New FDA 483: Euthanasia drug found in canned dog food, misc. facility findings, and questions for FDA

fda-483-footerI would be remiss in the goal of this blog if I didn’t do some digging into the form 483 that was just released by FDA this week following a recall for canned dog food containing Pentobarbital. For information on the products recalled and company involved check out the FDA recalls page and search for the issue. As usual I’ll refrain from writing company and product names on this blog when there isn’t any pending civil or criminal action associated with an event. But that information is readily available for anyone by clicking through the links or performing a simple search.

The 483 is short, just two pages. What the goal of this post will be is to go over each of the observations and try to provide additional information that isn’t included in the document to hopefully provide a complete picture.

All FDA observations began with the heading clarifying which portion of the law (FDCA) the firm violated:

The following observations were found to be adulterated [sic] under the Federal Food, Drug, and Cosmetic Act: A food shall be deemed to be adulterated if it bears or contains any added poisonous or added deleterious substance that is unsafe within the meaning of section 402.

This wouldn’t be FF&F if I didn’t pause here for some definitions. Adulterated is a condition of food by which it cannot be sold in commerce. It includes both reasons of safety as this case demonstrates, but it could also be forms of “economic adulteration”, where something claims to be what it isn’t or has otherwise been robbed of characteristics that the consumer would expect. Like if I were to sell you caviar but it was actually flavored gelatin balls or something.

Poisonous or added deleterious substance is a substance that when added to food “may render it injurious to health; but in case the substance is not an added substance such food shall not be considered adulterated under this clause if the quantity of such substance in such food does not ordinarily render it injurious to health.” (emphasis mine)

FDA says two things there. First, don’t add anything poisonous to food (Protip). Second, if the food happens to contain something poisonous naturally, you need to make sure it occurs at a level where it isn’t toxic. This is the often cited”dose makes poison” principal. An example would be that I can’t sell food into which I accidentally spilled some cyanide (whoops) no matter how much or little it was, but I can sell fruits that may have trace amounts of cyanide precursors in the seeds, because it’s not expected to cause an issue in both the actual dose of the seeds and the expectation that people will avoid them when eating. This clarification is actually pretty critical as we try to make sense of past FDA guidance in this case and why the food was adulterated.

So, how did these dog food products cause themselves to be adulterated?

Your low-acid canned dog food product…was found by chemical analysis to contain the barbiturate drug pentobarbital.

By Harbin (Own work) [Public domain], via Wikimedia Commons
By Harbin (Own work) [Public domain], via Wikimedia Commons
Pentobarbital is a sedative that in the form sodium pentobarbital is used as a euthanasia drug. This recall/483 event was initiated when 5 dogs became sick and one subsequently died. Several new updates have occurred since then and I encourage you to follow the story on a site like food safety news.

Here’s the thing about this finding, it’s annoying that the 483 made no mention of the dose that was recovered. This is important because FDA did a study on pentobarbital in dog food in 2002. In that study, the samples (not randomized/representative, convenience samples selected for likely positives) tested positive for the presence of pentobarbital in more or less than 50% of the samples. However, in the same study FDA made a determination of dose that caused adverse effects:

Based on the data from this study, CVM scientists were able to determine that the no-observable-effect level – which is the highest dose at which no effects of treatment were found – for pentobarbital was 50 micrograms of pentobarbital per day

Dogs would have to consume 5-10 micrograms of pentobarbitol per Kg body weight to hit that dose. The highest value FDA found in their samples was 32ppb (32 micrograms per Kg of food). This means that 7 Kg (15.4 lb) dog would need to eat between 35-70 micrograms to reach the minimum dose, which would have been a little over 1Kg of the highest testing food. Pet food isn’t very dense (canned pet food is denser but contains more water that dilutes other ingredients) and 2.2 lbs of it is a lot of food for a 7Kg dog. Therefore FDA concluded:

the results of the assessment led CVM to conclude that it is highly unlikely a dog consuming dry dog food will experience any adverse effects from exposures to the low levels of pentobarbital found in CVM’s dog food surveys

Which means that FDA concluded that the mere presence of pentobarbital does not make the product adulterated because “the quantity of such substance in such food does not ordinarily render it injurious to health” per the FDA study.

