Transparent adverse pet food reporting and investigation
This chapter considers the evidence presented to the committee in
relation to improved communication about adverse pet food events – including to
the PetFAST system – as well as the provision of a direct consumer complaints
Reporting adverse events
Evidence to the committee indicated that there is no formal mechanism
available to members of the public who want to report an incident or concern in
relation to pet food. Indeed, one of the primary lessons emanating from the recent megaesophagus cases,
is the need for a direct communication channel for consumers who have concerns
about pet food. According to the evidence before the committee, consumers with
concerns about megaesophagus were unable to provide information through an
official channel. They were therefore, unable to report adverse pet food events
in a formalised manner to a professional body that could collect, assess and
act upon that information.
In fact, the committee received a considerable volume of evidence which
detailed the efforts of pet owners, who, without any other recourse, contacted
manufacturers directly. A number of submitters detailed the steps they
undertook in seeking redress from manufacturers after purchasing substandard
pet food, and of their attempts to alert other consumers through social media.
Ms Dola explained the context in relation to the megaesophagus cases and
the consequences for pet owners:
An issue with the public relying on social and media guidance
is the vast range of interpretation and muddling of vital information. I
watched as many owners joined support groups, and were given inaccurate
information around reporting cases to PetFAST, being told that it was no longer
required because it was clear that the system had already identified the
minimum 3 cases. What if those new cases had slightly varying records of vital
information, or if this message was mixed in with different food concerns and
so went unreported? Some owners were even confused about who they needed to
report to, was it PetFAST? Was it Melbourne U-Vet? Was it the pet food
manufacturer? Pet owners in this instance have been publicly ridiculed for
their assertion that they suspected the food to be the cause of their pet's
condition and were discriminated against for making this public for fear of
unsubstantiated legal implications by sharing the information that industry
associations delayed in communicating.
In 2012, the Pet Food Adverse Event System of Tracking (PetFAST) was
launched to keep track of adverse events relating to pets. As a joint
initiative of the AVA and the PFIAA, PetFAST enables veterinarians to log
health problems associated with pet food and treats, for the purpose of
identifying any trends or patterns that might point to a cause. The system is
managed and administered by the AVA, and reports generated by the system are provided
to the PFIAA for its information. When a pattern is identified, a joint
committee of AVA members is convened to discuss what action should be taken. The individual
manufacturer of the pet food product in question is also notified.
PetFAST can only be used by veterinarians, and access is limited to AVA members.
According to the AVA, this is a key aspect of the system's 'integrity and
efficiency'. Pet owners who suspect a problem with pet food or treats are not able to report
a concern directly on the PetFAST system but rather, must take their pet to a
veterinarian for examination. The veterinarian will then determine whether to
log the health problem on PetFAST.
The PFIAA and AVA informed the committee that the system is well
regarded by other countries, with a number of jurisdictions indicating an
interest in establishing a similar reporting regime. While the AVA was of the view that PetFAST has been a 'successful initiative',
other witnesses were more circumspect. RSPCA
Australia stated that PetFAST has been 'working well' in the absence of a
mandatory recall system, and has contributed to the recall of pet food on a
number of occasions, including both the Weruva BFF cat food recall in 2017 and
the Mars Advance Dermocare dog food recall in 2018. However, Professor Caroline Mansfield observed that the system was a 'vast
improvement on what was previously there (nothing)'.
There were a range of concerns expressed regarding the management,
effectiveness and efficacy of PetFAST. Specifically, concerns were raised in relation to matters of accessibility,
underutilisation and onerousness. Questions were also raised about the system's
ability to facilitate the identification of chronic and long-term illnesses, as
well as to trigger and facilitate investigation.
A key issue for submitters was the fact that PetFAST is only accessible
to registered veterinarians. The AVA website states:
Only veterinarians can use this system. If you are a pet
owner and suspect a problem with pet food or treats, you need to ask your vet
to examine your pet and lodge a report if they too suspect an adverse event
associated with pet food.
The AVA indicated that exclusive veterinarian access to PetFAST had
ensured that the data is 'cleaned'. Indeed, the AVA suggested that the restriction of accessibility and reporting
is a key part of the system's 'integrity and efficiency'. Furthermore:
As only veterinarians can use this system, a pet owner who
suspects a problem needs to engage a veterinarian to first examine the pet, and
then lodge a report if they suspect an adverse event associated with the food.
In this way all, the data obtained is relatively "clean data" with
reports that incorporate a veterinarian's opinion before a report is made.
Pet food manufacturer, Nestlé Purina Petcare, noted that the
'veterinarian-to-veterinarian' aspect of PetFAST ensures that there is a level
of professional expertise provided when assessing the health of an animal, and
identifying a link to pet food. Mars Petcare held the view that the existing system in the US allows consumers
to report adverse events without first visiting a veterinarian, which 'can
increase the quantity of information collected, while undermining the quality
of the data collected'.
However, concerns were raised by RSPCA Australia, that there are
'several thousand veterinarians' who are neither members of an associated
organisation, nor receive communications regarding the PetFAST system. Ms Jodi Burnett also pointed out that many veterinarians are unaware of the
existence of the PetFAST system. This was corroborated by a number of veterinarians who appeared before the
committee, including the ex-president of the AVA.
