Animal Health Foundation Blog

Dr. Scott Weldy Receives Prestigeous AHF Cortese-Lippincott Award

January 16th, 2020 by Animal Health Foundation

Dr. Weldy Has Devoted His Career to Exotic Animals

By Jim Bell

When Scott Weldy was a kid in Mission Viejo, he would go hiking in the hills, catching snakes, lizards and other animals and bringing them home.  “I’ve always been interested in exotics,” he said.

That is probably more true now than it was then.  Dr. Weldy owns Serrano Animal and Bird Hospital in Lake Forest and he spends much of his time treating exotics of all species in three zoos and at his practice.  He also is director of the Orange County Bird of Prey Center.

On February 1 at the SCVMA Annual Celebration he will be presented with the prestigious Cortese-Lippincott Award.  That will be a special moment for Dr. Weldy.  He knew both men for whom the award is named but Dr. Joe Cortese was a good and special friend. He had met Dr. Larry Lippincott but did not know him well.

“I really loved Joe,” he said in an interview.  “I was a technician when I first met him. It’s an honor to be up there [for this award], especially because of Joe.  He was such a gem to me.  He was a good doctor but he was a great guy, too.  If I could be half the person he was, I’d be in good shape.  My wife Marie and I really enjoyed his wife Goldee – both of them.  They were nice people.

“The only reason most people get recognized,” he said, “is because they’re surrounded by a team of people that keeps them honest and humbled.  I’ve got a good group of people around me.  We’re all part of a good team and they support me.”

Dr. Weldy moved his practice to a new facility last January, more than doubling its square footage.  Five doctors work in the facility, two of them part time.

“Tuesdays we do the Santa Ana Zoo all day and Thursdays we spend most of the day at the Orange County Zoo, then finish up in Santa Ana,” Dr. Weldy said.  “There are always two of us.

“We go to the Exotic Feline Breeding Compound in Rosamond near Palmdale as we’re needed.  Sometimes we stay overnight.  It’s a breeding center for endangered species.  They’re all exotic types: ocelots, leopards, jaguars.”  He is the veterinarian of record there.

Dr. Weldy took over the Bird of Prey Center in 1990.  Now that his new hospital is up and running, his major goal, he said, is to get the center up to par.  “That’s the last major goal of my career,” he said. “It’s a nonprofit organization.  I’m the medical director and director of the operation.  The center focuses on raptor education, rehabilitation and release.

“It’s a dream I’ve been working on since 1998.  We have a chunk of land that has some cages on it and a small building.  We’re slowly building up the cages.  It’s a temporary facility right now but we do educational programs.  The center is tucked in the back area of Rancho Las Lomas in Santiago Canyon.”

The new center is being built off El Toro Road behind O’Neill Park on land generously leased by Orange County Parks, he said.  Eventually, it will be able to provide medical and educational functions and will be the Bird of Prey Center’s permanent home, replacing the Rancho Las Lomas facility.

“We’re trying to get grants and public money.  We’re also wrapping up endowments and trying to raise money to accomplish our goals,” Dr. Weldy said.  The center rehabilitates injured hawks and owls and releases them.

Raptors needing medical care are treated at Serrano Animal and Bird Hospital.  “That’s all free stuff,” Dr. Weldy said. “No one pays for it.  We’ve also treated racoons and bobcats, ring-tailed cats and weasels.

“We don’t do small birds.  We work with wildlife biologists, the U.S. Geological Survey and people in mountain lion groups.  Most of the time when wildlife is brought into the practice it’s by Animal Control, and sometimes by good sam[aritan]s.”

Dr. Weldy loves the desert.  “I still go out and hunt reptiles and stuff like that,” he said, “but now I hunt them for photos.  I’m more of a desert person than anything.”

Her loves restoring old cars.  He has a 1961 Volvo that is fully restored and a 1969 Camaro that is nearly restored.  He also has a ’67 Camaro in waiting.  The Volvo is a special car.  It has been in his family since it came off the show room floor.  “My grandmother owned it then.  It later became my first car.”

He loves driving “muscle cars” – and his motorcycle, he said.  He is planning a motorcycle trip to “Bike Week” in Daytona, Fla., with friends in March.  “I have relatives and friends all the way across the southern United States so we’ll see part of the U.S. and spend a couple of weeks doing it,” he said.

Dr. Weldy came to Southern California in 1966.  He earned a BS degree in 1979 and a DVM degree in 1985, both from UC Davis.  He returned to Orange County and El Toro Animal Hospital, where he had worked as a teenager, after he became a doctor. He worked there 10 years before starting his practice in 1996.

The year 2019 has not been a good one for Dr. Weldy.  Wife Marie died of cancer last May – eight days after his mother died.   He has a daughter, Jennifer, 34, who is a registered veterinary technician.  She is teaching at Orange County Veterinary Assistant School in Garden Grove, where she had studied.  His son, Robert, 30, does research work in human neurology.

Besides cars and motorcycles, Dr. Weldy loves travel and scuba diving.  “Almost everything I do is related to animals,” he said.  “There has got to be an animal in it somewhere.”

The Animal Health Foundation’s Cortese – Lippincott Award was created to recognize and honor an individual who has gone above and beyond in making the world a better place for both animals and humans.  The winner of this award has gone above and beyond in community service, service and education of the veterinary community and the human-animal bond.

The award was named in honor of veterinarians Larry Lippincott and Joe Cortese.

Veterinary euthanasia: the last act of love

January 16th, 2020 by Animal Health Foundation

from dvm360.com   2019-08-20

Mike Paul, DVM

When it comes to ending a pets life, many people wonder, How do vets do it? I consider ending an animals suffering to be one of the greatest responsibilities entrusted to the veterinary profession and one of the gifts many veterinarians take for granted.

When a pet’s quality of life declines so much that the owner is faced with having to make the decision to actively end that pet’s life, it can seem impossibly overwhelming. Euthanasia is a difficult discussion topic for both pet owners and pet care providers. The concept of proactively ending a pet’s life, regardless of the reason, brings up complex emotions and challenging ethical issues, especially as euthanasia for people is increasingly explored and legalized. After all, where is the line to be drawn when we discuss end-of-life issues? While animal euthanasia is almost universally accepted as humane and necessary when quality of life fades, very similar scenarios are commonly faced and debated in human health care.

Physician-assisted death, or “aid in dying,” is currently legal in a number of countries, including Canada, Belgium, the Netherlands, Luxembourg, Colombia, Switzerland, and parts of Australia and the United States (California, Colorado, District of Columbia, Hawaii, Montana, Maine [bill signed by the governor June 12, 2019], New Jersey [as of Aug. 1, 2019], Oregon, Vermont, and Washington). There is little question that as medical science advances and people are living longer, the progress of disease will change. People will become more involved in decisions about their own right to die, and a greater number of states, countries and societies will create a space for physician-facilitated death owing to physical and emotional pain as well as dignity and quality-of-life issues.

I cannot imagine the difficulty of making this ultimate decision for myself, nor can I imagine actively participating in the death of another human being even if they choose to end their life. And yet, all practicing veterinarians have participated in ending the suffering of animal life.

Of all my professional interactions with patients, caregivers and family members, by far the most emotional have revolved around issues of euthanasia. I have always viewed euthanasia as one of the greatest responsibilities entrusted to our profession and at the same time one of the gifts many veterinarians take for granted. Clearly, we all value the lives and welfare of our patients, but at times our abilities have been exhausted and we must consider the remaining options. After all, our professional oath dictates that our ultimate goal is to relieve suffering for those under our care.

An old friend recently said goodbye to his very special dog. Now, I know all pets are special to their caregivers, but even I cried at this pet’s passing despite not having seen the dog in years. As his pet parent (not a term I use often or take lightly) and I shared a tear, he raised the question, “How do you vets do it?”

It never gets easier, I started to explain, and as I spoke I recalled countless euthanasias I had performed over the course of my career. My own philosophy about ending a patient’s life is this: “Not a day too soon but not a moment too delayed.” The growing movement in the direction of pet hospice is based on that perspective. Saying goodbye to a beloved pet carries so many emotions and psychological steps that we sometimes gloss over them … until it is our pet and we experience it up close and personal.

For veterinarians, humane euthanasia is a way of ending pointless suffering in animals when all else has failed. It is often a difficult therapeutic option in the best interest of the animal and the family. In fact, we are obligated to consider euthanasia as an option to relieve suffering. It seems there is always another thing that can be done in an effort to forestall pain and death, but to what end? Sometimes it seems rather than extending life we wind up prolonging the death process.

Discussing death: an ongoing conversation

Click here for the dvm360 end-of-life toolkit, which includes articles, tips, handouts, videos and other tools designed to help veterinary professionals have thoughtful, meaningful end-of-life discussions with pet owners.

While animals are not thought to be self-aware or able to reflect on their own condition, and they cannot balance their suffering against time or pleasure or memories of better days, they are certainly sentient creatures capable of feeling physical and psychological pain. Yet, they are not in a position to make decisions about their own medical care. That responsibility falls on their owners.

For many pet owners, however, even the thought of losing a beloved pet can be too much to process. When a pet’s quality of life declines so much that the owner is faced with having to make the decision to actively end that pet’s life, it can seem impossibly overwhelming. How many times has an owner told me that they just wanted their pet to “die peacefully in its sleep”? Yet, very few animals die quietly in their sleep and even those pets too often have suffered needlessly until their body simply could not go on. A peaceful death is often only possible with the intervention of euthanasia.

As veterinarians, we are expected to be more objective and should work with owners to decide when euthanasia might be the kindest option, providing permission and support when the time arrives. Euthanasia is sometimes the last arrow in our quiver … the last act of love we can give.

Dr. Mike Paul is the former executive director of the Companion Animal Parasite Council and a former president of the American Animal Hospital Association. He is currently the principal of Magpie Veterinary Consulting. He is retired from practice and lives in Anguilla, British West Indies.

Debunking the “Alpha Dog” Theory

January 13th, 2020 by Animal Health Foundation

Exerting “dominance” over your dog is the wrong way to build a good relationship.