Now, because there is report of adverse events and an Oregon State College of Veterinary Medicine report out there showing that the levels in this food were high enough to cause an effect, this food is clearly adulterated. But it seems like FDA should have included a note about the concentration of the drug found in the food in this 483 to clarify why it was legally adulterated, given the past study.

Now for the findings not related to the chemistry analysis and recall:

Condensate dripped throughout your processing facility from the building…including condensate dripping directly into open cans of the in-process low-acid canned dog food product…and also into multiple open totes of raw meats including beef intended for your canned dog food product

Example: steam hood over my stove that I apparently need to clean…gross.

Condensate is found wherever foods are heated and cooled, and FDA has been addressing it more and more. Condensate was noted in the Blue Bell 483’s as well. The logic is that while steam or vapor may be clean, once it collects on a surface like the ceiling or whatever else, it can carry bacteria from these “non product contact” areas back onto your food. Think of it this way, would you lick the underside of the steam hood/vent above the stove if you hadn’t just cleaned it? Now imagine that the steam from your stroganoff was condensing on the underside of the hood and dripping back into it, carrying all that old grease and dust. Yum.

The floors throughout your processing facility are pitted, cracked, and otherwise damaged causing pooled water in areas where food is exposed including where open cans of…dog food are staged

Source: my patio.

Uncleanable floors = environmental pathogens. While they didn’t go on a “swab-a-thon” in this facility (yet), uncleanable floors are essentially considered harborage points for things like Listeria and Salmonella. In any other business than food, pitted floors aren’t normally an issue, which makes it a common finding in plants holding themselves to a manufacturing efficiency standard rather than a “food grade” standard.

Additional sanitary conditions observed…include peeling paint and mold on walls throughout the processing facility including in areas where food is exposed, a live fly-like insect in the …hand-packing area during processing, and an open sanitary sewer within approximately 25 feet of two food storage trailers and one food processing trailer at the rear exterior of the facility.

Really just shows a lack of preventative maintenance and facility investement when there wasn’t a clear ROI. This particular company has been in business for a long time in the same location, so it’s possible they themselves put that old coat of paint in years ago to spiff it up and make it look nice and be good for food. These kinds of things are expensive preventative maintenance tasks (mold removal, repainting) because it causes downtime as well as the expense of the repair. Typically FDA will show discretion depending on risk to product (e.g. if you only have closed containers in a room with old paint), but the inspectors here probably determined that this was facility neglect and should be noted. Same thing happens in restaurants and retail establishments where facilities have aged but there’s been no spiffing up.

You lack operating refrigerated storage facilities or other means of controlling the temperature exposure of raw meats during thawing, storage, and processing.

Ding, ding, ding! We have a winner, here’s where we demonstrate the true lack of food safety commitment/appreciation at this facility. The last findings all relate to proper temperature control:

…raw beef and other meats in various stages of thawing were stored in ambient temperature inside your processing facility and also at abmient temperature inside three trailers…the exterior ambient temperatures were below freezing…there was frozen ice containing a blood-like substance across the floors of the three trailers and also on the ground…

Open cans of beef were staged on a pallet at ambient temperature during the hand packing process [from the start of operations until 2:00 PM]

So here’s what the deal is with food safety here. This product is going to be retorted, which means that as a low-acid product, it’s going to be cooked until it’s commercially sterile.

So, in theory, it doesn’t matter if your raw meat doesn’t stay refrigerated, since you’ll kill anything that might grow on it! Heck, you can pack it in a dirty facility with dirty tools if you wanted to…

That was sarcasm.

