By Devon McPhee

La Petite Ranch of Ferndale, Wash., makes Bit O' Luv dog and cat treats. It purchases the chicken liver and beef liver for its treats from local wholesalers or meat companies, said Cheryl Anne Weismantel, director of the company.

Its proximity to the Canadian border allows for brisk business with the United States' northern neighbor at least for some of the treats it manufactures.

"Canadians purchase the treats in Blaine, Wash., and are able to take the chicken treats over the border, but not the beef," Weismantel said.

Canada has placed restrictions on the importation of U.S. beef products to prevent the spread of bovine spongiform encephalopathy (BSE), or mad cow disease. The United States has similar restrictions on Canadian beef.

Many manufacturers have special ovens for baking treats. Courtesy of La Petite Ranch

BSE is one of numerous global health issues impacting the importation and exportation of pet treats in the United States, creating a maze of regulations and restrictions for manufacturers.
World health issues, including avian influenza and hoof and mouth disease, take on special significance because many American companies outsource the manufacture of their treats to foreign countries, such as China and Brazil.

Yet federal regulations and proper quality-control procedures should eliminate any possibility of contamination, regardless of the product's country of origin, according to manufacturers and government officials.

Border Controls
Pet treats of foreign origin bound for the United States must meet the same standards and requirements as domestic treats, according to the U.S. Food and Drug Administration's Center for Veterinary Medicine (CVM). Unlike domestic products, the FDA may refuse entry of products of foreign origin if they "appear" to violate U.S. food laws. It's a lesser standard than is required to claim that domestic treats violate food laws, according to CVM.

To minimize the risk of BSE, the U.S. Department of Agriculture has banned beef or beef products from countries with a high incidence of the disease, which includes the majority of countries in the European Union. It has also restricted the types of animal by-products domestic manufacturers can use in pet treats.

Countries with outbreaks of bird flu cannot export fresh, chilled or frozen poultry or eggs into the United States, but the USDA does allow importation of cooked poultry or egg products from these countries.

Ingredient testing, whether it's done by the manufacturing company or by an outside quality assurance firm, helps monitor treat safety. Courtesy of Shuster Laboratories Inc.

The heat treatment processes used during the production of most pet treats kills most viruses, including the avian influenza virus and hoof and mouth disease, and most bacteria, including salmonella, said Linda Grassie, a spokeswoman for CVM. For instance, cooking poultry or eggs to 165 degrees Fahrenheit kills the bird flu virus if it is present, according to the FDA.

"Provided the temperatures and cooking times are adequate to kill the viruses and bacteria and the products aren't recontaminated by these agents after being cooked, the manufacturing process should take care of such contaminants," Grassie said.

Safety Procedures
On top of federal regulations, a manufacturer institutes quality-control procedures within its facilities to minimize the risk of treat contamination.

To prevent mold, salmonella and e. coli, a manufacturer must thoroughly clean and sanitize its equipment, Weismantel said.

"As soon as you open your oven, even for human food, there is danger of bacteria seeping into it," she said. "This can happen to any large or small company, so the key is cleanliness."

Re-contamination of treats can occur if manufacturers do not enforce the separation of raw materials and finished products, said Joel Adamson, senior vice president of business development and marketing services for Sergeant's Pet Care Products Inc. of Omaha, Neb.

"A well-run facility will keep raw, uncooked products in one area of the facility and finished material in another area," Adamson said, adding that it would also control the flow of employees between the two areas, minimizing the risk of employees handling raw materials also handling the finished product.

Many manufacturers monitor treat safety by periodically testing raw materials in-house or through an outside product testing and quality assurance firm, said Philip Katz, senior vice president of one such firm, Shuster Laboratories Inc. of Canton, Mass.

Tests will detect any deleterious heavy metals and microbiological contaminants, such as pathogens, he said.

Manufacturers may test finished products for moisture and pH levels, which indicate whether a treat has been formulated properly, Katz said.

Companies may also choose to audit the quality-control measures used in their plants to measure effectiveness and pinpoint possible areas of improvement, Katz said. Quality assurance firms can audit both domestic and foreign facilities, he said.

Traceability of products from animal to finished treat becomes important if contamination arises, said Katz. Pinpointing the source of contamination can limit the scope of recalls to only those products manufactured at the site of contamination, and alert manufacturers to the problem areas, he said.

Monitoring the quality-control processes of foreign manufacturing facilities takes one of two forms.

If an American company owns its manufacturing facilities abroad, its U.S. division should help to assure that its foreign factories comply with U.S. requirements, said Mel Drozen, a partner at Keller & Heckman LLC, a Washington D.C.-based law firm with expertise in international and food law.

If it has a foreign co-manufacturer, the U.S. company should send personnel to monitor the facility's quality-control procedures to assure U.S. compliance before manufacturing begins, then periodically checks procedures throughout the relationship of the two companies, he said.

Labeling Laws
A manufacturer's responsibility for the safety of its treats extends to their consumption, said David Syverson, chair of the Association of American Feed Control Officials' pet food committee. A manufacturer must provide consumers with information on the proper use of its product, feeding instructions and, if necessary, appropriate warnings and cautions.

"Instructions should be prominently displayed so they can be easily observed by the customer under normal conditions of purchase," he said.

Treat labels must bear a guaranteed analysis that at the least contains the minimum percentages of crude protein and crude fat and maximum percentages of crude fiber and moisture, said David Dzanis, D.V.M., Ph.D., pet food nutritionist for the American Pet Products Manufacturers Assn.

Manufacturers cannot claim that their product treats or prevents a disease or condition, or affects the structure or functioning of the body beyond normal nutrition or taste, Dzanis said.

Manufacturers could use terms such as 'packed with protein for a healthy coat' or "helps freshen breath' on product packages without a problem, but claims to "promote a healthier coat," or "prevent halitosis," would likely violate FDA regulations, he said.

Treat manufacturers aren't under any obligation to make their treats nutritious, Dzanis said.
"By definition, pet treats are intended as an occasional reward or indulgence and not as the sole source of an animal's nutrition. As such, there are no specific nutritional requirements for treats,' he said.

Yet the majority of manufacturers make an effort to provide treats with some nutritional value. And Weismantel is one of them. She said she developed Bit O' Luv dog treats because she wanted a healthy, natural treat for her two pet collies.