H5N1 Raw Food Cat Deaths Spur Federal Guidance by APHIS and FDA

CNN article explores raw meat and milk pet deaths on West Coast; Washington Post account of critically ill Canadian H5N1 victim is a lesson in non-scalability of intensive treatment required

Friday afternoon was a lesson in “don’t leave the office early” for federal news reporters! Both USDA APHIS and HHS FDA released major policy initiatives related to H5N1 human and pet food safety concerns in response to recent deaths of several domestic cats and big cats in shelters linked to raw meat products (raw turkey): What is the Deal with H5N1 in captive big cats in December?

FDA updated Pet Food Guidance:

First, here is the FDA press release, which goes into some detail regarding FDA’s role in regulating (or not) the manufacture and safety of pet foods:

Cat and Dog Food Manufacturers Required to Consider H5N1 in Food Safety Plans | FDA

January 17, 2025

The U.S. Food and Drug Administration has determined that it is necessary for manufacturers of cat and dog foods who are covered by the FDA Food Safety Modernization Act Preventive Controls for Animal Food (PCAF) rule and using uncooked or unpasteurized materials derived from poultry or cattle (e.g., uncooked meat, unpasteurized milk or unpasteurized eggs) to reanalyze their food safety plans to include Highly Pathogenic Avian Influenza virus (specifically H5N1) as a known or reasonably foreseeable hazard. Furthermore, the FDA is issuing this update to ensure that cat and dog food manufacturers are aware of information about the new H5N1 hazard associated with their pet food products, which is an additional reason that manufacturers must conduct a reanalysis of their food safety plans.

The FDA is tracking cases of H5N1 in domestic and wild cats in California, Colorado, Oregon and Washington State that are associated with eating contaminated food products. Scientific information is evolving, but at this time it is known that H5N1 can be transmitted to cats and dogs when they eat products from infected poultry or cattle (e.g., unpasteurized milk, uncooked meat, or unpasteurized eggs) that have not undergone a processing step that is capable of inactivating the virus, such as pasteurizing, cooking or canning. Cats (domestic and large felids) in particular can experience severe illness or death from infection with H5N1. Dogs can also contract H5N1, although they usually exhibit mild clinical signs and low mortality compared to cats. At present, H5N1 has not been detected in dogs in the United States, but there have been fatal cases in other countries.

The FDA Food Safety Modernization Act Preventive Controls for Animal Food (PCAF) rule requires that certain animal food businesses develop a food safety plan. In this food safety plan, animal food businesses must identify and evaluate known or reasonably foreseeable hazards for each type of animal food manufactured, processed, packed, or held at their facility to determine whether there are any hazards requiring a preventive control. Businesses must identify these hazards based on experience, illness data, scientific reports, and other information. In the hazard evaluation, animal food businesses must assess the severity of the illness or injury to humans or animals if the hazard were to occur and the probability that the hazard will occur in the absence of preventive controls. The animal food industry can find guidance related to these requirements in the FDA’s Center for Veterinary Medicine’s Guidance for Industry #245, “Hazard Analysis and Risk-Based Preventive Controls for Food for Animals.”

Under the PCAF requirements, animal food businesses must conduct a reanalysis of their food safety plan when the FDA determines it is necessary to respond to new hazards and developments in scientific understanding. The FDA has determined that it is necessary for cat and dog food manufacturers covered by the PCAF rule, who are using uncooked or unpasteurized materials derived from poultry or cattle (e.g., uncooked meat, unpasteurized milk, unpasteurized eggs) in cat or dog food, to reanalyze their food safety plans to include H5N1 as a new known or reasonably foreseeable hazard.

The reanalysis is necessary to respond to the recent domestic cat illnesses and deaths described above and to scientific data indicating that cats and dogs have become ill from consuming H5N1 virus. Manufacturers that implement a preventive control for the H5N1 hazard as a result of their reanalysis will be taking an important step toward protecting cat and dog health and helping to prevent spread of H5N1. Addressing H5N1 will require a concerted effort across sectors, including by government, businesses, and consumers.

Manufacturers also are required to conduct a reanalysis of their food safety plans when they become aware of new information about potential hazards associated with animal food. The FDA and the American Veterinary Medical Association have previously published information on risks to pets from H5N1, which has been amplified in mainstream media. Some additional published references are listed below.

As we learn more about the transmission of H5N1 in animal food, there are several practices that the FDA is encouraging pet food manufacturers and others in the supply chain to use to significantly minimize or prevent H5N1 transmission through animal food. These practices include seeking ingredients from flocks or herds that are healthy, and taking processing steps, such as heat treatment, that are capable of inactivating viruses. For example, some businesses already implement a heat treatment step that is capable of inactivating the virus as a process control. Heat treatments have been shown to be effective for inactivating H5N1 in meat, milk, and egg products. A different practice would be to implement a supply-chain-applied control to provide assurance that ingredients used in animal food do not come from H5N1-infected animals.