Processors who think like this fail to understand how cooking and kill steps work, and don’t have respect for your food at all stages of production.

FDA expects the thermal process for low-acid foods to provide a minimum of a 5 or 7-log reduction for spores and pertinent pathogens. What this means is that the process should destroy a minimum 99.999% of spores/bacteria in the product, or alternatively, it would sterilize meat that contained 10,000 spores/gram (bacteria are easier to kill than spores, and would have a much higher log reduction with the same process).

This would work for most “raw” products used in this process. However, if you don’t refrigerate or otherwise control raw meat to keep it out of the danger zone of 40-140ºF, bacteria will start to grow. And with the average piece of beef trim having anywhere from 100 to 100,000 bacteria/gram, if these bacteria are allowed to multiply to the ten-millions from lack of refrigeration suddenly that 5-log reduction doesn’t work anymore!

99.999% of 10,000,000=100

While 100 un-killed spores may not seem like much, one of them could be C. botulinum, and with a shelf life of years in a can of dog food, it only has time to grow.

Take this home: every cook or “kill” step in food processing has a log-reduction value. So while you can technically cook spoiled meat until all the bacteria are dead, you have no way of knowing (without testing) that your standard procedure of cook until 165ºf will work if the number of bacteria are 100 fold higher than what the cook was intended for.

If you still think you can throw away your refrigerator and just cook everything through, I recommend purchasing an autoclave to really sock-it-to-em. Don’t think what comes out will be very tasty though. Oh, and general autoclave parameters will give you a 12-log reduction. Happy cooking.

While this is a significant finding, it isn’t related to the issue causing the current recall (and subsequent enforcement). The issue with the product had to do with pentobarbital in the food, which is a supplier sourcing issue (pentobarbital didn’t make it’s way in at the plant unless it was a malicious act). This plant has had a poor history with supplier approval (sourcing duck that wasn’t actually duck for example), and also has a history of being ignored by the FDA based on inspection history.

What this warning letter serves to do is show that FDA is doing it’s job (or backtracking to do so) enforcing all the regs at this plant regardless of the specifics of the current problem. But I have a lingering problem with this timeline:

12/31/17: Dogs become sick after eating the implicated food.

1/3/17: Oregon State University receives the samples for autopsy and analysis, report indicates FDA was informed.

1/10/17: FDA shows up at the plant to perform inspection that led to the facility 483 findings

1/17/17: Michigan State University confirms Pentobarbital contamination

2/1-2/2/17: FDA continues inspection according to the 483, no new findings noted from the later dates

2/3/17: Recall initiated, presumably this was a result of the meeting with FDA from the previous two days where they informed them of the results and helped identify the scope of the recall and “recommended” a “voluntary” recall.

2/8/17: FDA continues inspection according to the 483, no new findings noted from later dates.

2/17/17: FDA releases their own independent press release through CVM updates

This facility had multiple problems in 2011 and 2012 that led to FDA action, and FDA had last interacted with them (according to the inspections database, which does not include contracted inspections through the state) on 2/28/13.

Did FDA inspect a facility, find problems, and then decide not to go back for 4 years? And from this timeline above, did they only go back to this facility because they had a potential poisoning related to it on file?

Thorough and rapid response to a crisis FDA, good job! But shouldn’t you have been inspecting a known problem facility to prevent problems like this from happening?

After all, in 2011, you said this:

The FDA Food Safety Modernization Act (FSMA), signed into law by President Obama on Jan. 4, enables FDA to better protect public health by strengthening the food safety system. It enables FDA to focus more on preventing food safety problems rather than relying primarily on reacting to problems after they occur.

We can’t say whether increased visits from FDA (which should have been every 3 years at minimum) would have prevented this from happening. But it certainly couldn’t have hurt.