The alpha myth is everywhere. Google “alpha dog” on the Internet and you get more than 85 million hits. Really. While not all the sites are about dominating your dog, there are literally millions of resources out there – websites, books, blogs, television shows, veterinarians, trainers and behavior professionals – instructing you to use force and intimidation to overpower your dog into submission. They say that you, the human, must be the alpha. They’re all wrong. Every single one of them.

The erroneous approach to canine social behavior known as dominance theory (two million-plus Google hits) is based on a study of captive zoo wolves conducted in the 1930s and 1940s by Swiss animal behaviorist Rudolph Schenkel, in which the scientist concluded that wolves in a pack fight to gain dominance, and the winner is the alpha wolf.

The Origin’s of the “Alpha” Dog Theory

Schenkel’s observations of captive wolf behavior were erroneously extrapolated to wild wolf behavior, and then to domestic dogs. It was postulated that wolves were in constant competition for higher rank in the hierarchy, and only the aggressive actions of the alpha male and female held the contenders in check. Other behaviorists following Schenkel’s lead also studied captive wolves and confirmed his findings: groups of unrelated wolves brought together in artificial captive environments do, indeed, engage in often-violent and bloody social struggles.

The problem is, that’s not normal wolf behavior. As David Mech stated in the introduction to his study of wild wolves (Mech, 2000), “Attempting to apply information about the behavior of assemblages of unrelated captive wolves to the familial structure of natural packs has resulted in considerable confusion. Such an approach is analogous to trying to draw inferences about human family dynamics by studying humans in refugee camps. The concept of the alpha wolf as a ‘top dog’ ruling a group of similar-aged compatriots (Schenkel 1947; Rabb et al. 1967; Fox 1971a; Zimen 1975, 1982; Lockwood 1979; van Hooff et al. 1987) is particularly misleading.”

What we know now, thanks to Mech and others, is that in the wild, a wolf pack is a family, consisting of a mated pair and their offspring of the past one to three years. Occasionally two or three families may group together. As the offspring mature they disperse from the pack; the only long-term members of the group are the breeding pair. By contrast, in captivity unrelated wolves are forced to live together for many years, creating tension between mature adults that doesn’t happen in a natural, wild pack.

Dominance-Based Training is Disrespectful to Your Dog

But that’s all about wolves anyway, not dogs. How did it happen that dog owners and trainers started thinking all that information (and misinformation) about wolf behavior had anything to do with dogs and dog behavior? The logic went something like, “Dogs are descended from wolves. Wolves live in hierarchical packs in which the aggressive alpha male rules over everyone else. Therefore, humans need to dominate their pet dogs to get them to behave.”

Perhaps the most popular advocate of this inaccurate concept, Cesar Millan, is only the latest in a long line of dominance-based trainers who advocate forceful techniques such as the alpha roll. Much of this style of training has roots in the military – which explains the emphasis on punishment.

As far back as 1906, Colonel Konrad Most was using heavy-handed techniques to train dogs in the German army, then police and service dogs. He was joined by William Koehler after the end of World War II.

Koehler also initially trained dogs for the military prior to his civilian dog-training career, and his writings advocated techniques that included hanging and helicoptering a dog into submission (into unconsciousness, if necessary). For example, to stop a dog from digging, Koehler suggested filling the hole with water and submerging the dog’s head in the water-filed hole until he was nearly drowned.

Fast-forward several years to 1978 and the emergence of the Monks of New Skete as the new model for dog training, asserting a philosophy that “understanding is the key to communication, compassion, and communion” with your dog. Sounds great, yes? The Monks were considered cutting edge at the time – but contrary to their benevolent image, they were in fact responsible for the widespread popularization of the “Alpha-Wolf Roll-Over” (now shortened to the alpha roll). Reviewing the early observations of captive wolves, the Monks concluded that the alpha roll is a useful tool for demonstrating one’s authority over a dog. Unfortunately, this is  a complete and utter misinterpretation of the submissive roll-over that is voluntarily offered by less assertive dogs, not forcibly commanded by stronger ones.

The Monks also advocated the frequent use of other physical punishments such as the scruff shake (grab both sides of the dog’s face and shake, lifting the dog off the ground) and cuffing under the dog’s chin with an open hand several times, hard enough to cause the dog to yelp.

While professing that “training dogs is about building a relationship that is based on respect and love and understanding,” even their most recent book, Divine Canine: The Monks’ Way to a Happy, Obedient Dog (2007), is still heavy on outdated, erroneous dominance theory. Immediately following their suggestion that “a kindly, gentle look tells the dog she is loved and accepted,” they say “But it is just as vital to communicate a stern reaction to bad behavior. A piercing, sustained stare into a dog’s eyes tells her who’s in charge; it establishes the proper hierarchy of dominance between person and pet.” (It’s also a great way to unwittingly elicit a strong aggressive response if you choose the wrong dog as the subject for your piercing, sustained stare.)

Despite the strong emergence of positive reinforcement-based training in the last 20 years, the Monks don’t seem to have grasped that the “respect” part needs to go both ways for a truly compassionate communion with your dog. Perhaps one of these days . . .

The Birth of Positive-Reinforcement Training

Just when it seemed that dog training had completely stagnated in turn-of-the-century military-style dominance-theory training, marine mammal trainer Karen Pryor wrote her seminal book, Don’t Shoot the Dog. Published in 1985, this small, unassuming volume was intended as a self-help book for human behavior. The author never dreamed that her modest book, paired with a small plastic box that made a clicking sound, would launch a massive paradigm shift in the world of dog training and behavior. But it did.

police dog training

Forward progress was slow until 1993, when veterinary behaviorist Dr. Ian Dunbar founded the Association of Pet Dog Trainers. Dunbar’s vision of a forum for trainer education and networking has developed into an organization that now boasts nearly 6,000 members worldwide. While membership in the APDT is not restricted to positive reinforcement-based trainers, included in its guiding principles is this statement:

“We promote the use of reward-based training methods, thereby minimizing the use of aversive techniques.”

The establishment of this forum facilitated the rapid spread of information in the dog training world, enhanced by the creation of an online discussion list where members could compare notes and offer support for a scientific and dog-friendly approach to training.

Things were starting to look quite rosy for our dogs. The positive market literally mushroomed with books and videos from dozens of quality training and behavior professionals, including Jean Donaldson, Dr. Patricia McConnell, Dr. Karen Overall, Suzanne Hetts, and others. With advances in positive training and an increasingly educated dog training profession embracing the science of behavior and learning and passing good information on to their clients, pain-causing, abusive methods such as the alpha roll, scruff shake, hanging, drowning, and cuffing appeared to be headed the way of the passenger pigeon.

A Step-Backward for Positive-Reinforcement Training Techniques

Then, in the fall of 2004, the National Geographic Channel launched its soon-to-be wildly popular show, The Dog Whisperer. Dominance theory was back in vogue, with a vengeance. Today, everything from housetraining mistakes to jumping up to counter surfing to all forms of aggression is likely to be attributed to “dominance” by followers of the alpha-resurgence.

“But,” some will argue, “look at all the dogs who have been successfully trained throughout the past century using the dominance model. Those trainers can’t be all wrong.”

In fact, harsh force-based methods (in technical parlance, “positive punishment”) are a piece of operant conditioning, and as the decades have proven, those methods can work. They are especially good at shutting down behaviors – convincing a dog that it’s not safe to do anything unless instructed to do something. And yes, that works with some dogs. With others, not so much.

My own personal, unscientific theory is that dog personalities lie on a continuum from very soft to very tough. Harsh, old-fashioned dominance-theory methods can effectively suppress behaviors without obvious fallout (although there is always behavioral fallout) with dogs nearest the center of the personality continuum – those who are resilient enough to withstand the punishment, but not so tough and assertive that they fight back. Under dominance theory, when a dog fights back, you must fight back harder until he submits, in order to assert yourself as the pack leader, or alpha.

Problem is, sometimes they don’t submit, and the level of violence escalates. Or they submit for the moment, but may erupt aggressively again the next time a human does something violent and inappropriate to them. Under dominance-theory training, those dogs are often deemed incorrigible, not suitable for the work they’re being trained for nor safe as a family companion, and sentenced to death. Had they never been treated inappropriately, many might have been perfectly fine.

At the opposite end of the spectrum, a very “soft” dog can be easily psychologically damaged by one enthusiastic inappropriate assertion of rank by a heavy-handed dominance trainer. This dog quickly shuts down – fearful and mistrusting of the humans in his world who are unpredictably and unfairly violent.

Most crossover trainers (those who used to train with old-fashioned methods and now are proud to promote positive reinforcement-based training) will tell you they successfully trained lots of dogs the old way. They loved their dogs and their dogs loved them.

I’m a crossover trainer and I know that’s true. I also would dearly love to be able to go back and redo all of that training, to be able to have an even better relationship with those dogs, to give them a less stressful life – one filled with even more joy than the one we shared together.

We Aren’t Dogs, and Our Dogs Know It

Finally, the very presumption that our dogs would even consider we humans to be members of their canine pack is simply ludicrous. They know how impossibly inept we are, for the most part, at reading and understanding the subtleties of canine body language. We are equally inept, if not even more so, at trying to mimic those subtleties. Any attempts on our part to somehow insert ourselves into their social structure and communicate meaningfully with them in this manner are simply doomed to failure. It’s about time we gave up trying to be dogs in a dog pack and accepted that we are humans co-existing with another species – and that we’re most successful doing so when we co-exist peacefully.

The fact is, successful social groups work because of voluntary deference, not because of aggressively enforced dominance. The whole point of social body language rituals is to avoid conflict and confrontation, not to cause it. Watch any group of dogs interacting. Time and time again you’ll see dogs deferring to each other. It’s not even always the same dog deferring:

Dog B: Hey, I’d really like to go first. Dog A: “By all means, be my guest.” Dog B passes down the narrow hallway.

Dog A: “I’d really like to have that bone.” Dog B: “Oh sure – I didn’t feel like chewing right now anyway.” Dog A gets the bone.

