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Sec. 690.700 Salmonella Contamination of Dry Dog Food (CPG 7126.17)

BACKGROUND:

In a case involving salmonellosis diagnosed in a mother, daughter and the family dog, the Milwaukee Health Department traced the cause to a dry dog food, and a recall resulted. Following the recall, *CVM* initiated an abbreviated inspection and analytical survey of a representative number of manufacturers of finished dry dog food products to explore an industry claim that it is an impossibility to manufacture this type of product without Salmonella contamination.

The survey resulted in the examination of 207 subsamples, only two *of which* representing two different manufacturers were found to be positive for Salmonella. The survey included nine (9) different manufacturing plants and eight (8) different manufacturers, and covered extruded coated chunk as well as extruded coated meal type dog foods. These findings indicate that such products can be manufactured free of Salmonella contamination.

Dried dog food products were reviewed in terms of product hazard characteristics and the human population exposure to establish a risk category and ultimately a statistically appropriate sampling technique for Salmonella organisms in ten separate subsamples of 25 grams each, there is a 95% confidence level that there will be less than 1 Salmonella organism in 83 1/3 grams of tested material. The hazard characteristics were chosen so as to parallel those for human food products sampled for Salmonella contamination, since dog food is usually brought into the home and often prepared in the same area where meals are prepared for humans. Also, dry dog food may be mixed with tap water and allowed to sit for long periods of time providing an appropriate substrate for the growth of these organisms. Moreover, pet food dishes may be readily available to crawling infants, may be washed in the same sink, and can otherwise serve as a direct source of Salmonella contamination in the home.

It was concluded that, based upon the sampling formula of 10 subsamples of 25 grams per sample and in light of the fact that dry dog food has characteristics that place it in a risk category, the presence of Salmonella contamination may not be permitted. That the industry can avoid Salmonella contamination was clearly demonstrated by the survey.

POLICY:

The *Center for* Veterinary Medicine will consider dry dog food adulterated under Section 402(a)(1) of the FD&C Act when Salmonella organisms are found in one or more samples out of 10 subsamples tested.

<> The action of choice will be recall of the involved product code or seizure, whichever is more appropriate to remove the adulterated material from the market.

*Material between asterisks is new or revised* <> Indicates material has been deleted

Issued: 10/01/80 Revised: 3/95