Avian Flu Diary: US FDA Issues New Requirements For Pet Food Manufacturers - APHIS Updates Turkey Surveillance Policies

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Late yesterday the U.S. FDA announced that manufacturers of cat and dog foods need to reanalyze their food safety plans to include HPAI viruses (specifically H5N1) as a known or reasonably foreseeable hazard.

This comes following a number or wild and domestic cat infections (including deaths) from the H5 virus after consuming `raw' pet food products, and has led to several recalls (see LA County Animal HAN: H5 Bird Flu Confirmed in Three Additional Domestic Cats in LA County & in One Commercially Available Raw Pet Food Product).

Technically, pet foods in the United States are required to be `fit for human consumption', although there is some leeway in those regulations. This from the FDA:

The Food and Drug Administration (FDA) regulates pet food similar to that for other animal foods. The Federal Food, Drug, and Cosmetic Act (FD&C Act) requires that all animal foods, like human foods, be safe to eat, produced under sanitary conditions, contain no harmful substances, and be truthfully labeled. In addition, canned pet foods must be processed in conformance with the low acid canned food regulations to ensure the pet food is free of viable microorganisms, see Title 21 Code of Federal Regulations, Part 113 (21 CFR 113). For more information about low-acid canned foods, see Acidified & Low-Acid Canned Foods Guidance Documents & Regulatory Information.

Generally speaking, the FDA considers meat, poultry, and grain to be safe for consumption. But these assumptions were created before the introduction of HPAI viruses to livestock. Yesterday APHIS announced the following inspection change for turkeys, due to the virus.

APHIS Updates Policy to Enhance Surveillance of Turkey Flocks in Highly Pathogenic Avian Influenza Affected States
Press Release
Media Contact:
aphispress@usda.gov
WASHINGTON, January 17, 2025—As part of its ongoing, multi-faceted efforts to combat the spread of highly pathogenic avian influenza (HPAI), USDA’s Animal and Plant Health Inspection Service (APHIS) today is updating its policy for pre-slaughter surveillance to enhance testing of turkey flocks in affected states. In late December 2024, APHIS became aware of a genetic link between turkeys potentially infected with HPAI H5N1, virus detected in raw pet food, and an infected household cat.
Out of an abundance of caution, and to remove a potential avenue for ongoing disease spread as well as to bolster consumer and trading partner confidence, APHIS collaborated with state animal health officials and the poultry industry to update its guidance for existing pre-slaughter surveillance steps to further ensure that affected poultry does not enter the food system. APHIS will continue to report confirmed HPAI detections to the World Organisation for Animal Health and on the APHIS website (more information below).
These updates include implementing isolation with clinical monitoring and premovement testing 72 hours prior to sending to slaughter, for turkey premises outside control areas in HPAI-affected states. Specifically, APHIS will be piloting this enhanced pre-slaughter surveillance, starting with turkey premises greater than 500 birds in Minnesota and South Dakota, based on current and historical HPAI detections of commercial turkey premises in these states. These states were selected because of genetic linkages to virus from infected cats and because of the high percentage of cases in turkeys in those states. APHIS will continue to evaluate progress of the outbreak and may update this policy, if needed, to include additional states.

The FDA's new ruling follows, after which I'll have a postscript.