Social hierarchies do exist in groups of domesticated dogs and in many other species, including humans, and hierarchy can be fluid. As described above, one dog may be more assertive in one encounter, and more deferent in the next, depending on what’s at stake, and how strongly each dog feels about the outcome. There are a myriad of subtleties about how those hierarchies work, and how the members of a social group communicate – in any species.

Today, educated trainers are aware that canine-human interactions are not driven by social rank, but rather by reinforcement. Behaviors that are reinforced repeat and strengthen. If your dog repeats an inappropriate behavior such as counter surfing or getting on the sofa, it’s not because he’s trying to take over the world; it’s just because he’s been reinforced by finding food on the counter, or by being comfortable on the sofa. He’s a scavenger and an opportunist, and the goods are there for the taking. Figure out how to prevent him from being reinforced for the behaviors you don’t want, and reinforce him liberally for the ones you do, and you’re well on your way to having the relationship of mutual love, respect, communication, and communion that we all want to have with our dogs.

Pat Miller, CBCC-KA, CPDT-KA, is WDJ’s Training Editor. Author of numerous books on positive dog training, she lives in Fairplay, Maryland, site of her Peaceable Paws training center, where she offers dog training classes and courses for trainers.

You Can Speak Dog Too. Here’s How

January 7th, 2020 by Animal Health Foundation

Whole Dog Journal – Tip – January 7, 2020

Communicating with your dog is a two-way street. While you’re teaching her to understand and accept primate language, you can also learn and use canine body language. This will greatly enhance your relationship and your training program, since your dog can respond very quickly when she realizes you are speaking Dog. It’s also a useful skill to have when you’re meeting or interacting with a strange dog.

The following tips on human’s body language are applicable when interacting with any dog, but are especially important when dealing with a fearful dog, or any dog who appears worried or unsure about an interaction. Adopt mannerisms and teach others who interact with your dog to do so as well.

1. Let the dog come to you. If a dog is frightened, she must be allowed to decide whether or not to approach. It’s never a good idea to restrain a dog and force her to accept contact from others. Remember the “fight or flight” response; if the opportunity for flight is taken away, a dog’s choices are limited.

2. Turn to the Side. Facing a dog directly is more confrontational than keeping your body turned partially or completely to the side; even turning your head to the side will make a frightened or worried dog feel less anxious.

3. No staring, please! A direct stare is a threat in the animal kingdom. It is perfectly fine to look at a dog; just soften your expression and don’t hard stare directly into her eyes. Do not allow children to put their faces near your dog’s face or to stare into her eyes. Adults who insist on direct eye contact with strange dogs also tend to get bitten.

4. Don’t hover. Leaning over a dog can cause the dog to become afraid and possibly defensive. When we bend over dogs to pet them or to cuddle them, we are unwittingly offering a posture of threat and intimidation.

5. Pet appropriately. Approaching dogs by patting them on the head is ill-advised. Envision the interaction from the dog’s point of view; a palm approaching from above can be alarming. It’s not that dogs should never be petted on top of the head, but that head-patting (or petting over the dog’s shoulders, back, or rump) should not be used as an initial approach. It is wiser to make a fist, hold it under the dog’s nose is to allow her to sniff, then pet the dog on the chest, moving gradually to the sides of the face and other body parts, assuming the dog is comfortable. Likewise, a hand moving in quickly to grab for a dog’s collar is more potentially fear-inducing than a hand moving slowly to a dog’s chest, scratching it, then moving up to take hold of the collar.

6. Stoop, don’t swoop. Small dogs in particular are often swooped down upon when people want to pick them up. Fast, direct, overhead movements are much more frightening than slow, indirect ones. To lift a small dog, crouch down, pet the dog for a moment, then gently slip your hands under her belly and chest, and lift.

7. Watch your smile. While humans interpret a smile as friendly, a dog might not be as fond of seeing your pearly whites. A show of teeth is, after all, a threat in the animal kingdom. Smile at dogs with a closed mouth.

To learn more about reading and listening to your dog’s body language, purchase Whole Dog Journal’s Dog to English Dictionary.

Reforming a Reactionary Dog

January 6th, 2020 by Animal Health Foundation

from The Whole Dog Journal

Resources and training tactics for reforming a reactive dog.

We’ve all seen them – those nightmare dogs who lunge, leap, growl, snarl, snap, bark, threaten, bare their teeth, act like bullies, and charge at other dogs. They ruin visits to dog parks and even walks around the block. They’re out of control. They shouldn’t be allowed! 

It’s only natural to feel angry or annoyed when you encounter a problem dog. That’s scary enough – but it’s worse when the out-of-control dog is yours. 

Years ago, almost no one used “reactive” to describe these difficult dogs. They were called “aggressive,” and most trainers applied physical corrections. Today “reactive” describes several related problem behaviors, and the emphasis has shifted from physical punishment to positive-reinforcement training. 

Like many who have reactive dogs, I was not prepared. My first two Labradors, Samantha and Chloe, were calm, friendly, relaxed, and easy going. Neither ever chased a deer or a car. From time to time I heard about the rehabilitation of problem dogs but didn’t pay much attention. 

Now I’m making up for lost time. My crash course in reactive dog training began two years ago, when my Labrador Blue Sapphire was six months old. Blue would love to race after not only tennis balls but animals, skateboards, kids on bikes, motorcycles, joggers, and anything that moves. For months she erupted with ferocious barking as soon as she saw motion – a hiker, dog, deer, or bike – 50 or 100 yards away. No one meeting us would assume that this growling, barking, lunging terror was otherwise intelligent, affectionate, and a joy to live with. 

Since then, in addition to working with talented local trainers, I’ve been studying books, DVDs, articles, and online classes devoted to reactive dogs. Blue is mastering impulse control and I’m learning a lot about training. Perhaps some of what has helped us will help you as well.

FIND SOME BOOKS…AND MAYBE A VIDEO

You don’t have to purchase the library’s worth of books I’ve invested in, but multiple descriptions can help you understand and implement effective training programs. Trainers presenting the same basic information do so with different examples and approaches, at least one of which may be a perfect fit for you, your dog, and your schedule. If you prefer video demonstrations, try some DVDs, webinars, or online classes. 

It would be wonderful if these resources came with magic wands that transformed our dogs overnight, but alas, they don’t. They offer tools that we have to master and practice in order to help our dogs develop patience, confidence, and good manners.

Some of you may be most interested in how and why dogs become reactive and what their body language means; you may find technical descriptions and the language of behavior modification fascinating. Others may be impatient to skip the technicalities and start training, or want to focus on the emotional and energetic bonds connecting dogs and humans. No matter what your approach, you will find resources that will help advance your understanding and ability to deal with your reactive dog. 

For a topic that barely existed two decades ago, reactivity has spawned a training industry. So far I’ve studied 40 books and more than a dozen DVDs from force-free trainers, some of whom live with reactive dogs and all of whom have helped inexperienced handlers change their reactive dogs’ behavior. 

DEFINING REACTIVITY

What exactly is a reactive dog? Reactivity describes a dog’s over-the-top or excessive response to specific situations, such as seeing a person, animal, other dog, or unexpected object. Dogs are called leash-reactive when the frustration caused by a restrictive leash overwhelms them (see Feisty Fido by Patricia McConnell). Blue is a good example, for once she’s off-leash on a trail or in a dog park, she plays well with other dogs.

In the training book The Midnight Dog Walkers, Annie Phenix says, “A reactive dog responds to normal events in his environment with a higher-than-normal level of intensity. Some of those overreactions include barking, whining, lunging, hypervigilance, panting, pacing, restlessness, and difficulty responding to his owner, even for well-known cues such as ‘sit.’”

The training and rehabilitation of reactive dogs has generated dozens of books, DVDs, and other resources that help “over-the-top” dogs and their owners relax, stay calm, and enjoy life together using effective strategies, detailed instructions, and positive, force-free training methods.

Aggression is usually defined as threats to harm an individual, whether human or animal, with attacks, attempted attacks, or threats of attack. Underlying causes of aggression include guarding or protecting territory or family members, guarding resources, prey drive, physical pain, and frustration. According to Pamela Dennison in How to Right a Dog Gone Wrong, aggression is a normal canine behavior, so it’s important to channel a dog’s natural aggressive instinct into socially acceptable activities. This can be done by identifying the dog’s unique issues and redirecting her actions. 

The first time Blue leaped in the air, snarled, and lunged at another dog, I was too startled to think straight. When she did it again, I was upset and confused. To me – and I’m sure to the people who saw her in action – she looked aggressive and dangerous. In and out of the house she began reacting in the same noisy, alarming way toward anything unexpected. 

We did well in the American Kennel Club’s STAR puppy class, but when we took the Canine Good Citizen test, the neutral dog did us in. Here was a new dog! And a new person! It was all too much!

In addition to the training classes we took with Adele Delp at Canine Fitness (caninefit.com) here in Helena, Montana, I hired Jeff Lepley (happytrailsdogservices.com), who had recently completed Jean Donaldson’s Academy for Dog Trainers certification. 

It was Jeff who helped me understand that when Blue barked at distractions, she was frightened. At first I found that hard to believe because she looked so fierce, but the logic made sense. Yikes, there’s a strange person/thing/animal/whatever! I’ll scare it away! See? It worked! 

THRESHOLDS AND TRIGGERS

Thresholds are borders at the edge of a dog’s peaceful, comfortable state – the place or time when some stimulus causes the dog to experience stress, anxiety, or fear. A trigger is any stressor that occurs within the dog’s threshold, resulting in reactive behavior.

When a dog is “over threshold,” as Sunny Weber explains in Beyond Flight or Fight, “it means that the animal has lost control of logic and his brain is engulfed with stress hormones, making reasoned thought or learning impossible.”

What is your dog’s threshold? Blue’s extended as far as she could see in any direction, but once a scary visitor was inside the house, she relaxed. For some dogs it’s all about proximity – the closer the threat, the more intense the reaction. For others it’s the unexpected. Inanimate objects like parked cars and plastic bags startled Blue if they appeared where she wasn’t used to seeing them. Studying your dog’s threshold is important because with every repetition, a dog’s reactive behavior becomes stronger and more established. 