To assist animal food businesses as they conduct their reanalysis, we have included a summary of current scientific literature regarding (1) the prevalence of H5N1 in cattle and poultry and their animal-derived ingredients, (2) the severity of H5N1 illness or injury in cats and dogs, and (3) the impact of processing steps on inactivating H5N1.

The FDA and the United States Department of Agriculture (USDA) remain confident in the safety of the food supply. USDA’s Food Safety and Inspection Service, Animal and Plant Health Inspection Service, and Agricultural Research Service (ARS) have completed multiple studies to confirm that meat, poultry and eggs that are properly prepared and cooked are safe to eat. Additionally, to verify the safety of the meat these agencies have completed three separate beef safety studies related to avian influenza in meat from dairy cattle. Furthermore, USDA and the U.S. Food and Drug Administration (FDA) have performed multiple retail sampling studies to reaffirm the safety of the pasteurized milk supply and milk products.

All that verbiage is somewhat vacuous in my mind. If I was a raw pet food seller (NO chance of that), I’d have to really ponder how to meet HAACP steps to “implement a supply-chain-applied control to provide assurance that ingredients used in animal food do not come from H5N1-infected animals”.

I came across a CNN article on Saturday that put some human faces on the feline deaths on the west coast: With bird flu cases rising, certain kinds of pet food may be risky for animals – and people. I have to admit that I really struggle to understand the mindset of enthusiasts for raw food for pets and raw milk for people and pets; however, these people are obviously here to stay in pretty significant numbers, with raw pet food and raw milk likely to remain on the shelves indefinitely.

USDA APHIS Pilot Enhanced Pre-Harvest Turkey Surveillance:

In the second Friday release, APHIS weighed in with an updated pilot program for enhanced preharvest surveillance of turkey flocks 72 hours prior to scheduled slaughter:

APHIS Updates Policy to Enhance Surveillance of Turkey Flocks in Highly Pathogenic Avian Influenza Affected States

WASHINGTON, January 17, 2025—As part of its ongoing, multi-faceted efforts to combat the spread of highly pathogenic avian influenza (HPAI), USDA’s Animal and Plant Health Inspection Service (APHIS) today is updating its policy for pre-slaughter surveillance to enhance testing of turkey flocks in affected states. In late December 2024, APHIS became aware of a genetic link between turkeys potentially infected with HPAI H5N1, virus detected in raw pet food, and an infected household cat.

Out of an abundance of caution, and to remove a potential avenue for ongoing disease spread as well as to bolster consumer and trading partner confidence, APHIS collaborated with state animal health officials and the poultry industry to update its guidance for existing pre-slaughter surveillance steps to further ensure that affected poultry does not enter the food system. APHIS will continue to report confirmed HPAI detections to the World Organisation for Animal Health and on the APHIS website (more information below).

These updates include implementing isolation with clinical monitoring and premovement testing 72 hours prior to sending to slaughter, for turkey premises outside control areas in HPAI-affected states. Specifically, APHIS will be piloting this enhanced pre-slaughter surveillance, starting with turkey premises greater than 500 birds in Minnesota and South Dakota, based on current and historical HPAI detections of commercial turkey premises in these states. These states were selected because of genetic linkages to virus from infected cats and because of the high percentage of cases in turkeys in those states. APHIS will continue to evaluate progress of the outbreak and may update this policy, if needed, to include additional states.

APHIS realized the obvious here - H5N1-infected turkeys were slaughtered last summer in the upper Midwest, likely passing through visual FSIS slaughter inspection while incubating infection prior to visible clinical disease. The infected carcasses contained sufficient virus to infect frozen turkey products which were later distributed to pet food manufacturers and/or meat sources for big cat sanctuaries. The infection came to light due to later feeding of thawed raw product to feline species, who are extraordinarily susceptible to H5N1 2.3.4.4b B3.13 virus.

While left unspoken, it’s also highly likely that infected turkey was also distributed for human consumption. As with pasteurized milk, H5N1-laden cooked meat is perfectly safe for human consumption if slaughtered and handled with protective measures prior to cooking. Therein lies the real danger with H5N1-infected poultry and read meat products!

Slaughter plants employ line workers (and FSIS inspectors) with daily exposure to raw carcasses and internal organs. H5N1 infected carcasses present a health hazard to them, as well as on to wholesalers, retailers, and consumers preparing meals from raw product. It is not a safe or sustainable meat industry practice to routinely market meat products with more than a negligible risk for contamination with a known zoonotic viral agent.