USDA-FSIS Quarterly Enforcement Report: Downloadable Raw Data and 10 Year Trends

data-graphicIn my mass of emails from the government each day, every quarter I get one from FSIS letting me know what they’ve released their quarterly enforcement report. These reports detail actions taken against specific establishments, as well as details on how many enforcement-type actions are taking place ongoing.

I have a problem with this report however. It’s presented as a pdf with no metrics or historical data to put the information in context. FDA has done a good job in the past few years at releasing metadata in formats that allow analysis (CFSAN adverse event reports, inspection database, etc.), but USDA takes the time to kick out this report without showing what the trends are.

Alright raw data nerds, here at FF&F we’ve got your back. For all your analysis needs, we’ve collected a few of the more “top level” reporting numbers from reports going back to 2007, and put them all in excel for you to strip apart and analyze to your hearts content. We’ll even keep updating this spreadsheet and re-uploading every quarter ongoing.

fsis enforcement reports data (.xlsx)

Because some of us like bringing home a growler on a Friday night and entering data to do basic trending on government statistics, here are some of the trends I found interesting that aren’t visible by looking at any one of the individual reports.


These are the number of individual verification procedures performed by FSIS inspectors each quarter. We can’t speak as to why there was such a change in 2010-2011, as these numbers could simply have started being calculated differently in the system. But NPR had some data to suggest that overall meat consumption started declining in 2010, which could lead to fewer establishments or approved inspection hours, and thus fewer verification events.


Compliance rates have always remained above 98% (meaning that 98% of all verification activities end with an inspector going “okay, you’re doing the right thing here”). But like overall verification, compliance seems to have a slight downward trend as well. It’s hard to say this decline is significant since the standard deviation of these percentage data is only 0.0016, but the whole point of getting this data organized to demonstrate the trend is to keep tabs on things like this. It’s hard to never have a downward trend when you hover near 100%, but it will be interesting to see if there is any FSMA effect in the next few years on this trend in either direction.


That 2% noncompliance rate is a count of Noncompliance Records (NR’s) that are issued. Per FSIS:

An NR is a written record that documents noncompliance with FSIS regulations. An NR notifies the establishment of the noncompliance and that it should take action to remedy the situation and prevent its recurrence. Noncompliance reported on NRs varies from non-food safety issues to serious breakdowns in food safety controls.

When an establishment fails a verification activity, it is issued an NR and has the option to appeal if they think an observation was out of context, the inspector was incorrect in his/her interpretation of the regulation, or some other circumstance led them to believe the finding was incorrect. The graph above shows that historically about 1/3 appeals are granted by regional offices/DC when establishments challenge an NR. But in recent years that number has dropped from around 35% to 30%. This could have also contributed to the increased number of noncompliances observed earlier, now that fewer appeals are being granted.


The poultry carcass inspection/condemn data didn’t have any interesting trends, it swung up and down without a lot of overall variation. The livestock carcass data was more interesting in that it seems to have a sustained downward trend.  This could be to better herd health in the last decade or more efficient slaughter practices that result in fewer condemned carcasses from injury or contamination. While the cause is uncertain, as long as it isn’t the result of poor or inconsistent enforcement, this is a great trend! Fewer condemned animals is better for the animals and the environment.percent-meat-and-poultry-refused-on-inspection

I’m not sure this paints a completely accurate picture, but the data points were real, they actually wrote zeroes in the older reports. While the number of products imported has increased overall, this % refused trend shows that even though imports are increasing, we’re also rejecting more meat at the border than ever before. You can check out this FSIS directive to learn more about inspection of imported meat and poultry and what refusal criteria might be.

If you’re more intense than I am and want to do advanced statistics that excel can’t handle, you can see what’s out there in terms of software and let me know if you discover any new insights from this data! The spreadsheet and all graphs were created from source data in the FSIS quarterly enforcement reports.

USDA/FSIS (2017). Quarterly Enforcement Report for Quarter 1, Fiscal Year 2017 United States Department of Agriculture

Why isn’t the USDA declaring the invisible feces in our meat?