Canine body language offers plenty of clues if we train ourselves to notice them. Handlers whose attention wanders won’t observe changes in posture, ear or tail positions, hackles, eyes, or facial expressions, all of which give important signals. When Blue was leaping in the air and barking her head off, subtle cues had already come and gone, but with practice I learned to recognize them and redirect her before she progressed into full reactive mode. One simple test is whether she’ll take a treat. If not, I know we’re already over threshold. If she takes it in a distracted way, I know we’re close. Either response gives me options like changing direction, moving to a new location, getting her attention back, and practicing familiar commands.

Knowing how to interrupt a reactive response is worthwhile, but avoiding it is even better. As Sue Brown explains in Juvenile Delinquent Dogs, “The first step to changing your dog’s behavior is to prevent it from happening in the first place…. Preventing a behavior is called ‘management’ and it is done by managing your dog’s environment. You will save a lot of frustration, stress, anger, and energy if you focus on managing your dog’s environment rather than reacting to your dog’s unwanted behaviors.”

Annie Phenix agrees. “If I could enforce a signed pledge that owners won’t expose their dogs to the outside while they’re enrolled in the Growly Dog class, I would surely do it,” she says. “I ask for no walks during this time because it is critical to keep the dog under threshold (don’t put him in a position where he barks, lunges, growls, etc.) while we are reframing what an oncoming dog or person means to your dog. We are rebuilding trust and communication between owner and dog as well. It’s like a bank account built of trust. We spend four weeks building up that all-important account, and one scary incident can wipe out your savings, particularly in these beginning stages.”

Pat Miller, whose training articles are familiar to WDJ readers, says in her book Beware of the Dog, “If something you’re doing is triggering your dog’s aggression, stop doing it. If something or someone else is triggering the aggression, prevent your dog’s access to that person or thing, and prevent that person or thing from having access to your dog.” 

To this end, Miller and other trainers recommend blocking a reactive dog’s access to windows, fences, and similar triggers. When left unsupervised, Blue monitored upstairs windows, watching open fields and hiking trails. If something moved, she’d go ballistic. 

In Help for Your Fearful Dog, Nicole Wilde warns readers to keep reactive dogs away from “lookout posts.” Because the barking that results is self-rewarding, she writes, it is likely to continue. “The problem is that with each incident, adrenaline and other stress hormones are flooding your dog’s system so that her anxiety level spikes. The cumulative effect can be a dog who is perpetually stressed and on guard.”

Through her favorite window lookout post, Blue spots a jogger and immediately whines, growls, barks, and leaps in the air. Blocking her access to lookout windows prevents her from practicing this unwanted behavior

I’m embarrassed that it took me so long to appreciate the damage caused by Blue’s lookout posts, but setting ground rules and maintaining them made an immediate difference. As Wilde recommends, I closed doors leading to upstairs windows and interrupted barking by calling her to me, praising her for coming, asking for different basic behaviors (sit, down, touch my hand, watch me, let’s go), and rewarding her with favorite toys or treats. Whenever I leave the house without her, Blue stays in her crate or in a quiet room with closed curtains. Without the constant reinforcement of outdoor distractions, the indoors stays peaceful. 

ACT LIKE A TRAINER

In 1993, Jean Donaldson videotaped dog trainers and dog owners to see what they did differently. As one would expect, all of the dogs performed better with professional trainers, but there was an even more important difference that Donaldson didn’t notice until she rewound and fast-forwarded the tape while collecting data. In Train Your Dog Like a Pro she writes, “I was amazed to find that I could identify whether the person on the screen was a trainer or not with just a one-second sample or even a freeze-frame, based strictly on whether the person was attempting to train the dog at all.”

Donaldson calls this difference “the perseverance gap.” Typically, non-trainers tried something a few times, such as getting the dog to lie down, and then, whether successful or not, they stopped training and waited for the next activity. Once again they tried two or three repetitions and then quit. In between, they chatted with anyone nearby, checked their watches (today they would check their cell phones), or petted their dogs. Most of their training time consisted of this “between-training” dead air. 

In contrast, the trainers constantly watched their dogs while doing one repetition after another. Donaldson says this pattern was evident whether the dogs caught on quickly, were difficult to train, were already highly trained, or were unruly novices. “The trainers trained like bats out of hell,” she says, “and the non-trainers were mostly on break time.”

Count that as a breakthrough realization. No one had videotaped Blue and me in our classes, but if they did, we’d see a lot of between-training dead air. Following the advice to “fake it till you make it,” I imagined Jean Donaldson observing us as we walked up and down stairs, practiced heeling in the living room, went outside, paused at gates, came inside, paused at doors, went to the dog park, practiced retrieves, practiced recalls, practiced basic obedience, and practiced tricks while Blue received undivided attention, rapid rewards, and enthusiastic praise. 

My second turning-point trainer was the late Sophia Yin, DVM, whose DVD exercises revealed just how slow my timing was, how my posture was incorrect (bending over the dog, not standing straight), and how my reward delivery was vague and inconsistent. Practicing along with her workshop participants made my movements faster, more direct, more decisive, and easier for Blue to understand.

In her video workshops and in How to Behave So Your Dog Behaves, Dr. Yin focused on “sit” as an automatic behavior equivalent to “please,” because insisting that a dog “sit for everything” helps one become a clearly communicating leader while changing the dog’s perspective. 

In addition, Dr. Yin recommended tethering, attaching dog to handler with a hands-free leash, and wearing a bait pouch containing not just a fraction of the dog’s daily food allowance but all of it. In other words, during the early phases of training, all of every meal arrives one piece at a time from the handler in response to correct behaviors.

Because Blue’s raw diet doesn’t work well in a bait pouch, I loaded up on hand-feedable treats that could replace parts of her dinner. Tethering and keeping the bait pouch full improved my observation skills, helped me notice and reward every behavior I wanted to encourage, kept Blue motivated, kept her away from threshold-threatening windows, and reminded me to act like a trainer. 

A third breakthrough author, Amy Sutherland, helped me appreciate force-free training from a completely different perspective. While writing a book on modern training methods, Sutherland spent a year with the Exotic Animal Training and Management program at Moorpark College in California. Her follow-up book, What Shamu Taught Me About Life, Love, and Marriage, focuses not on killer whales and other creatures but on humans struggling to master training fundamentals. 

By applying modern training methods to every aspect of her own life, Sutherland changed herself, her husband, and all of her relationships. Several of the books listed here discuss challenges like unsympathetic observers, anger, and vocal criticism faced by those with reactive dogs, but Sutherland demonstrates how the versatile laws of behavioral training can transform handlers as much as the animals we work with.

FOUNDATION AND DEFAULT BEHAVIORS

Foundation behaviors are responses so thoroughly practiced and automatic (think muscle memory) that the dog does them without thinking. These are often basic obedience commands, and they provide alternatives to whatever a dog is doing (or about to do) that is other than what you want. Most of the resources listed describe how to teach, practice, and improve foundation behaviors.

In When Pigs Fly: Training Success with Impossible Dogs, Jane Killion calls automatic attention the mother of all behaviors and one of the first things we should teach our dogs. “There is no point in teaching your dog how to do things if he is going to ignore you when you ask him to do them,” she says. “Attention is the foundation for any training program.”

As Patricia McConnell explains in Feisty Fido and her DVD “Treating Dog-Dog Reactivity,” the attention or “watch” cue has many advantages. “Teaching an incompatible behavior is a time-honored and elegant solution to a lot of behavior problems,” she says, “and it works wonderfully with fidos who are a bit too feisty on leash walks. Additionally, by teaching your dog to look at your face when she sees another dog, you’re teaching her what you want her to do, rather than hoping she’ll figure it out for herself.”

In addition to making eye contact, Pamela Dennison’s essential behaviors include name recognition, heeling on a loose leash, accepting touching, accepting secondary reinforcers (rewards other than food), staying in place, coming when called, doorway control (when going in or out of cars or buildings), and remaining relaxed around objects, people, or places instead of guarding them. 

In Control Unleashed, Leslie McDevitt adds the whiplash turn, which is a fast turn of the head away from something and toward the handler. “If the dog isn’t looking at me,” says McDevitt, “the first thing he needs to do is disengage from what he is looking at and orient toward me instead.”

Her instructions include mat training, which involves independently going to a mat, lying down or sitting on the mat automatically, and staying on the mat without fidgeting until released. Blue responded right away to mats, which can be anything from a square of plywood on the ground to a towel, area rug, or bathmat on the floor. That’s where she stays while meals are prepared and consumed, plus whenever the doorbell rings. Outdoors she runs to her plywood mat when we practice retrieves.

Emma Parsons’ foundation behaviors in Click to Calm include watch (make eye contact), sit, down, heel on a loose leash, target (touch an object such as a hand or target stick on cue), stay, come when called, four-on-the-floor (no jumping allowed), kennel up (go into your crate), leave it, and hold an object. 

In Out and About with Your Dog, Sue Sternberg recommends three essential skills for moving past dogs and other distractions: watch the handler’s face without interruption, heel on the left side, and heel on the right. “The more treats you use and the more frequently you give them during the initial foundation training, the stronger your dog’s behavior will be in the end,” she says. “Don’t skimp. Have many tiny treats ready in one hand and shovel them into your dog, one at a time, until he is looking at you and there is a constant stream of treats going into his mouth.” Before you run out of treats, put the food away, walk away from your dog, and ignore him for a few minutes. “Leave him wanting more,” she says, “while there’s still more to be had.”

Default behaviors are whatever responses come easily to the dog and which are stabilizing, relaxing, and comfortable. Leslie McDevitt defines a default behavior as one the dog commits to and maintains for the duration of a specific context. “The context is the cue to begin the behavior,” she says, “and the behavior will continue until the context changes or you give your release cue.” The default behavior is automatic and it gives the dog something to do (lie down and chill out, for example) when she isn’t receiving instructions. McDevitt recommends letting the dog choose her defaults. Whatever the dog offers, such as a sit, down, or anything else, can be encouraged, strengthened, and lengthened with attention and rewards.

