THE PUSHBACK THAT PET MANUFACTURERS HAVE BROUGHT FORWARD(from Diamond Pet Food)
- Diamond Pet ships over 425,000 units of Taste of the Wild every week. After going through the FDA’s report, of the 53 cases gathered over 5 years, less than 30 cases were from atypical DCM breeds. It is completely illogical that we can ship over 15 million units of product and be causing a disease that will only show up 20-25 times over 5 years.
- Without a baseline understanding of how frequent DCM is, how can the FDA claim that the reports received are “unusual”? How is that defined/what does it mean? Other data suggest that DCM is not increasing (as reported by Eva Oxford, DVM, PhD, DACVIM Cardiology, Cornell University). How is it possible for grain free diets to grow from 0% to 25% of the market over 10 years without raising the incidence of DCM?
- While the FDA indicates that they “began an in-depth investigation”, those who have met with them about this issue suggest that only one person at FDA is regularly working on this topic – assessing dog medical reports and data, but doing no independent scientific work, and that the agency is relying on outside support, largely from the Chesapeake Veterinary Cardiology Associates, which many are concerned has a biased view against grain-free foods. For instance, at this link on a CVCA website, they “suggest alternate diets” to grain free, while the FDA has not taken such a step.
- By the nature of the letter, the FDA implies that they have assessed the linkage of diet to DCM without considering other possible causes. We are now bringing forward data to show that litter size/birth weight, obesity, intestinal microbiome are among other possible causes that the FDA should be investigating. Inherited (genetics) should be added as a possible cause. Considering the FDA still includes Dobermans, Great Danes, and multiple other dogs known to have a genetic link, it is important to note genetics.
- The FDA’s note about continuing to receive reports is not surprising, as age has an effect on DCM, so more dogs will develop the condition and this would be natural. And as the media has reported on the FDA’s investigation, it would lead more pet owners and vets to send in reports. In addition, these reports likely include ‘look-alike’ cases, where dogs may have other heart health conditions that on initial assessment may resemble DCM but are possibly other conditions. However, the FDA has been selective in seeking and collecting reports of dogs with DCM that eat grain-free but omitting those (and/or not asking for) reports of dogs with DCM that eat grain-based foods. Why hasn’t the FDA asked for reports from all dogs suffering from DCM symptoms, not just those that were fed grain-free?
- Research suggests DCM occurs in dogs at between 0.5-1.1% of the population. Even when we factor in a 200x underreporting we are only looking at 0.15% of the population.
- To the best of our knowledge, the manufacturers have not shared formula information with the FDA, so it is unclear how the FDA can claim that current grain-free diets have higher proportions of pulse crop ingredients. What is their data to support this claim? Also, since the FDA has not actively engaged the industry – rather, the manufacturers have had to pursue meetings with the FDA – their claim to have reached out to industry does not coincide with the experiences of the manufacturers I have interacted with.
- Dogs given medication and prescription diets will often show improvement. That is distinct from the substance of their diet. The FDA conflates medication and diet change, when the two are separate. Unless they have controlled for each change in assessing individual dogs’ recovery, they don’t have a basis to make this universal claim.
- The FDA has included brand names without context, including how much pulse crop ingredients are in a certain food, how many cases there are relative to total market share, and whether a brand has grain-based as well as grain-free lines. The FDA also arbitrarily chose to list 16 brands, while there were others that were included in DCM dog reports, that the agency chose to omit.
FALLOUT FROM THE VET COMMUNITY’S ADVANCEMENT OF THE FDA ANNOUNCEMENT
- Negative Pet Health Consequences There are negative consequences that take place when a dog’s diet is abruptly changed. That’s why every pet food bag sold includes transition instructions. Those dogs benefiting from low glycemic diets are now in jeopardy of their care givers changing their diet for fear the ingredients may be unsafe, only to cause direct harm by doing so. This situation was reinforced by a communication from the Pennsylvania Veterinary Medical association in an opinion editorial on July 15 (see Appendix Exhibit B). FDA is totally ignoring the possibility that there are dogs that do better, thriving on grain fee recipes.
- Negative Food Sustainability and Carbon Footprint Consequences The advent of using legumes in pet food allowed formulations to deliver protein with lower requirements for meat content. Legumes such as peas and lentils deliver 3 times the protein found in grains such as rice and corn. Consumers are now leaving foods that contain legumes in droves. Converting to foods without legumes will require increased meat usage in order to deliver equivalent amounts of protein. Increased meat usage does 2 things:
- The pet food category becomes increasingly competitive with the human food sector, reducing the sustainability of animal protein.
- The carbon footprint of pet food manufacturing is increased, caused by a 20% addition of protein from meat, and 20% less from plant.
- Negative Environmental Consequences Legumes are exceptional rotational crops that restore nitrogen to the soil, allowing for reduced fertilizer application. The pet community has created a significant value chain to vegetable farmers. It is good for the agricultural economy, and it is good for the environment.
- Negative Economic Consequences for Small Business Owners It is estimated that the store traffic in the pet specialty sector (Family Owned) has been reduced by 30% since the 3rd FDA announcement on June 27. This sector is the most heavily dependent on grain free sales, some as high as 85% grain free. They won’t be able to pay their rent.
- Ingredient Supply Chain Devastation Ten years ago, pea & lentil growers had only one profitable outlet for cull peas—international exports. The rest were sold off for livestock use. The advent of the pet food sector has given them two profitable outlets. However, since June 27, spot prices for cull peas and lentils have cratered upwards of 30%. It will get worse before it gets better. Many growers still have some bushels under contracts with pet food manufacturers that have not yet expired. As those contracts elapse, prices will continue to slide. Many of these farmers were already suffering from trade tariffs. It is no overstatement to suggest that there will be operations that fall into receivership.
- Negative Consequences for Pet food Manufacturers Those manufacturers that have helped establish these important supply chains for agriculture have had their brand names tarnished, despite the fact that no DCM connection to diet has been established by the FDA. FDA had no proof of a connection, yet they published 16 brand names regardless. Those brands have lost anywhere from 15-40% in sales, just since June 27. For companies like Diamond that have alternative grain-based recipes, the loss is not as stark.
WHO IS DIAMOND PET FOOD?
Diamond Pet Foods® is a privately held, family-owned enterprise. Founded in 1970 by two brothers-in-law, Gary Schell & Richard Kampeter, Diamond specializes in the manufacture of dry super-premium dog and cat foods.