Cat and Dog Food Manufacturers Required to Consider H5N1 in Food Safety Plans
January 17, 2025
The U.S. Food and Drug Administration has determined that it is necessary for manufacturers of cat and dog foods who are covered by the FDA Food Safety Modernization Act Preventive Controls for Animal Food (PCAF) rule and using uncooked or unpasteurized materials derived from poultry or cattle (e.g., uncooked meat, unpasteurized milk or unpasteurized eggs) to reanalyze their food safety plans to include Highly Pathogenic Avian Influenza virus (specifically H5N1) as a known or reasonably foreseeable hazard. Furthermore, the FDA is issuing this update to ensure that cat and dog food manufacturers are aware of information about the new H5N1 hazard associated with their pet food products, which is an additional reason that manufacturers must conduct a reanalysis of their food safety plans.
The FDA is tracking cases of H5N1 in domestic and wild cats in California, Colorado, Oregon and Washington State that are associated with eating contaminated food products. Scientific information is evolving, but at this time it is known that H5N1 can be transmitted to cats and dogs when they eat products from infected poultry or cattle (e.g., unpasteurized milk, uncooked meat, or unpasteurized eggs) that have not undergone a processing step that is capable of inactivating the virus, such as pasteurizing, cooking or canning. Cats (domestic and large felids) in particular can experience severe illness or death from infection with H5N1. Dogs can also contract H5N1, although they usually exhibit mild clinical signs and low mortality compared to cats. At present, H5N1 has not been detected in dogs in the United States, but there have been fatal cases in other countries.
The FDA Food Safety Modernization Act Preventive Controls for Animal Food (PCAF) rule requires that certain animal food businesses develop a food safety plan. In this food safety plan, animal food businesses must identify and evaluate known or reasonably foreseeable hazards for each type of animal food manufactured, processed, packed, or held at their facility to determine whether there are any hazards requiring a preventive control. Businesses must identify these hazards based on experience, illness data, scientific reports, and other information. In the hazard evaluation, animal food businesses must assess the severity of the illness or injury to humans or animals if the hazard were to occur and the probability that the hazard will occur in the absence of preventive controls. The animal food industry can find guidance related to these requirements in the FDA’s Center for Veterinary Medicine’s Guidance for Industry #245, “Hazard Analysis and Risk-Based Preventive Controls for Food for Animals.”
Under the PCAF requirements, animal food businesses must conduct a reanalysis of their food safety plan when the FDA determines it is necessary to respond to new hazards and developments in scientific understanding. The FDA has determined that it is necessary for cat and dog food manufacturers covered by the PCAF rule, who are using uncooked or unpasteurized materials derived from poultry or cattle (e.g., uncooked meat, unpasteurized milk, unpasteurized eggs) in cat or dog food, to reanalyze their food safety plans to include H5N1 as a new known or reasonably foreseeable hazard.
The reanalysis is necessary to respond to the recent domestic cat illnesses and deaths described above and to scientific data indicating that cats and dogs have become ill from consuming H5N1 virus. Manufacturers that implement a preventive control for the H5N1 hazard as a result of their reanalysis will be taking an important step toward protecting cat and dog health and helping to prevent spread of H5N1. Addressing H5N1 will require a concerted effort across sectors, including by government, businesses, and consumers.
Manufacturers also are required to conduct a reanalysis of their food safety plans when they become aware of new information about potential hazards associated with animal food. The FDA and the American Veterinary Medical AssociationExternal Link Disclaimer have previously published information on risks to pets from H5N1, which has been amplified in mainstream media. Some additional published references are listed below.
As we learn more about the transmission of H5N1 in animal food, there are several practices that the FDA is encouraging pet food manufacturers and others in the supply chain to use to significantly minimize or prevent H5N1 transmission through animal food. These practices include seeking ingredients from flocks or herds that are healthy, and taking processing steps, such as heat treatment, that are capable of inactivating viruses. For example, some businesses already implement a heat treatment step that is capable of inactivating the virus as a process control. Heat treatments have been shown to be effective for inactivating H5N1 in meat, milk, and egg products. A different practice would be to implement a supply-chain-applied control to provide assurance that ingredients used in animal food do not come from H5N1-infected animals.
To assist animal food businesses as they conduct their reanalysis, we have included a summary of current scientific literature regarding (1) the prevalence of H5N1 in cattle and poultry and their animal-derived ingredients, (2) the severity of H5N1 illness or injury in cats and dogs, and (3) the impact of processing steps on inactivating H5N1.
The FDA and the United States Department of Agriculture (USDA) remain confident in the safety of the food supply. USDA’s Food Safety and Inspection Service, Animal and Plant Health Inspection Service, and Agricultural Research Service (ARS) have completed multiple studies to confirm that meat, poultry and eggs that are properly prepared and cooked are safe to eat. Additionally, to verify the safety of the meat these agencies have completed three separate beef safety studies related to avian influenza in meat from dairy cattle. Furthermore, USDA and the U.S. Food and Drug Administration (FDA) have performed multiple retail sampling studies to reaffirm the safety of the pasteurized milk supply and milk products.

While government agencies `remain confident in the safety of the food supply', the reality is raw milk continues to be sold in most states across the nation (see map below).

And, despite frequent assurances from the USDA and other agencies that `Avian influenza is not transmissible by eating properly prepared poultry, so properly prepared and cooked poultry and eggs are safe to eat.' - there is a catch.

As we discussed in Mixed Messaging On HPAI Food Safety, there may be some risks entailed in the preparation of raw poultry. PAHO (the Pan-American Health Organization) mentions this on their Avian Influenza landing page:

Transmission

The most common way for the virus to enter a territory is through migratory wild birds. The main risk factor for transmission from birds to humans is direct or indirect contact with infected animals or with environments and surfaces contaminated by feces. Plucking, handling infected poultry carcasses, and preparing poultry for consumption, especially in domestic settings, may also be risk factors.

Similarly, last August the WHO published Interim Guidance to Reduce the Risk of Infection in People Exposed to Avian Influenza Viruses, which lists a number of `risk factors', including:

keep live poultry in their backyards or homes, or who purchase live birds at markets;

slaughter, de-feather and/or butcher poultry or other animals at home;

handle and prepare raw poultry for further cooking and consumption;

Unfortunately, very little is published specifically about the risks from HPAI during food preparation, with links usually to generic `safe poultry handling' advice (see USDA's massive Chicken from Farm to Table webpage, where HPAI is never mentioned).