Studying your dog’s inclinations can help you discover a canine sport for which he has a special aptitude or interest, such as dock diving, hunting/retrieving, scent tracking, herding, agility, rally obedience, nosework, flyball, disc sports, parkour, or trick training. As your dog becomes more confident and responsive to your management skills, any of these might become a perfect match. For inspiration, see Hyper Dog 101 by Kim Mayes; Play Your Way to Good Manners by Kate Naito and Sarah Westcott; and Dog Parkour by Anna Louise Kjaer. 

REWARD THE BEST, IGNORE THE REST

Behavioral trainers reward what they want to see more of. This simple strategy is the key to modern training, and it’s based on research. In You Can Train Your Dog, Pamela Dennison describes three basic laws of learning:

  • Rewarded behavior is repeated.
  • Ignored (unrewarded) behavior stops.
  • Once a behavior is in place, random (variable) rewards will strengthen it.

What do we mean by “ignoring” unwanted behavior? When a dog jumps on people, his rewards may include attention, physical contact, shouts of alarm, or an opportunity to run and chase, so the recommended response is to stand still, turn your back, look away, and ignore the dog’s jumping. When jumping isn’t fun any more, the dog will look for something else to do, and when sitting politely earns rewards and treats, that new behavior replaces jumping.

But what about self-reinforcing activities like barking, running fence lines, chasing bikes, or lunging at people and other dogs? Ignoring these behaviors won’t extinguish them, and as long as they’re rewarding to the dog, they will grow stronger. This is why it’s important for handlers to manage their dogs’ environment, plan ahead, avoid triggers, notice changes in posture, and become skilled at evasive maneuvers. Inattentive handlers and reactive dogs are a dangerous combination. 

To the basic laws of learning, we can add three suggestions for motivating your dog from Jane Killion:

  • Identify the things that your dog loves.
  • Gain control of them.
  • Exchange them on a regular basis for behaviors that you want.

And as Sue Brown adds, when training doesn’t change your dog’s behavior, one of three things is probably happening:

  • There isn’t enough consistency.
  • You have not given it enough time.
  • What you are doing is not effective and needs to be changed.

The most widely used reward is food, but whatever your dog finds valuable or fulfilling can work. Some dogs live for tennis balls, tug toys, an opportunity to run hard, or play dates with special friends. Verbal praise and physical petting may be appreciated, but they are seldom as rewarding as food, toys, or the chance to do something exciting. 

The least rewarding food treat is your dog’s regular kibble. Try filling your bait pouch with a variety of meats, cheeses, crunchy biscuits broken into small pieces, and other tasty handouts.

If your dog enjoys them, interactive puzzles can be amazing motivators. Whenever Blue (a puzzle addict) is almost but not quite reliable with something she is learning, I show her a Nina Ottosson puzzle and she suddenly seems to remember and understand exactly what I want from her and she does it with great enthusiasm.

Many trainers recommend documenting results on a printed form or in a training notebook because keeping an objective record of your dog’s progress will help you move forward without the frustration and disappointment of setbacks.

“We want an ever-increasing level of difficulty without losing the dog by having him quit because it’s too hard,” says Donaldson. She recommends measuring the success of every step in a training session and not moving on until the dog successfully completes the behavior for five repetitions in a row. 

When completing a practice set, be sure that all of the repetitions are identical. Don’t change your location, position, the direction you’re facing, your body language, voice, or other signals until you’re ready for the next installment. Paying close attention to what you are doing helps prevent the accidental reinforcing of behaviors you would rather extinguish. 

 When the dog performs each action successfully five times in a row, she is ready to move on to the next, more complicated, assignment. If she can’t complete more than one or two repetitions, make it easier by dropping back to a previous, simpler behavior. If she completes three or four repetitions, stay where you are and try another set of five repetitions.

Blue works to find and eat the treats hidden in a food puzzle. She loves this activity, so the opportunity to play with one motivates her to pay close attention and respond quickly in a training session.

The advantage to training in sets is that they clearly show your progress. Endlessly repeating a behavior that your dog already knows is inefficient and boring, and jumping ahead too quickly is inefficient and stressful. 

Organizing training sessions helps us be “splitters” instead of “lumpers.” In The Toolbox for Building a Great Family Dog, Terry Ryan explains that two of her mentors, the positive training pioneers Marian Breland-Baily and Bob Bailey, taught her these terms. Splitters break tasks into small, easy pieces, increasing the chances for success. Lumpers grow impatient, assume that the dog can move ahead faster, and focus on the desired end result while skipping in-between steps. 

As Laura VanArendonk Baugh writes in Fired Up, Frantic, and Freaked Out, “If we lump behaviors – ‘my dog has learned to sit in an empty room, so now I’ll ask him to sit while the doorbell rings and guests walk in’ – we’re going to experience failure and frustration. Splitting can feel ‘slow’ to those not used to it, because it’s many small steps instead of a few large ones, but in the long run training actually moves much faster!”

In support of good training, your definition of “jackpot” may need updating. I used to think that a jackpot, which is a special reward for something done well, would be an unusually yummy treat, like maybe a chunk of raw steak. But that’s only part of it. A really rewarding jackpot isn’t a single treat that’s quickly swallowed, it goes on for  as much as 20 seconds or more. That’s a long time! 

The other day as Blue and I walked to my car from the dog park, a commotion erupted on the sidewalk ahead. When I said, “Come front!” Blue spun around, sat with her back to the action, and ignored a leaping, snarling, on-leash German Shepherd exchanging words with a leaping, snarling, on-leash Lab. Blue’s jackpot consisted of 30 small pieces of hot dog, cheese, freeze-dried liver, almonds, bacon, turkey jerky, peanut butter treats, and dehydrated bison tripe, delivered one at a time with decisive arm movements while I stood straight and praised her for being so awesome. The distracting dogs went their separate ways and Blue ignored them as we resumed our walk. 

LIFELONG MANAGEMENT OF REACTIVE DOGS

If there’s one thing the experts agree on, it’s the importance of ongoing practice. For best results, reactive dog training never stops. Well-managed reactive dogs are often the best-behaved dogs in classes, competitions, at home, and in the great outdoors because their handlers’ management skills are so polished and automatic. 

In Better Together: The Collected Wisdom of Modern Dog Trainers, Ken Ramirez observes, “The most impressive changes have occurred with dogs that have had a lengthy break from exposure to triggers combined with lots of fun and advanced training as part of a stable program.” When advanced training is not part of the equation, he says, most of the dogs he has worked with continue to have challenges.

Living well with reactive dogs requires commitment, patience, and a willingness to try new methods. It’s an ambitious investment of time and effort. It’s also one that, as I’m learning with Blue and the resources listed here, can pay a lifetime of dividends. 

Avoid Leash-on-Leash Meetings

January 6th, 2020 by Animal Health Foundation

Breaking: Taurine might not be behind heart disease from kibble

December 30th, 2019 by Animal Health Foundation

From Dogs Naturally Magazine

By:  –

They alerted pet owners about the potential for heart disease in dogs on certain diets … diets that may be deficient in taurine.

Everyone panicked … but was this panic warranted?

The Tale Of Taurine

Taurine is an amino acid found mainly in meat. Unlike other amino acids, which are used mainly to build proteins, taurine is a loner. It has many special functions, including:

  • It’s a component of bile, which breaks down dietary fat.
  • It’s vital for the proper function of muscles (especially the heart), eyes, brain, and the immune system.
  • It has beneficial antioxidant and anti-inflammatory properties.

Dogs manufacture their own taurine from the sulfur-containing amino acids methionine and cysteine.  But, with advancing age, taurine production decreases.

The first inkling about taurine’s importance came in the 1980s. Researchers at UC Davis discovered that taurine deficiency was impacting cats. Thousands of cats were going blind. Some were even dying from a heart condition called dilated cardiomyopathy (DCM).

This happened because pet food companies were making ingredient substitutions. They substituted more and more plant proteins, such as soybeans or corn gluten meal, in place of real meat.

The trouble is … soybeans and corn are poor sources of sulfur-containing amino acids. They also contain zero taurine.

Unlike dogs, cats (and ferrets) must consume taurine in the diet and cannot produce their own.

So the manufacturers started supplementing all cat foods with taurine. The epidemic then faded away (although DCM can still occur, unrelated to diet). Pet food makers saw no reason to add taurine to dog foods, so they chose not to incur the added expense.

However, DCM is common in dogs, especially large breeds. And there is such a thing as taurine-deficiency DCM in dogs; it was discovered in the 1990s.

Spaniels, Golden Retrievers, Newfoundlands … and a handful of other breeds … appear to be genetically predisposed to DCM. It’s also recognized that big dogs produce taurine more slowly than small dogs. This increases their risk of DCM.

[Related: NEWS: FDA Reports Some Dog Foods May Cause Heart Disease]

What The Research Has To Say

Recent research suggests that diet is a factor in less than 20 to 30 percent of dogs with DCM. Some (but not all) of these dogs will improve with taurine supplementation. And that raises even more questions about it!

For one thing, taurine may not even be the real culprit. Taurine production relies on adequate methionine and cysteine in the diet. So the problem may be a deficiency of those amino acids, rather than a lack of taurine itself.

The microbiome may also play a major role in taurine deficiency. This turned out to be the primary factor in cats.  The taurine from bile is reabsorbed in the colon … but bacteria can “steal” taurine and prevent this crucial recycling.

Processing may also play a significant role in dogs as well as cats. This has not, to date, been considered or investigated.

Grain-Free And “Boutique” Foods

The FDA reported a link between DCM and “grain-free” dog foods with large amounts of:

  • Potatoes
  • Legumes
  • Exotic proteins

One expert called these “BEG” (Boutique, Exotic and Grain-Free) diets.

The increase in reported taurine-DCM cases caught the FDA’s attention. Not because it was a new concern … but because the dogs weren’t breeds previously known to develop taurine-deficiency DCM. 