As PetFAST is reliant upon registered veterinarians and is not
accessible to pet owners, it requires owners to seek professional advice for a
matter to be reported. It was argued that this factor, as well as the lack of
an appropriate communication channel for consumers, has led to a proliferation
of online commentary amongst pet owners groups; which in turn has increased the
level misinformation and confusion.
The point was also made that the costs involved in seeking professional help
from a veterinarian were cost-prohibitive for low-income households. The 2016
AMA report into pet ownership revealed that the owners who don't take their pet
to the vet at all are likely to be those living in lower-income households (earning
less than $30 000). Noting this evidence, Ms Stephanie Shaw concluded that PetFAST was 'biased
towards low income families' for whom a veterinarian examination of their sick
pet is cost-prohibitive.
Underutilisation and onerousness
In addition to accessibility concerns, RSPCA Australia noted that
PetFAST relies on veterinarians to be both 'aware and empowered' to report
incidents. However, the discretionary nature of the reporting system can contribute to
lower numbers of veterinarians utilising the system and logging reports.
Another matter seen by submitters as problematic is the system's
dependence on veterinarians to voluntarily report matters. This was raised as a
concern for a number of reasons including a reliance on individual
veterinarians (often in small or isolated practices) to make an association
between a condition and a pet food. Professor Mansfield continued:
When there is acute onset of disease associated with feeding
something this is an easier association to make. But with more chronic disease
this is not so intuitive. The system also relies on vets physically entering in
detail on a web-site, and volunteers that man this responding, logging and when
necessary mobilising an investigation.
This concern was exemplified by the number of megaesophagus cases
reported in 2018. Mr Duncan Hall, Executive Manager of the PFIAA indicated that
46 of the 52 cases reported in PetFAST in the last 12 months occurred only after the Advance Dermocare recall announcement, rather than before. According to Dr Sue Foster of the AVA, only one report relating to
megaesophagus was logged in PetFAST prior to the recall, and this was from a
'very, very top specialist...dealing with a highly confidential group of dogs'. Witnesses attributed this to both the underutilisation and lack of awareness of
the PetFAST system, as well as the rarity of the condition.
The committee was also told that veterinarians may choose not to report
at all because the process of logging a report on PetFAST was 'extremely onerous'. When logging such a report, veterinarians are required to provide the following
- detailed medical records of affected animals;
- detailed diet history of affected animals;
- product consumptions details and documents;
- product name, type, and manufacturing information;
- food samples for analysis; and
- serum and tissue samples (if pertaining to a deceased animal).
Ms Karin Strehlow argued that the amount of data required for each
report, coupled with the potential costs and time associated with obtaining,
preparing and sorting tissue samples, means that many vets may not be inclined
to lodge a report.
Similarly, in noting the detail required by the system, Ms Jodi Burnett
questioned the inclination of veterinarians to submit a report without
prompting from clients:
The other thing with PetFAST is that it's up to the vets' discretion
as to whether they log a report through PetFAST. In my case, I went back after
my dog was officially diagnosed by Melbourne uni and requested that the vet log
with PetFAST, and I was there while she did that. Had I not done that, it
probably would not have been logged.
To 'strengthen' the utilisation of the PetFAST system, Mars Petcare
suggested that a communication campaign be developed to target all Australian
veterinarians. The campaign could educate veterinarians, particularly those
that are not members of the AVA, about when and how to access the PetFAST
system, what information to provide, and how the data is managed by the AVA. According
to Mars Petcare, this would ensure that PetFAST 'continues to provide the most robust
foundation to underpin decisions made by industry and government' regarding pet
food safety and sale.
Identifying chronic and long-term
Another issue raised in relation to the PetFAST system was the difficulty
that it poses in reporting chronic and long-term illness associated with pet
foods. Some submitters argued that the PetFAST system focuses on single events
or outbreaks, and does not capture relevant long-term data. In light of the megaesophagus cases, Ms Jodi Burnett noted that it is
unclear whether the PetFAST system can retain sufficient data to identify
trends or patterns over just a six month period.
Professor Caroline Mansfield raised a similar concern, noting that:
A contemporary association between eating a food and being
sick within 30 to 60 minutes is a fairly apparent one and quite easy to notify,
but, when we're talking about more chronic disease, particularly with a food
that's not widespread in use, one clinic, one veterinarian, is unable to make
Indeed, Ms Christine Wattle submitted that the system 'does nothing' to
address chronic ill-health caused by unsuitable pet foods. At the same time, however, Professor Mansfield also indicated that PetFAST was
not equipped to detect sporadic problems in a timely fashion or to identify
emerging new conditions. She suggested that there are better options including databases that could be
developed to provide a better suited monitoring tool to detect trends in
conditions that are typically unusual, but are increasing in incidence over
Efficacy, management and
The point was made that once veterinarians had logged a report, the
system relies on volunteers to respond, and where necessary, mobilise an
investigation. However, as Professor Mansfield noted, there are no independent
or 'sufficiently resourced groups' affiliated with PetFAST to investigate any
potential food toxicity. She noted in this regard that investigations of potential
pet food issues are expensive:
They require a lot of expertise. They require statistical
assessment, toxicological and nutritional assessment and bacteriological
assessment, all of which cost money and all of which take a significant amount
of time and expertise to put together. It is probably therefore only the very
large pet food companies that have the capacity to finance that—and, again, if
they are financing that, it's not a truly independent investigation.
