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Monday, August 4, 2008

Pentobarbital Is Killing Eagles But the FDA Says It's Safe for Pets

by Susan Thixton

Just when you think you've seen it all and nothing would be too shocking to learn or read about the pet food industry, you stumble across something that causes your jaw to drop. I stumbled across something that proves once again –- you can't be too careful about the food and treats you give to your pet.

First – a little background information. Back in 2002, the FDA released a report of their 2-year study/testing finding pentobarbital (the drug used to euthanize animals) in pet food. Their findings were that many brands of pet foods –- purchased right off of store shelves -- contained the euthanizing drug pentobarbital. With that finding, the FDA began an 8-week test to see if levels of pentobarbital in pet food could be harmful to pets. The FDA testing showed that the amounts of pentobarbital in pet food would not harm pets (even though their study only tested dogs). You should know that the FDA ran their testing on 42 twelve week-old Beagles –- and again the testing was only for 8 weeks.

Pentobarbital was found in many pet foods yet was determined by the FDA not to be harmful to pets. And one more time –- the testing to determine this only lasted 8 weeks even though our pets might be eating this euthanizing drug in pet food their entire life.

So, to the point of this article -- I just stumbled upon a U.S. Fish and Wildlife report that stated pentobarbital is considered an environmental hazard "responsible for the deaths of over 140 Bald and Golden Eagles in recent years -- as well as numerous other wildlife and dogs." Other wildlife named in the report were California Condors, Vultures, Hawks, Wood Storks, Gulls, Crows, Ravens, Bears, Lynxes, Foxes, Bobcats, and Cougars.

This report stated the reason the wildlife was exposed to pentobarbital is from access to euthanized carcasses of farm animals and small animals in land fills. "Poisonings due to accidental feeding of tainted meat to captive animals have also been reported."

In big bold letters the report stated "Poisoning of eagles or other wild birds, even if accidental, violates Federal law!" This report also stated that Veterinarians and livestock owners have been recently fined for 'involuntary killing' of eagles. "Veterinarians must inform clients that a pentobarbital euthanized carcass is poisonous and requires proper disposal. The client needs to know that the carcass can poison and kill scavenging animals, including federally protected species, other wildlife, or even pet dogs."

Even though the FDA determined through their eight week test that pentobarbital in pet food was Not harmful to our pets, the U.S. Fish and Wildlife Agency is saying that pentobarbital euthanized carcasses are killing wildlife, including endangered species. Do we have a conflict between Federal Agencies?

As I wondered about the 'conflict' between the FDA and the U.S. Fish and Wildlife Agency, I continued to dig a little further, and that's when I found the jaw dropper document. I wondered if the FDA had any information regarding the U.S. Fish and Wildlife report –- and low and behold, I found something...Dated July 21, 2003 (a little over a year after the FDA's report that pentobarbital found in pet food was determined to be safe for our pets to consume) –- the FDA posted a change in the labeling requirements for pentobarbital and a change in the definitions. The following are the quoted changes... "Special considerations. Product labeling shall bear the following warning statements: ENVIRONMENTAL HAZARD: This product is toxic to wildlife. Birds and mammals feeding on treated animals may be killed. Euthanized animals must be properly disposed of by deep burial, incineration, or other method in compliance with state and local laws, to prevent consumption of carcass material by scavenging wildlife." And "Limitations. Do not use in animals intended for food."

So this is what we have: Euthanized animals are being rendered and the end ingredients become ingredients used in pet food. The FDA determined that the pet food/treat ingredient most likely to contain pentobarbital is Animal Fat. Pets are consuming pentobarbital as you read this right now.Pentobarbital euthanized animal carcasses are killing wildlife. The FDA's own rules for the drug specify its limitations 'not for use in animals intended for food.' Yet it's still there. Granted, and geez I hate to give them this, the amount of pentobarbital in pet food –- since it is found in only some pet food and pet treat ingredients (but some very commonly used ingredients) –- is not at the same levels as would be consumed by wildlife in a euthanized carcass. But come on folks (FDA, CVM, and AAFCO) –- can you not add two and two and come up with four?

Personally, I think the FDA should again test pet food for pentobarbital and any dog food, cat food, dog treat, or cat treat (and any other animal feed for that matter) that contains even the slightest bit of the drug –- the manufacturer should be heavily fined. With respect to our national treasures –- the Bald Eagles and Golden Eagles: "The laws provide for substantial fines and prison sentences in criminal cases. For example, the maximum fine for violating the Eagle Act is $100,000.00 for a person or $200,000.00 for an organization and one year in prison." Under Federal Law 'intent' is not required for conviction –- criminal convictions require the violation be 'knowingly' committed. With respect to our pets, we've got a 'knowingly' committed act. The guilty pet food manufacturers knowingly purchase ingredients that contain pentobarbital. Yet no one fines them for breaking the law.

One year (2002) the FDA determines pentobarbital in pet food is perfectly safe for our pets to consume, and the very next year (2003) they determine pentobarbital an environmental hazard responsible for killing over 140 eagles. No further study or regulation change within the FDA has occurred since the 2003 label change. Did they forget about our pets? I think so.

Eagles are a national treasure –- no grey area there. Our pets are a treasure as well. They enhance our lives. They are family. To allow pentobarbital euthanized animals to be cooked and placed into pet food is criminal and should be stopped immediately.

One more quote from the FDA document dated July 21, 2003, "This rule does not meet the definition of "rule" in 5 U.S.C. 804(3)(A) because it is a rule of "particular applicability." Therefore, it is not subject to the congressional review requirements in 5 U.S.C. 801-808." I'm just guessing that the above quote means 'let's keep this quiet. After all, if people find out about this, we might have to go back and change what we said about pet food.' Just a guess.

Wishing you and your pets the best.

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