These included:

  • Labrador Retrievers
  • Whippets
  • Miniature Schnauzers
  • Shih Tzu
  • A Bulldog and an unspecified number of mixed-breed dogs (and 7 cats).

The FDA said, “potatoes or multiple legumes such as peas, lentils, other pulses (seeds of legumes), and their protein, starch, and fiber,” were the main ingredients of the food in several cases of DCM reported to the agency.

In practical terms, this means that a pet food containing related ingredients … such as “peas, potatoes, pea starch, pea protein, potato protein” could be problematic. This is a common label trick known as “splitting.”

Listing ingredient fractions separately helps a small amount of meat rise to the top … as the ingredients are listed by weight. But, in reality, if they totaled all the plant products, they’d outweigh the meat. This means the food is primarily plant-based.

If the meat is itself is low in taurine, as it is in …

  • Beef
  • Venison
  • Lamb
  • Rabbit
  • Kangaroo

…  that exacerbates the problem in diets with these ingredients.

Interestingly, most vegetarian and vegan dog foods already contain added taurine and carnitine. Evidently, this issue was not hard to anticipate in low- or zero-meat diets.

Manufacturers whose products have been implicated quickly retuned to add supplemental taurine to their foods … but even that may not be enough to correct the problem.

The link between canine DCM and diet is not restricted to exotic meats, potatoes or legumes. Current and past research notes that any of these ingredients may be correlated with DCM:

Animal Products

  • Bison
  • Duck
  • Lamb
  • Kangaroo
  • Salmon
  • Venison

Plant Products

  • Barley
  • Beet pulp*
  • Chickpeas
  • Fava beans
  • Lentils
  • Peas
  • Potatoes
  • Rice/rice bran**
  • Sweet potatoes
  • Tapioca

* While it was not named by FDA in this situation … beet pulp is known to decrease taurine status in dogs under some conditions. 

** Previous studies found taurine deficiency from eating diets containing rice or rice bran. 

[Related: The Truth About Grain-Free Dog Foods And DCM]

Consider All Factors

It’s important to remember that correlation does not equal causation. Just because taurine is a common factor in a bunch of dogs with DCM … it does not mean that taurine deficiency is the sole cause.

Taurine may just be an innocent bystander! Moreover, this list is counter-intuitive, because salmon and duck are high in taurine. Therefore, processing, bioavailability or other factors are also playing a role. 

For example, taurine from fish is diminished by heat processing; the loss is about 30 percent.

The FDA claims … food made by small “boutique” manufacturers is more likely to be problematic.

However, in one set of 18 cases, 15 were from foods with “boutique” brand labels … but those brands are owned and produced by some of the world’s biggest pet food manufacturers …

  • Purina
  • Mars
  • Champion

It appears that the size of the pet food company is largely irrelevant. And now the FDA has done irreparable damage to small brands’ reputations … with its premature and inaccurate assessment.

DCM occurs in all kinds of dogs eating all kinds of foods …

  • Foods with a simple ingredient list
  • Food with a very complex ingredient list
  • Homemade diets
  • Commercial raw foods.

And while the FDA listed ingredients that have at some point been associated with DCM in dogs … they seem to only be concerned with potatoes and legumes.

It’s very important to note this: Not all dogs with DCM … and not all dogs with very low blood levels of taurine … respond to taurine supplementation. 

Many dogs with DCM have perfectly normal taurine levels. A few dogs with low taurine levels can develop DCM …  but so can dogs who are eating high-taurine foods.

This implies that taurine itself isn’t the problem (at least in those cases). It could be a lack of methionine, cysteine or any number of completely different factor(s).

One study on taurine in dogs concluded, “there was no clear relationship between low (whole blood taurine) and presence of DCM.”

The Bottom Line

Grain-free dog foods have been safely fed to hundreds of thousands, if not millions, of dogs for many years. The relationship to DCM is far from clear.

The FDA is not recommending a diet change for any dog, as their investigation is ongoing.

The link between diet and DCM is much more complicated than blaming a few ingredients. It’s clear that we need to consider genetics and diet ingredients combined.

Or perhaps the food’s overall content of …

  • Methionine
  • Cysteine
  • L-carnitine
  • Taurine

… And other factors like processing are at the root of DCM in these cases.

But at this point, no one – the FDA or anyone else … has any idea which factors are actually problematic. Nor do they know in what amounts or combinations.

Unfortunately, many veterinarians are now recommending grain-based foods … even though there haven’t been all that many cases.

And the chance of a dog developing taurine-related DCM  is extremely small.

Grain-based foods have their own (significant) set of problems including:

  • Pesticide residues
  • Genetically modified organisms (GMOs)
  • Toxic byproducts of processing
  • Mycotoxins from mold

They also tend to use less expensive, poorer quality animal proteins. You’ll see ingredients like poultry by-products, meat meal and bone meal.

So, what should you do?

Ideally, feed your dog a fresh diet that’s high in animal protein. But at the very least, make sure the food you’re feeding has more meat proteins than plant substitutes.

Don’t forget, you can call the manufacturer and ask questions if you’re uncertain! 

Symptoms Of DCM In Dogs

Symptoms of DCM in dogs include:

  • Tiring easily
  • Excessive panting
  • Coughing
  • Weakness
  • Ataxia (being unsteady on the feet)

If you have any concerns about your dog or the food you’re feeding, talk with your vet about testing. Your veterinarian can submit blood and plasma samples to UC Davis for analysis.

However, as expected, their laboratory has been overwhelmed since the FDA’s announcement. So it could take weeks to get your dog’s results.

Keep Yourself Up To Date

The best place for up-to-date information on brands can be found on Facebook, in the Taurine DCM group.

While there is a great deal of speculation and misinformation in the posted comments … you’ll find a few helpful items. They have a current chart of cases, including breeds, as well as specific brand names. You’ll find these in their Files Section. 

It’s way too early to hit the panic button, but it’s certainly good to be aware of this ongoing issue.

The Runaway Concept of an Emotional Support Animal

December 18th, 2019 by Animal Health Foundation

From:  https://healthypets.mercola.com/sites/healthypets/archive/2019/12/15/emotional-support-animal-certification.aspx

Analysis by Dr. Karen Shaw Becker               December 15, 2019

STORY AT-A-GLANCE

  • Emotional support animals (ESAs) seem to be everywhere these days, but the issue is not without controversy
  • Researchers at the University of New Mexico have developed a standard assessment for therapists asked to provide patients with ESA certificates
  • The proposal answers the need for ethical guidelines around ESAs
  • If the proposal is adopted as an industry standard, it will become more difficult for individuals to receive ESA certifications, but will benefit society as a whole from the standpoint of safety

By now almost everyone is familiar with the concept of an emotional support animal (ESA), and chances are, many of you have already encountered an ESA in a formerly “animal-free zone.” Or perhaps you or someone in your family or circle of friends has a dog, cat, bird, or other animal companion who serves as an ESA.

How ESAs Differ From Service Animals

Emotional support animals, according to the Fair Housing Act and Air Carrier Access Act (ACAA), can be any species of animal, who must fulfill a disability-related need and whose use is supported by a physician, psychiatrist or mental health professional.

ESAs don’t qualify as service animals under the Americans with Disabilities Act (ADA). Service animals are highly trained and can receive certifications as psychiatric service dogs to help people who suffer from depression, bipolar disorder, anxiety, panic attacks, post-traumatic stress disorder (PTSD), obsessive-compulsive disorder (OCD), schizophrenia and other mental conditions.

Emotional support animals, on the other hand, don’t require specific training to provide assistance to someone with a psychological disability. However, they may be permitted in housing facilities that would otherwise prohibit animals, and the ACAA allows some ESAs to travel on airlines at no extra cost, often with supportive documentation required.

As you might expect, there’s growing controversy surrounding the appearance of ESAs in ever-increasing numbers in locations that have traditionally been off-limits to animals. Sadly, the backlash isn’t surprising given that more than a few people have taken advantage of the special access granted to ESAs, falsely claiming their pet is necessary for emotional support.

Researchers Propose a Standard Assessment to Certify ESAs

Recently, researchers at the University of New Mexico published an article in the journal Professional Psychology: Research and Practice, outlining the ethical challenges therapists face when asked to certify emotional support animals for their patients, and offering possible solutions to better serve both people who feel they need ESAs and those who must comply with the animals, such as landlords and airlines.1

The research team developed and is proposing a four-prong standard assessment for therapists when asked by patients to provide an ESA certificate:

  1. Understanding, recognizing and applying the laws regulating ESAs.
  2. A thorough valid assessment of the individual requesting an ESA certification.
  3. An assessment of the animal in question to ensure it actually performs the valid functions of an ESA.
  4. An assessment of the interaction between the animal and the individual to determine whether the animal’s presence has a demonstrably beneficial effect on that individual.

Assessment Will Address Whether the ESA Is Able to Do What It’s Being Asked to Do

The proposed assessment involves not just the patient, but the animal as well.

“Somebody has to certify that the animal is able to do what you’re asking it to do,” says lead article author Jeffrey Younggren, a forensic psychologist and clinical professor at the University of New Mexico’s Department of Psychiatry and Behavioral Sciences. “And there are avenues by which animals can be evaluated regarding their capacity for these kinds of experiences.”2

There’s no shortage of horror stories of encounters with emotional support animals, especially during air travel, and Younggren and his colleagues believe that implementing standardized guidelines and practices will reduce the number of incidents.

“Our research has nothing to do with service animals,” Younggren clarifies. “Seeing eye dogs and therapy dogs are animals that help individuals manage their disabilities in certain situations — but that’s not what an ESA is. An ESA is an example of a well-intended idea that has metastasized and developed into a world of nonsense.”

Proposal Answers the Need for Ethical Guidelines Around ESAs

Paper co-author Cassandra Boness, a University of Missouri Ph.D. candidate, says the proposed assessment will better align ESA certifications with professional and legal practices, while also providing guidelines for mental health therapists.

