Finally, an explanation from the consumer’s side.
(Thanks to Halm for posting the link to “ourdogsonline” blog and the recent Natura post regarding test results.)
I’ve received some questions regarding the difference in test results, so I thought it might be helpful to hear an explanation from the consumer’s side.
Submission of Samples for AnalysisWe purchased 2 bags of dog food and the chunks were in both bags. We submitted two samples for analysis from each bag. There was a general scoop of kibble from the bag and a separate sample with the most prominent chunks. We also submitted photos of the most prominent chunks so there would be no question what we were referring to. Identical samples were sent to Natura’s manufacturing plant and Expertox Lab.
Donna’s Analysis 1. Expertox Lab
Sample(s) Received: May 25, 2007 Sample(s) Tested: June 4, 2007
ExperTox tests to 0.1 ppm.
“Unknown Chemicals and Other Toxins” scan
A. General Scoop from Kibble – this yielded no detection of toxins.
B. “Chunks” – yielded detection of cyanuric acid at 3.71 ug/g and trace of acetaminophen.
Natura’s Analysis at 3 Laboratories NOTE: This is per my review of the analysis reports posted on the company’s website which Mr. Atkins provided the link. I will post from those test results below and follow with my comments regarding important points to consider.
1. Midwest Lab -
Sample(s) Received – June 14, 2007 Sample(s) Tested – June 14, 2007
Midwest tested to 10 ppm.
A. “PER 07-5519 Bag 1” – melamine and cyanuric acid – not detected
B. “PER 07-5519 Bag 2” – melamine and cyanuric acid – not detected
C. “Premium Dog Vitamin” – melamine and cyanuric acid – not detected
(Note PER 07-5519 is the case number they assigned to us.)
Midwest Labs tests to 10 ppm. Thus, they are not going to detect anything below 10 ppm. My result for cyanuric acid was 3.71 ug/g – so this lab would not have detected cyanuric acid. My result was for a trace of acetaminophen – so this lab would not have detected acetaminophen.
Question –
Would you want to know if there was any cyanuric acid or acetaminophen or any other toxin in your pet food?
---- or ----
Are you “ok” knowing there may be some level of toxin in your pet food, however it’s under 10 ppm?
The FDA stated
traceable amounts of melamine are considered
adulteration. Thus, I would think any other compound not approved for use in pet food would also be adulteration.
Reference - the April 19, 2007 FDA Press Conference regarding Pet Food,
David Kerley of ABC asked “Can you explain it from a food (science) purpose or reason why the company wanted to do it?”
(his reference is to adding melamine to protein supplements).
Dr. Stephen Sundlof, Director, FDA Center for Veterinary Medicine – “the motivation would be economic”
Michael Rogers, FDA, Office of Regulatory Affairs, Director, Division of Field Investigations – “the headline is,
it shouldn’t be there and raw materials and finished pet foods that contain traceable amounts of melamine are considered adulterated”
http://www.fda.gov/oc/opacom/hottopics/petfood/transcript041907.pdf
2. UC Davis
Sample(s) Received – July 5, 2007 Sample(s) Tested – July 10, 2007
UC Davis tested to 1 ppm
A. “Composite #1” – Acetaminophen – not detected
B. “Composite #2” – Acetaminophen – not detected
UC Davis tested for acetaminophen at 1 ppm.
Why did they test a production sample at UC Davis and not my sample? Quoting: “We also sent representative samples of the production run of Donna’s food for additional testing at UC Davis and Expertox; all of which came back negative.”
http://www.itchmo.com/read/innova-testing-results-posted-by-ceo-of-naturapet_20070724#comment-39706and
http://www.ourdogsonline.com/ubbthreads.php/ubb/showflat/Number/125393#Post125393Consider this – We discussed our concerns regarding levels of detection in testing with Mr. Atkins on June 13. He addressed those concerns with us on June 15. “He stated he consulted with a vet nutritionist at UC Davis who told him it was “
impossible” to test at levels to 0.1 ppm. The vet consultant said you would do good to get 10 ppm, but anything less than 10 ppm was
impossible and that you would run a greater risk of false readings.
Thus, why would UC Davis test for acetaminophen at a level of 1 ppm?
Which statement from UC Davis should we believe –
the one that says it is “impossible” to test below 10 ppm
-- or --
the analysis that was completed by UC Davis which tested at 1 ppm?
Why did UC Davis only test for acetaminophen? What about cyanuric acid?”
If UC Davis had tested for cyanuric acid at 1 ppm they would have found it and, keep in mind, the toxins were detected in the chunks, not the overall kibble sample.
Another point to consider – research the EPA and pesticides. A very smart friend passed this along to me. Melamine is a byproduct (metabolite) of cyromazine which is a pesticide. The EPA documents tolerances for residues for cyromazine and certain food products and the tolerance levels go as low as 0.5, 0.1, and 0.05ppm.
Thus, if the EPA references testing tolerance levels to 0.05ppm, it must be possible.
3. ExperTox Lab
Sample(s) Received – July 6, 2007 Sample(s) Tested – July 20, 2007
ExperTox tested to 0.1 ppm
A. “pet food” – unknown chemicals and other toxins – not detected
(Details: melamine, cyanuric acid, acetaminophen all non-detected)
Again, why did they test a production sample at ExperTox and not my sample? (reference above)
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In summary, as a pet owner and a consumer you have to make the decision for what
you feel is safe. We have all heard about dilution factors, low risk, etc., but we have also heard about redacted ingredients and lack of regulation. And “yl” had an excellent question – “…can what ever made my pets sick have any long term effects?” We can only hope it will not.
My parents used to say, “if you want something done right, do it yourself.” My pets will not be fed commercial foods any longer and I will not be "fed" confusing information any longer. It’s up to us to find the answers.
Donna