Dr Andrew Spanner suggested that the PetFAST system was ineffective in
improving pet food safety for various reasons; including the lack of reporting
of submissions on the system, the voluntary nature of adverse findings, or the recommendations
made to pet food manufacturers. Similarly, Ms Karin Strehlow argued that under the current arrangements, lodged
reports are viewed by AVA and PFIAA and that these bodies then determine
whether to make recommendations and initiate discussions.
Inability to mandate or enforce
Under the current system, where a problem is 'obvious and severe enough
and very likely to be associated with a pet food', the AVA can seek the
agreement of PFIAA to request from a manufacturer, the recall of a product. The fact that the PetFAST system cannot mandate or enforce a pet food recall
was a primary concern for many submitters.
Submitters questioned the efficacy of the system, which is only able to
prompt voluntary recalls on the basis of negotiations between the AVA, PFIAA,
and manufacturers, with no legislated authority to mandate them. Ms Karin Strehlow argued that for this reason, PetFAST is a 'toothless
Despite criticisms of the PetFAST system, some witnesses cautioned that
the system was never designed to pick up 'every single adverse event' relating
to pet food. Dr Sue Foster of the AVA noted that it 'depends on the type of problem' as to
whether PetFAST is likely to detect it. However, she reiterated submitters'
views that, while the PetFAST system is useful, 'it is certainly not the same
as having regulation for mandatory recall'.
Direct consumer reporting mechanism
A large volume of evidence to the inquiry supported a direct consumer
reporting system, which would allow pet owners to log pet food related issues
on a central register. As Dr Malik indicated, the 'first people who are going
to see something wrong are the public'.
A clear and direct consumer reporting mechanism was supported by a range
of submitters for a number of reasons, including the fact that it would provide
a reporting mechanism for pet owners who rarely visit the vet (or who visit a
veterinarian that is not a member of the AVA).
Ms Kristina Vesk of The Cat Protection Society of NSW highlighted the
importance of a direct consumer reporting system:
There needs to be capacity for consumer input into
surveillance. We're not suggesting that people do their own veterinary
diagnosis at home. Obviously, if your pet's sick you need to take them to see
the vet. But if you open a tin of food and you see that it's spoiled or mouldy
or you find foreign objects in it, there's no reason for you to go to the vet.
You can take a photo, upload it and put it in some kind of portal. I made a
complaint the other day about a water leak. Sydney Water has this fantastic
reporting system you can do online. In terms of surveillance and gathering epidemiological
data, we need to have consumer input and I think it's very limited by
restricting it only to veterinarians.
RSPCA Australia noted that as a large percentage of pet owners 'either
never or rarely' visit a veterinarian, there is no outlet for them to report
pet food safety concerns other than through a direct complaint to a manufacturer. According to Miss Jasmine Erhard, this is problematic as many pet owners 'can't
afford to individually fight big companies'. She added that pet owners are
further disadvantaged by the fact that the standards are not mandatory.
CHOICE noted that another disadvantage of reporting directly to
manufacturers was that complaints, and how they are handled, are not made
public. Reflecting on these arrangements, CHOICE's Ms Erin Turner stated that there
'doesn't seem to be a strong, transparent connection between complaints and any
activity or recalls' because the information is not held on a central, publically
available register. Ms Turner considered this to be particularly shocking as
pet owners 'know their pets best' and want to alert others when incidents with
pet food occur.
Indeed, Mrs Jenny Kent of Pets Australia noted that there is no
facilitated communication mechanism which allows veterinarians who have
observed pet food related issues to share this information with pet owners. As
such, 'the only person who knows it is not working is the person who it is not
In comparison, the USFDA maintains the Safety Reporting Portal, which
allows consumers to log or report complaints about any food product intended
for human or animal consumption. CHOICE noted that the USFDA's reporting portal is both clear and accessible and
allows consumers, vets, and other interested parties to make complaints. The effectiveness of this system was also highlighted by The Cat Protection
Society of NSW and Australian National Cats Inc.
Dr Andrew Spanner expressed the view that a direct reporting system
would 'get the right stuff off the market' through relying on statistics and
data rather than social media scare campaigns. Another veterinarian, Dr Camilla Forss, stated that a simple reporting process
could increase the likelihood of detecting pet food related disease early, and
contribute to saving the lives of pets that would otherwise be at risk. She suggested that all pet food labels be required to include information about
how to report a complaint. According to Dr Forss:
This would simplify the reporting process and improve the
monitoring system, increasing the likelihood that food-related disease
outbreaks were detected earlier, saving the lives and improving the health
outcomes of many animals.
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