“One of our biggest goals is to disseminate this information in order to better educate mental health providers, as well as policy writers, about the need for ethical guidelines around ESAs,” Boness said.3

Importantly, mental health practitioners who aren’t knowledgeable about the law may not realize that when they write an ESA certification letter for a patient, legally it constitutes a disability determination that becomes part of the patient’s permanent medical record. Per the UNM Newsroom publication:

“Currently, in order to receive waivers for housing or travel purposes where animals are banned, the law requires patients must have a mental or emotional condition diagnosable by the Diagnostic and Statistical Manual of Mental Disorders (DSM-5).

If patients are given certifications for an ESA, it means they, and the therapist signing the certification, are declaring the patient to be psychologically disabled with significant impairment in functioning.”4

The proposed assessment will require ESA certifiers to perform a comprehensive evaluation of the person requesting the certification to determine if they have a disability under the DSM-5, according to Younggren.

“That disability has to substantially interfere with the patient’s ability to function, which is what the ADA requires,” he explains. “And the presence of the animal has to ameliorate the condition, which means you have to see the person with the animal.”

If the proposal is adopted as an industry standard, it will become more difficult for individuals to receive ESA certifications, but will benefit society as a whole from a safety perspective.

Moving Forward

The researchers are hopeful their work will spur more research on the impact of emotional support animals on patients in order to build a larger body of scientific evidence.

The important takeaway here is that no one is arguing that pets provide both physical and mental health benefits to humans — those facts are well-estab­lished and backed up with an ever-growing library of scientific studies.

The human-animal bond is real and describes the powerful, positive interaction that exists between people and animals. It’s not just about companionship — it’s about a deep connection that enhances the quality of life of both humans and animals.

The issue is that in a civilized society, it’s necessary to develop and enforce guidelines and standards that benefit the many rather than the few. It’s also important to evaluate current trends, in this case the growing use of ESAs, for potential short and long-term consequences to the animals and humans involved in these pairings, as well as society as a whole.

The Invisible Emotional Burden of Caring for a Sick Pet

December 18th, 2019 by Animal Health Foundation
from: https://www.thecut.com/2017/10/the-invisible-emotional-burden-of-caring-for-a-sick-pet.html
Earlier this year, kindergarten teacher Jessica Wiles, 35, found herself faced with a choice: her boyfriend or her dog, Mia. The problem had been brewing for some time: Two years into Wiles’s relationship, Mia was diagnosed with Cushing syndrome, an endocrine disorder that can cause lethargy, weakness, and frequent infections. Wiles began staying home more often to take care of her; as time wore on, she says, her boyfriend became frustrated, accusing her of neglecting him to be with her dog. This past June, he reached a breaking point: “He actually ended the relationship because he said the dog took precedence over him,” Wiles says. “He didn’t understand that it’s not just a piece of property. They are living, breathing things.”

When Wiles told other people about her situation, she says, she was often met with bafflement and scorn rather than sympathy, and questions about why she didn’t just put Mia down. But Cushing, while chronic, is manageable. “I have a problem deciding to kill my dog just because of health issues. I don’t understand the mind-set of, ‘She’s got a health problem, we’re going to put her down,’” Wiles says. “If the dog was suffering, it would be one thing, but she is still interested in life.”

There’s no question, though, that caring for her has made Wiles’s own life more difficult — emotionally, socially, financially. It’s well known that people caring for ill relatives can suffer from caregiver burden, negatively impacting the health and well-being of the caregiver, but the toll of taking care of a sick pet is often minimized or overlooked. According to a new study, that’s a mistake.

“I wouldn’t equate pet caregiving with human, and certainly don’t want to minimize what family caregivers go through,” said lead author Mary Beth Spitznagel, a clinical neuropsychologist at Kent State University, but “we are seeing similar patterns in terms of a greater level of burden, higher level of stress, depressive symptoms, and a lower quality of life.”

Spitznagel, who had previously worked with caregivers of relatives with dementia, says she got the idea for the study while caring for her dog Allo, who had recently been diagnosed with bladder cancer. “It was a daily challenge trying to fix the problems that sprang up.
And that was kind of when I realized the similarity,” she says. “When we see a burdened caregiver, oftentimes the burden is kind of the constant problem solving, because new problems are always emerging when you are caring for someone who is sick.”

Compared to participants with healthy pets, study subjects caring for chronic or terminally ill animals scored higher on scales of depression, anxiety and lower on well-being, and a psychometric test called the Zarit Burden Interview used to measure burden in human caregivers (the study authors adapted the test by replacing the word “relative” with “pet”). In itself, the finding that people with sick pets feel more of a burden isn’t surprising — but the intensity of that burden was. “It’s meeting this threshold for what we would consider to be concerning if someone were in a human caregiving relationship,” Spitznagel says.

In humans, a score of 20 or higher on the Zarit — which contains items related to feeling strained about your pet, having your social life suffer, and financial stress — indicates “significant burden.” Caregivers of sick pets scored 25.42 on average, compared to 13.96 for owners of healthy pets.

A few caveats: Participants in the current study were almost exclusively educated, wealthy, white women, with an average age of 48. The skewed sampling is likely a limitation — but “at the same time, this might be exactly who the population is,” Spitznagel says. After all, caregiving in humans typically falls to women, and veterinary care, which typically comes out of pocket, is unaffordable to many. Beyond replicating the results in a more diverse group, Spitznahel adds, the next step in her research would be to investigate the “ramifications of burden and the impact on the pet.”

Pet owners go into more detail, describing serious negative impacts to their finances, mental and physical health, social and employment status, and relationships. Wiles, who works two side jobs to help pay for vet treatments, says she has become physically ill from the stress of caring for Mia, compounded by the fact that she now helps her mother care for her grandmother as well.

Emotionally, caring for Mia and caring for her grandmother didn’t feel very different, Wiles says. “The biggest difference is with my grandma there was someone to relieve me,” Wiles said. “Other family members would come and help, but when it’s a dog people aren’t willing to do that.”

“I felt really trapped, ” said Petra Lee, 40, who at one point last year was caring for blind dog, a dog with allergies, an epileptic dog, and a cat with cancer. “I’ve lost a lot of sleep. There was a point where I was really stressed out just having to function with all this and I was having to take a lot of time off of work. I had a hard time making food for myself.” Lee’s caregiving also caused fights with her ex-girlfriend, she says, although overall her ex was very helpful.

But “the biggest thing for me,” Lee says, “is financial.” She felt a lot of guilt last year when she had to balance caring for her cat against her other animals, and also encountered a lot of people who question her choices. “I think I have a lot of privilege, I can afford it,” Lee explains. “I don’t make a lot of money, but I have pretty good salary. And I don’t have children and my dogs are my life.”

“We have our good days, our bad days, and our horrible days,” says Ana Sakuta, 37, whose dog, Roxy, became paralyzed a few years ago. Surgery fixed the problem — Roxy recovered and things went back to normal for a while. But soon, new issues emerged: Roxy stopped eating, became lethargic, and wouldn’t take her medicine.

At that point, Sakuta, who has been the main caregiver for the dogs, brought up euthanasia to her husband, which caused a fight — an added stressor she didn’t need. “It’s really rough. I’m crying, calling the vet all the time,” Sakuta says. “You try to talk to somebody about it and they don’t understand.” Sakuta has asked others in her family for help looking after Roxy, she says, but people tell her they don’t feel comfortable watching the dog due to the amount of work involved.

Although Spitznagel’s is the first study to formally document pet caregiver burden, veterinary social workers have long been aware of the issue. Susan Cohen, a support group facilitator at the ASPCA, estimates she has counseled thousands of pet owners over the years.
The most common issues she hears are “constant vigilance, isolation, and guilt,” she says, and the never-ending problem solving also take a toll: “They’re trying to decide all the time whether the pet is getting worse or getting better, and they often don’t have anyone to talk to about it,” she explains.

“I am so pleased that that study was done,” Cohen adds, noting that she’s tried to get vets to recognize caregiver burden and set up systems to address it. A few large veterinary practices have counselors on staff and offer support groups, but the practice isn’t widespread, and she often gets pushback about the lack of research.

In the meantime, Cohen works with pet owners to ease the decision-making load as much as possible, helping them establish boundaries and a treatment plan early on. Most people say that they will care for their pet so long as they have the means. “I want to figure out what their limits are,” Cohen says, which often involves naming a dollar amount or cap. Whether it’s money or quality of life, it’s helpful for pet owners to be able to answer one simple, and painful, question: “What are you trading it for?”

Warning Letter to Hills Pet Nutrition from FDA

December 14th, 2019 by Animal Health Foundation

WARNING LETTER

Hill’s Pet Nutrition Inc.MARCS-CMS 576564 —

Delivery Method:
VIA UNITED PARCEL SERVICE
Product:
Animal & Veterinary

Recipient:
Peter Brons-Poulsen
President and CEO
Hill’s Pet Nutrition Inc.

400 SW 8th Ave.TopekaKS 66603United States

Issuing Office:
Office of Human and Animal Foods Division II West

United States

 913-495-5100

Dear Mr. Brons-Poulsen:

The U.S. Food and Drug Administration (FDA) conducted inspections of your pet food manufacturing facility located at 320 NE Crane St., Topeka, Kansas on February 1 through February 19, 2019 and March 25 through 27, 2019.  These inspections were conducted in response to a Reportable Food Registry report (RFR) event (EON-378261) filed by your firm and in response to your recall of products marketed with toxic levels of vitamin D. FDA also conducted a complaint investigation from February 11 through February 12, 2019, during which FDA obtained samples of your canned dog food.

The inspections and the investigation confirmed that animal food products with unsafe levels of vitamin D were manufactured and marketed by your firm.  You determined the unsafe levels of vitamin D were the result of an ingredient that you received and accepted in a manner not in accordance with your receiving procedures, and that was subsequently incorporated in the animal food products. The unsafe amounts of vitamin D cause your products listed below to be adulterated because they bear or contain a food additive that is unsafe within the meaning of the Federal Food, Drug, and Cosmetic Act (FD&C Act).1

Furthermore, the inspection revealed violations of FDA’s Hazard Analysis and Risk-Based Preventive Controls requirements for animal food found in Title 21 of the Code of Federal Regulations, part 507, subpart C (21 CFR part 507, subpart C). This causes your products to be adulterated within the meaning of the FD&C Act.2

The introduction or delivery for introduction into interstate commerce of any food that is adulterated is a prohibited act under the FD&C Act.3 Furthermore, the failure to follow the hazard analysis and risk-based preventive controls requirements is also a prohibited act under the FD&C Act.4 You may find the Federal Food, Drug, and Cosmetic Act and FDA’s regulations through links on the FDA’s website at www.fda.gov.

