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Food Safety 227

Government has the authority under the Public Health toxins. Both factors tend to increase the risk of foodborne dis-
VetBooks.ir Security and Bioterrorism Preparedness and Response Act of ease in locally produced foods.
The risk of litigation also encourages pet food manufacturers
2002 (i.e., the Bioterrorism Act) to administratively detain food
to be diligent in maintaining high product quality standards.
items that may present a threat of serious adverse health conse-
quences or death to people or animals. The Act also authorizes Under tort claims law, all products offered for sale to the pub-
enforcement actions that may be taken against perishable foods lic contain an implied warranty (The American Law Institute,
subject to a detention order. 1965). The law specifically provides “that a person who sells a
A tolerance is a codified legal regulation whereas action and product in a defective condition unreasonably dangerous to the
advisory levels constitute nonbinding FDA guidelines that user or consumer or his property is liable for the physical harm
the agency uses in exercising its enforcement discretion. the product causes . . .” News programs frequently report large
Instead of a tolerance, the FDA may choose to issue either an verdicts against manufacturers of human food products because
action or an advisory level for some unnatural additives. All of the harm allegedly caused by their products (Taylor, 1996).
three are considered maximum allowable levels, but an action Animal feed and pet food manufacturers have also been caught
level is generally supported by more definitive safety data than up in this trend. Procedural breakdowns or oversights during
is an advisory level. Therefore, some circumstances may elicit production or storage can have a catastrophic effect on profits
enforcement action at levels below an action or advisory level or even company viability. Mycotoxin litigation alone cost the
whereas others may not, even when an action or advisory level pet food industry an estimated $7 million in the early 1990s
has been exceeded. (McCoy, 1996). Recent problems with mycotoxin contamina-
The FDA does not set tolerances for pesticides; instead these tion had financial repercussions and severely damaged the rep-
fall under the jurisdiction of the United States Environmental utation of companies involved (Industry News, 1995;
Protection Agency (EPA) by the authority of the FFDCA and Anonymous. FDA Recall, 2005). Such experiences have made
the Federal Insecticide, Fungicide and Rodenticide Act it necessary for manufacturers to devote extensive resources to
(Superintendent of Documents, 1995). The EPA establishes documenting product quality.
and publishes pesticide tolerances for the various plant and ani-
mal commodities in 40 CFR 180. These tolerances are devel-
oped by combining the results of field trials and laboratory ani- HOME-PREPARED FOODS
mal toxicity testing (NRC, 1993). The United States
Department of Agriculture (USDA) and FDA are then jointly The use of home-prepared pet foods also has clinical relevance
responsible for enforcing the pesticide tolerances. to foodborne disease. Meat and eggs produced for human con-
For contaminants not covered by a tolerance, an action level sumption and used to prepare homemade pet foods are contam-
or advisory level, the limit remains theoretically at zero. inated with microbes (Notermans et al,1995; Fenlon et al,1996;
However, present day analytical methods have become so sen- Remillard, 2005). Research indicates that many people are care-
sitive that minuscule amounts can be detected. Fortunately, the less about cross-contamination during food preparation at home
FDA has discretionary power when a contaminant is detected (Patil et al, 2005). If breeders and pet owners use grocery store
at a low level not considered to be a safety concern. ingredients that have been stored properly, heat foods to tem-
In Europe, the regulation of intentional additives (e.g., vita- peratures sufficient to destroy pathogens and prepare amounts
mins and minerals) and unintentional additives (e.g., pesticides, that are readily consumed, the potential for foodborne illness in
drug residues and metals) falls under the authority of the the pet is expected to be similar to that for people in the same
European Union (EU) (Ministry of Agriculture, Fisheries and household. Some health-conscious pet owners forgo commer-
Food, 1995). Control measures are implemented on a national cial foods and, instead, prepare foods for their pets daily. These
basis and can be stricter but never more permissive than the EU owners must be fastidious and very careful about preparing and
legislation. Non-EU foreign countries regulate pet food safety storing their pets’food,and truly be committed to the long-term
with a variety of internal regulations and policies. maintenance of proper hygiene and preparation methods.
Most regulatory agencies, both domestic and international, Otherwise, the best method to lessen the risk of foodborne ill-
use monitoring programs to maintain surveillance over pet food ness is to feed the pet a high-quality commercial pet food man-
products. Specifically, in the United States, the FDA monitors ufactured by a company that uses state of the art quality control
pet food and individual pet food ingredients for pesticides, procedures. There are no such requirements or regulations for
mycotoxins and heavy metals as part of its Feed Contaminants pet food manufacturers to do so and most do not; however,there
Program (Van Houweling et al, 1977). are a few world-wide manufacturers that maintain self-imposed
Intrastate pet foods are under less federal scrutiny, with pri- rigorous product quality control procedures.
mary regulation left to state and local officials.This relationship
has created concern that unsuitable food components, most
notably mycotoxin-contaminated grains, may be used inadver- RAW INGREDIENT DIETS
tently (Nicholson, 1986). In addition, such products are often
pelleted instead of extruded; therefore, processing temperatures Feeding raw ingredient diets (commercially available or home-
may not be sufficient to kill bacteria and inactivate heat-labile made) to household pets has become increasingly popular.