No, that wasn’t a typo. Today I came across this petition for rulemaking to FSIS from the Physicians Committee for Responsible Medicine.

First off: PCRM has some great programs that promote research, animal welfare, and better medicine. The overall merit of their organization cannot be judged by a single program or campaign they have in place.

Now let’s tear this petition apart, because I actually had to check their website to make sure it was real, and not an over-the-top satire from The Onion.

The concern the committee wishes to correct via this petition is thus:

“Inconsistent with its statutory mandate, USDA regularly passes at inspection meat and poultry that is  contaminated with feces. Although USDA implements a “zero tolerance” policy for fecal contamination, this policy applies to visible fecal contamination only. The result is that fecally contaminated meat and poultry products pass inspection as long as the feces on them are not “visible” to the naked eye.

This inspection policy conveys a misleading promise of “wholesomeness.” Feces may contain round worms, hair worms, tape worms, and leftover bits of whatever the animal excreting the feces may have eaten, not to mention the usual fecal components of digestive juices and various chemicals that the animal was in the process of excreting. Americans deserve fair notice that food products deemed “wholesome” by USDA would be deemed disgusting by the average consumer and adulterated under any reasonable reading of federal law.”

Not to quote without context, the petition goes on to list the ways in which non-obvious feces may be introduced to meat product, the most valid being shared scald/chill tanks in processing operations.

Ultimately, the corrections the committee is seeking are removal of the “wholesome” description from USDA inspected meats, begin treating feces as an adulterant, and:

“USDA should amend sections 317.2(l)(2) and 381.125(b)(2)(i) of the Code of Federal Regulations to exclude from the current mandatory label the sentence that reads, “This product was prepared from inspected and passed meat
and/or poultry.” USDA should amend sections 317.2(l)(2), 381.125(b)(2)(i), and 381.125(b)(2)(ii) of Title 9 to include in the mandatory label the following as the second-to-last sentence: “This product may be permeated with feces, which cooking does not remove.”

That’s some pretty heavy language, perfectly stated to play on the fears and squeamishness of your average consumer. However, I see nothing written there about food safety, so the intention of the change is obvious: prevent people from eating meat.

While the about page for PCRM mentions nothing about being proponents of animal rights, the amount of articles devoted to encouraging a purely vegan diet clearly shows that they have an anti-meat agenda. While they correctly advertize the health benefits of vegan foods, a quick search of their website saturates any visitor with the message “meat is bad, and animal agriculture is always cruel”.

The petition shines a light on a group that is ready to intentionally scare and mislead consumers into changing their lifestyle. As part of their justification that feces is everywhere, they cite one of their own studies, “Fecal Contamination in Retail Chicken Products“. In this study, the committee proved that invisible fecal contamination is everywhere by “testing for the presence of feces.”

No such test exists.

What they actually did was test for generic E. coli, which can act as an indicator organism for fecal contamination.  HACCP programs in slaughter facilities use on-line enumeration of E. coli and other coliforms to validate critical control points for just that purpose. But in this case, rather than setting limits and using a statistical rationale to make a conclusion about the level of contamination, it appears that any evidence of the presence of E. coli  led to the determination that the sample was contaminated with feces. Because there are no methods declared, this evidence could be as mundane as RNA fragments from a non-pathogenic strain recovered in an enriched sample.

The study is absolutely meaningless. There is no available data to review in terms of the levels of contamination, no methods listed for how the E. coli was enumerated, and finally no legitimate publication, suggesting that the construction of the study and its conclusions would not have passed peer review.

As part of the rule change, PCRM would like feces to be declared as an adulterant. Generally, USDA inspectors cannot allow adulterated products to enter commerce, adding to the ludicrosity of this proposal. By the PCRM’s definition, all meat products are covered in invisible feces, and the presence of invisible feces should prevent any product from entering commerce. In one swift move, PCRM will ensure that only clean, wholesome meats will be sold, i.e. none.