At the close of the February 1 through February 19, 2019 inspection, you were issued a Form FDA 483, Inspectional Observations.  We received your written responses dated March 12, 2019, May 23, 2019 and August 30, 2019.  We have reviewed your responses and we discuss your violations and your corrective actions below.

We acknowledge that your firm initiated several voluntary recalls for excessive amounts of vitamin D in various finished products. On January 31, 2019 your firm initiated a recall (RES# 82018) of twenty-five (25) different canned dog food products manufactured by your firm. On March 20, 2019 your firm determined that additional products were affected. As a result, approximately twenty (20) additional lots of product previously listed in the original recall were added, and the recall was expanded to include eight (8) new products of canned dog food. On May 20, 2019 your recall was expanded yet again to include an additional lot. A comprehensive list of your recalled products can be found on FDA’s website at www.fda.gov.

Adulterated Animal Food – Unapproved Food Additive
On February 11 and 12, 2019, during a complaint investigation, FDA collected for vitamin D analysis two samples of your Hills Prescription Diet Digestive Care i/d Low Fat (SKU Number 10423) canned dog food. These samples were part of the lots covered by your recall. Testing of the products revealed the following results:

  • Lot code BEST BEFORE 10 2020, T1911124 3912, found 100,170 to 107,282 IU/kg of vitamin D in your canned dog food.
  • Lot code BEST BEFORE 10 2020, T1911125 3912, found 102,829 to 102,346 IU/kg of vitamin D in your canned dog food.

A food additive is a substance that becomes a component of food unless it is generally recognized, among experts qualified by scientific training and experience to evaluate its safety, as having been adequately shown through scientific procedures to be safe under the conditions of its intended use.5 According to scientific literature reviewed and summarized by scientific committees in the National Research Council, and the 2017 Official Publication of the Association of American Feed Control Officials on pages 149-162, vitamin D in dog food is safe in the amount of 500 to 3,000 IU/kg.7 According to the scientific literature, concentrations of vitamin D in dog food above 4,000 IU/kg dry matter cause signs of vitamin D toxicosis, with severity of signs increasing with increasing concentrations of the vitamin.7 Although vitamin D is an essential nutrient that allows dogs to regulate the balance and retention of calcium and phosphorus, when high levels of vitamin D are consumed, excessive amounts are not excreted but are stored in fat tissue and the liver.  The adverse health consequences from consuming excessive levels of vitamin D can lead to kidney failure and even death.8

The above-referenced dog food samples contained vitamin D at levels in excess of 33 times the recommended safe upper limit. At these levels, vitamin D is not generally recognized as safe; therefore, it is a food additive. Under section 409 of the Act (21 U.S.C. § 348), a food additive is unsafe unless a regulation is in effect that prescribes the conditions under which the additive may be safely used, and the additive and its use or intended use are in conformity with that regulation. We are not aware of any regulation that would allow the use of vitamin D at the levels found in the above-referenced canned dog food. Therefore, the vitamin D is an unsafe food additive and the canned dog food containing these elevated levels of vitamin D is adulterated under section 402(a)(2)(C)(i) of the FD&C Act [21 U.S.C. § 342(a)(2)(C)(i)].

Adulterated Animal Food – Hazard Analysis and Risk-Based Preventive Controls Requirements
During our inspection of your facility, FDA Investigators noted violations of the Hazard Analysis and Risk- Based Preventive Controls requirements for animal food found in Title 21 of the Code of Federal Regulations, part 507, subpart C (21 CFR part 507, subpart C).  These violations render your animal food products adulterated under the FD&C Act.9 Violations observed during the inspection include, but are not limited to, the following:

Your firm did not sufficiently assess the probability that a vitamin D toxicity or deficiency hazard will occur in the absence of a preventive control as required by 21 CFR 507.33(c)(1).

Specifically, your firm uses vitamin premix in the manufacture of animal food products, but your firm failed to implement your prerequisite program to ensure that the vitamin premix did not contain an excess of vitamin D, which is a known or reasonably foreseeable hazard that could occur in the absence of a preventive control.  As stated in your food safety plan’s risk assessment matrix for your vitamin premix, you were relying on a (b)(4) to prevent nutrient deficiencies and toxicity hazards (b)(4), which you classified as a high risk chemical hazard. You noted that “[i]f the raw materials or other ingredients do not contain nutrients at the expected levels, this may result in either a nutrient deficiency or toxicity hazard when the ingredient is incorporated into the animal food based on a preset formulation.” Your food safety plan also stated that “[c]hemical hazards identified as high risk require the hazard be analyzed and be within acceptable limits prior to unloading the specific raw material into the manufacturing facility.”

However, the vitamin premix was not analyzed and subsequently reviewed to ensure that the vitamin D added to final products from the premix would meet your firm’s pre-set formulation. Your ingredient specification for the vitamin premix included a target specification for vitamin D and states that the “Supplier must include Certificate of Analysis (b)(4),” but your firm did not obtain Certificates of Analysis (COA) upon receipt (b)(4) of vitamin premix from your supplier. Your firm also failed to test, evaluate against your specification, and subsequently reject the vitamin premix containing excess vitamin D, as required by your food safety plan.  As a result, you used vitamin premix containing a concentration of vitamin D that was outside your specification.

As a result of your failure to follow your food safety plan, the hazard of vitamin D toxicity was not adequately managed at your receiving step.  Therefore, you did not reduce the probability that the hazard would occur in the absence of a preventive control. As a result of your failure to consistently implement your pre-requisite program, a systematic failure of your food safety plan occurred that resulted in the recall of canned dog food as identified above.  The systematic failure also resulted in adulterated animal food, as described above.

Corrective Actions

We acknowledge your promised corrective actions in your written responses dated March 12, 2019, May 23, 2019, and August 30, 2019 to the Form FDA 483, which include implementing a (b)(4) Certificate of Analysis (COA) requirement for vitamin premixes and trace mineral premixes, revising the Receiving Procedure to address the need for (b)(4) COAs (b)(4), training personnel on the revised Receiving Procedure, integrating COA requirements into an internal system so that incoming vitamin and trace mineral premix ingredients cannot be received without conforming COAs, conducting an onsite audit of your supplier’s facility, revising your Food Safety Plan, and implementing a process preventive control for the (b)(4) steps to enhance control of the misformulation hazard.

We are unable to assess the adequacy of your corrective actions because many are preexisting procedures that were not followed consistently prior to the recall event. For example, your requirement for vitamin premixes with vitamin D to have a COA (b)(4) was documented in your ingredient specification before the recall.  This was further confirmed by your firm’s special instructions to your supplier (b)(4).  In your response to the Form FDA 483, you stated that your food safety plan was not intended to cover “misformulation” by your supplier. (b)(4) and noted that “[n]utrient deficiency or toxicity hazards can be the result of incorrect levels of nutrients in incoming raw materials or ingredients.”

Your response states that your firm is now implementing a process preventive control at the (b)(4) step; however, you did not provide adequate documentation demonstrating the implementation and effectiveness of the preventive control to include the associated management components as required by 21 CFR 507.39 and therefore we are unable to determine the adequacy of this corrective action.

The corrective action of a “process preventive control” at your (b)(4) step (b)(4). However, it does not address the root cause of this incident, which was accepting an ingredient without confirming that it contained vitamin levels that were within specification as required by your procedures.

FDA will verify your proposed voluntary corrective actions during a future inspection of your firm.

Conclusions

The violations cited in this letter are not intended to be an all-inclusive list of violations that exist at your facility.  You are responsible for investigating and determining the causes of the violations identified above and for preventing their recurrence or the occurrence of other violations.  It is your responsibility to ensure your firm complies with all requirements of federal law, including FDA regulations.  You should take prompt action to correct the violation cited in this letter. Failure to promptly correct this violation may result in legal action without further notice, including, without limitation, seizure and injunction.

Within fifteen working days of receipt of this letter, please notify this office in writing of the specific steps that you have taken to correct violations.  Include an explanation of each step being taken to prevent the recurrence of violations, as well as copies of related documentation.  If you cannot complete corrective action within fifteen working days, state the reason for the delay and the time frame within which you will complete the correction.  If you do not believe that your products are in violation of the FD&C Act, include your reasoning and any supporting information for our consideration.

Section 743 of the FD&C Act [21 U.S.C. § 379j-31] authorizes FDA to assess and collect fees to cover FDA’s costs for certain activities, including reinspection-related costs.  A reinspection is one or more inspections conducted subsequent to an inspection that identified non-compliance materially related to a food safety requirement of the FD&C Act, specifically to determine whether compliance has been achieved.  Reinspection-related costs means all expenses, including administrative expenses incurred in connection with FDA’s arranging, conducting, and evaluating the results of the reinspection and assessing and collecting the reinspection fees [21 U.S.C. § 379j-31(a)(2)(B)]. For a domestic facility, FDA will assess and collect fees for reinspection-related costs from the responsible party for the domestic facility. The inspection noted in this letter identified non-compliance materially related to a food safety requirement of the FD&C Act.  Accordingly, FDA may assess fees to cover any reinspection-related costs.

Your firm’s response should be sent to Danial S. Hutchison, Compliance Officer, 8050 Marshall Drive, Suite 205, Lenexa, Kansas 66214.  If you have any questions about this letter, please contact Compliance Officer Hutchison at (913) 495-5154 or Danial.Hutchison@fda.hhs.gov.

Sincerely,
/S/
Cheryl A Bigham District Director
Program Division Director
Office of Human and Animal Foods Division II West