My primary concern with the proposed pilot program is the 72-hour window between testing and processing. HPAI infection in poultry is fast! Birds infected 70 hours prior to slaughter (after swabbing) may well be dead by the date of scheduled shipment! A negative test is more predictive each hour closer to slaughter it is conducted. I fear that the mechanics of shipping samples to a NAHLN (and perhaps on to NVSL, as I presume this program requires), compromises the efficacy of the main objective of the pilot.

This rapid detection objective is an ideal application for a Point-of-Care (POC) antigen test! 2 or 3 POC tests run in tandem by farm or plant personnel with 90% sensitivity at the time of shipment would be vastly superior to a single NALHN test with 98% sensitivity run at 72 hours in meeting detection objectives and be much cheaper to boot! No one wants to ship infected turkeys here! The USDA has to loosen the testing reins to make this work effectively. Positive POC’s would of course be confirmed at NVSL to qualify the infected flock for indemnity. Most importantly, last minute infected flocks incubating infection would avoid going to slaughter as a “false negative” flock with an out-of-date 72-hour negative NAHLN-NVSL test.

Another concern relates to coverage for turkeys in other states. H5N1 D1.1 is extremely widespread at this point, well beyond the 2 pilot states. Hopefully the program will soon expand to all at-risk slaughter flocks based on seasonal and migratory bird infection risk.

Finally, California has reported cat mortalities allegedly linked to a raw pet product reportedly sourced from free range chickens in the Central Valley. It’s hard to know what the inspection status of that product may have been. Regardless, there is at least a possibility that H5N1-incubating broiler flocks could slip through FSIS inspection similar to what seems to have occurred with turkeys. If scientifically plausible, broiler risk also needs to be addressed with some sort of pre-slaughter monitoring process for that industry.

What About Beef?

We lack robust data on H5N1 virus our red meat supplies, and no one in institutional agriculture is in a big hurry to make further assessments! FSIS has announced a limited cow beef H5N1 sampling program: H5N1 and Safety of U.S. Meat Supply | Animal and Plant Health Inspection Service

On September 16, 2024, FSIS added H5N1 influenza A monitoring of muscle samples from culled dairy cows to its already robust national surveillance programs for pathogens and chemical contaminants. Samples are being tested by FSIS laboratory personnel for presence of influenza A virus using polymerase chain reaction (PCR). Carcasses are held by establishments pending results. FSIS will update the results of the H5N1 testing on this website every other Friday.

• As of January 1, 2025, FSIS has results from 208 diaphragm muscle samples. Of these, samples from one dairy cow, as well the kidney from that animal, indicated a positive for H5N1 influenza A at very low levels.

208 samples have been collected over approximately 3 months with one positive sample from a California cow. Frankly, that is not a large enough sampling set from a subset of the total beef supply to draw any conclusions, other than that the risk is not 0! Early research published on infected cows found viral antigen in multiple tissues, including heart muscle. However, unlike an earlier FSIS finding of H5N1 antigen in a condemned cow at slaughter, this finding was in a cow passed for consumption but held for sampling (and later discarded due to the positive finding). So, the implication is that at least a small number of asymptomatic PCR-positive animals may be passing inspection for human consumption.

A larger concern for me is lack of published research and outright institutional hostility towards understanding any inroads that H5N1 has made into cattle outside of lactating cows. I’ve heard of H5N1 serological results not allowed to be published because of implications they bring to the beef industry. There is “chatter” of increased treatment-resistant respiratory illness in feedlots, accompanied by an unwillingness to explore PCR diagnostics for underlying viral influenza (H5N1) as a possible etiology.

The ecosystem is currently “raining” H5N1 into the cattle, sheep, and swine environments. This virus infects multiple species quite easily, experimentally demonstrated in cattle and swine. Diagnosticians in both large and companion animals should be routinely running influenza matrix PCR tests on respiratory swabs of sick individuals and groups of animals in multiple species. Positive samples should routinely be genotyped. Selected serological H5N1 herd profiling studies in cattle would be quite revealing if publishing was permitted.

I’m not naive; I know that veterinarians and researchers in the trenches face immense pressures to not rock the boats of clients or industries and lose income. However, kicking this virus down the road for some other poor veterinarian to diagnose only compounds the problem for everyone. The dairy industry and its veterinarians have faced these moral issues first, but I believe that the same questions are now upon beef and swine veterinarians. One option is some version of “shoot, shovel and shut up”; the other is following your curiosity and your oath where it leads you.

For my final thoughts, please read this article carefully:

Bird flu almost killed this teen. It’s a cautionary tale for Trump officials. - The Washington Post

How many kids can we support nationally with the level of medical care required to save them if this virus gets its legs? COVID19 specialized in the elderly; H5N1 may specialize in the young, providing an entirely different public narrative for the Trump Administration regarding the merits of the “Deep State” and pandemic response activities. Dead children will always have a chilling effect on idealogues; I hope we don’t discover that in a very painful way.

Please, let’s all move forward, for our grandkids…

John