Why the FDA Delay on the Grain Free Investigation?

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This article originally appeared in the January 2020 issue of Schutzhund USA Magazine.

In a recent meeting with senior executives at a major pet food retailer, the very first question we were asked was one that’s on the minds of many dog owners. What’s your opinion on the FDA and the grain free investigation? Without covering the entire conversation, I suggested they were possibly being too cautious in their communication. They felt the FDA was possibly a bit reckless. What was interesting is that we had different views on how the FDA was handling the investigation but for mostly the same reason. The reason was that the FDA sent up warning signals without communicating a clear cause or providing a solution on what to do about it. Our different opinions were based purely on perspective.

The Reckless Perspective

From the perspective of a retailer, they were now being asked a lot of questions by dog owners that they could not really answer with any confidence. This could probably be applied to veterinarians, breeders, trainers and really anyone involved in daily interactions with dog owners looking for advice. Understandably, the FDA approach left them with a lot of uncertainty regarding the health impact of grain free products and no real direction on how to address it. Understandably, this is a very difficult position to be put in when faced with potentially life altering food choices.

Why, then, would the FDA raise questions without being able to provide definitive answers? The answer to this question is why I felt they were potentially being too cautious.

The Cautious Perspective

Before getting into this, I want to clearly make the point that our perspective is based on speculation. We have no inside knowledge of the FDA investigation or any of the people involved in it. Our perspective is based on many years of working in the industry around scientists and nutritionists. They tend to be reluctant to take a position they cannot definitively prove.

With that being the case, why would they raise such concerns in the absence of definitive proof? We suspect it’s because they believe there is a significant health risk involved and that they know it but have not yet been able to link the condition to the specific cause. While the correlation is strong, correlation is not causation. We believe they know there’s a major problem, but can’t provide a solution until they can isolate the precise cause to their satisfaction. Hence, they issued a warning but were reluctant to make any claims they cannot yet substantiate.

The Risk of Caution

The problem with the cautious approach is that it has left a vacuum of information that some are using to suggest that there’s not really a nutritional issue. We’ve heard companies suggest that it’s simply a scare tactic driven by some of the major manufacturers to squeeze out smaller ones. We’ve heard that the number of affected dogs is too small to suggest a broader concern. To this we’d respond that the numbers appear small right now because it’s only the dogs that have progressed to the point of severe health problems. There may be no obvious symptoms of early stage dilated cardiomyopathy so the number of affected dogs could be exponentially higher than we’ve seen to date.

What to Do

It’s difficult to gauge how widespread the impact will become but we suspect this is going to get much worse as more information emerges. We’d suggest taking a cue from what manufacturers are doing. Many are already making formula changes in anticipation of FDA findings and a major shift away from grain free and similar diets. It would probably be prudent to follow this lead and consider a diet that engenders less risk.

For our part, we don’t need to change anything as we don’t offer these types of products. We never considered these types of diets founded in sound nutrition science and we’ll continue to focus on promoting nutritional education specific to the needs of working and sporting dogs.

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