspection report stated: (bold added) “the facility and individuals assigned duties like was implemented“.
According to the inspection report, the virtual part of the inspection goes beyond questioning the regulations, and accepting the pet food manufacturer’s responses as truthful.
The third day of the inspection was at the pet food manufacturing plant, representatives of the Missouri Department of Agriculture conducted “walk through, inspection of additional records, grounds and close out were conducted.”
This walk includes (bold added)…
“The plant is generally kept clean and tidy.”
“All ingredients and finished product storage are adequately identified.”
“Pest Service by (redacted) appear to be enough. Records of contractor visits and treatments are available for viewing.“
The inspection report does not indicate that inspectors actually looked at pesticide records or performed any testing for pesticide residues inside the plant.
Are pet food samples collected for testing? Nope.
Are samples of raw ingredients collected for testing? Nope.
Has the Missouri Department of Agriculture discussed the 84 reports of sick pets received by the FDA in the past nine months? Only three of the 84 reports were discussed.
The inspectors discussed only “13 complaints” with Blue Buffalo. Five are from 2016, two from 2017, three from 2019, three from 2020. Blue Buffalo told inspectors “a thorough investigation would have been completed.”
And that’s it. Regulatory authorities have accepted as fact that this pet food manufacturer has conducted a thorough investigation regarding consumer complaints. The regulation did not ask for any evidence of an investigation, the regulation did not request or look at any laboratory test results of pet foods involved in consumer complaints.
End of inspection.
Press here to read the full inspection report.
So many worries…
It’s definitely not an inspection, it’s a conversation.
Since the pet’s life is at stake, inspections should always include verification of all claims made by a manufacturer. Validation should include testing raw ingredients and finished pet food for all types of contaminants including pesticides used in the facility. Verification should include discussions with manufacturing employees in confidential settings (not just management) to determine whether claims of proper training are actually being implemented.
If a pet food manufacturer says “a thorough investigation” is conducted as a follow up to a consumer complaint received, the regulator must scrutinize what that investigation entails.
Regulatory authorities need to hire experienced private investigators to train their inspectors. Regulation needs to learn how to properly substantiate claims made by pet food.
Question and answer inspections are not inspections, they are conversations.
Pet owners deserve better than what we get from our regulatory authorities.
Wishing you and your pet(s) the best,
Susan Thixton
Pet Food Safety Advocate
TruthaboutPetFood.com
Association for Truth in Pet Food
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