But have things changed over the years to make eating meat less safe? The PCRM thinks so. I have no data to argue whether or not Americans are cooking less (PCRM also neglected to provide data), and eating more RTE products, but I did think it was funny that when I read this:

“Americans today consume far more meat and poultry than ever before, thereby increasing their potential exposure to fecal contamination in these products”

When the first link I read on their website contained this graph…
Which is it PCRM? Whichever is more convenient for the ad campaign at the time?
(side note: if people indeed are eating out more in restaurants, that would mean they are eating at inspected restaurants where county health inspectors ensure adequate cooking temperatures, rather than at home where people rarely if ever have proper process control)

Finally, the idea that the USDA needs to declare the presence of invisible feces on every product that passes inspection makes no logical sense,  and does nothing but mislead the consumer, not only by implying that the product isn’t safe in general, but that fully cooking the product makes no difference. If it wasn’t obvious by now that this proposed rule change isn’t solely to earn points with vegans, look closely the wording. In order to turn consumers off meat, PCRM would risk undoing years of public education and trust in proper cooking temperatures.

Clearly I took this proposal too literally, but because FSIS will actually have to review the proposal, and PCRM wants to brag about how these changes might occur, I offer one last piece of evidence to support my view that this proposal belongs on a tabloid.
Proposed legends

…one of their proposed inspection marks literally contains a DO NOT EAT symbol.

Physicians Committee for Responsible Medicine (2013). Re: Fecal Contamination of Poultry and Meat USDA Petition for Rulemaking


The poultry microbiome, once again proving that culture-based ecology misleads us all

Shigella penetrating the intestinal wall. Source:

If the world was enriched and homogenized, we would actually have a very good idea of what the microbiological community within looks like. Fortunately, the world is much more complex than the miniature environments we culture in the lab, and high throughput sequencing (HTS) is allowing us to fully appreciate micro-biodiversity. As new information becomes available, many of our models for microbial communities continue to be challenged by the actual composition of species in natural environments.

In the world of food safety, we rely on these models to set policy on a regulatory level, and to set critical limits down at the production level. Which tests we run on what products depend directly on what organisms (that cause food borne illness or spoilage) are supposed to be found on that type of food. The authors of this study that came out in PLOS ONE this February examined the microbiome associated with poultry products from farm to fork (meaning from clucking chicken to packaged poultry product) using HTS rather than culture/enrichment methods. The results indicate that there is an unappreciated amount of diversity between different stages of the poultry production process, and that we may not acknowledge the presence of some organisms as much as we should.

In the study, samples were taken from multiple steps in the poultry production process: wet and dry litter, fecal samples, fluid from carcasses collected during the cooling process following slaughter, and fluid from raw retail poultry products (legs, wings, and breasts). Other than the retail portion, all of the samples collected were from the same batch of birds from start to finish. The available RNA from viable cells in each sample was amplified and identified as belonging to specific species using a combination of Illumina sequencing and database referencing (blastn and usearch).

From this pile of data, lists of organisms were compiled to compare the ecosystem profile for each point in production.

The numbers refer the the number of unique taxa found in each group

The authors were very surprised by the amount of diversity between the two litter samples (wet and dry) and the fecal sample. They expected to see very similar profiles, as all of the predicted microbes in those groups would be inoculated from contact with fecal material (young chicks have no inherited microflora, and are coprophagous); however, all of the groups’ microbial communities had very little in common. As shown above, of the hundreds of unique species identified, only 52 were actually found at every stage from farm to fork.

In evaluating food safety, several results are of concern. The first was that the authors found significant amounts of Shigella spp., which have traditionally not been associated with poultry products and may not be a part of many sanitation programs. The second is that in one of their dry litter samples, the authors found a large amount of C. jejuni. It’s presence was interesting as previous studies have found it difficult to cultivate C. jejuni onto dry litter, suggesting that it will not grow in that environment. This discovery further shows that our attempts to cultivate bacteria are not indicative of their behavior in “the wild”. There may be nutrient gradients or a symbiont in play that allows C. jejuni to grow; therefore the possible contamination of dry litter has to be acknowledged in that facility’s Campylobacter monitoring program.

The last point of interest I’ll discuss here is the large amount of unique species that were found in samples following slaughter. This suggests that these species did not come from the farm, but rather were introduced during slaughter and processing. Interestingly, among Campylobacter spp., there was little to no abundance of C. jejuni in the samples, but differing amounts of other Campylobacter spp. This is revealing, as we have been predisposed to expect C. jejuni to be present due to our use of selective media.

Let’s fully appreciate the amount of diversity found within the processing facility, the authors collected two post-processing samples labeled carcass rinse and carcass weep. The rinse was composed of fluid shaken off of the carcass following its removal from the chlorinated chill tanks, and the weep was the drippings from the same carcass 48 hours later. 2/3 of the unique species found the weep samples were not found in the rinse. The authors interpret this as being due to the fact that the sterilization of carcasses is not the goal of poultry processing, and provide the example that viable Salmonella can be recovered from carcasses even after they are sent through the standard antimicrobial processes. The goal is to reduce enumeration, not sterilization.

Finally, in examining the retail samples, we get what we expect. Similar organisms as the weep, with some new faces, presumably because they persisted through processing at undetectable levels, and slowly grew as the product was stored in refrigeration.

The authors conclude by examining some potential symbionts that would allow C. jejuni to persist, but ultimately say that due to the high number of environments C. jejuni can occupy, attempting to exclude it in a universal way will not be very effective.

So all in all, a thorough example of the misdirection we receive from culture bias, and a startling look at how, given enough incubation time, properly processed meat can still support a huge amount of microbial diversity, including many food borne pathogens.

Appreciate this diversity, and make sure you cook your chicken to temperature.

Oakley BB, Morales CA, Line J, Berrang ME, Meinersmann RJ, Tillman GE, Wise MG, Siragusa GR, Hiett KL, & Seal BS (2013). The Poultry-Associated Microbiome: Network Analysis and Farm-to-Fork Characterizations. PloS one, 8 (2) PMID: 23468931

Newsworthy: Is horse slaughter back on the menu in the US?

Image from PennState's

Well, the 5 year ban on funding dedicated to inspection of horse slaughter facilities has ended. The question now is whether the industry has been effectively killed, or if there is still a large enough market to find the funding and overcome the opposition.

Full disclosure: I have no problem with horse slaughter, and I also really like horses. The animals are subject to the same humane end as beef and poultry, and any objection to the consumption of horse products by those who enjoy other animal products is hypocritical. You may now choose to read or ignore the rest of this post if you wish, knowing that I’ll speak with this bias. I will however, make my points respectfully, and fully welcome reasoned and intelligent debate from anyone who disagrees.

Psych Your Mind has a great post discussing how we meat eaters manage to both love animals and eat them. A lot of it boils down to our separation of cow and steak, and how we perceive livestock animals as opposed to pets. Horses are unique in that they fall into both the work and companion categories, and it’s amazing to see how they can switch back and forth. This is similar to the many free chickens you find on Craigslist that no longer lay eggs, but “make great pets!”. The original owners clearly want them for production, but want no part in their non-economic use.

Google scholar shows a host of articles looking at the impacts of the ban that I’m not going to detail here. However I would really like to hear from readers in the comments, specifically readers opposed to horse slaughter and consumption! It’s difficult to find arguments not rooted in a religious, animal rights, or sentimental background, and I’m really interested to hear if there is empirical evidence that supports a slaughter ban. Whether it be based on export economics, public health (I have heard of food-borne illness concerns with horse meat), or potential detriment to other industries, I want to hear about it! So please feel free to comment and let me know where you stand on the issue!