A year ago, Canada's Menu Foods announced it was recalling more than 60 million containers of dog and cat food sold in the United States. Although the name Menu Foods wasn't familiar to pet owners, the recalled cans and pouches bore the labels of dozens of the most familiar and trusted brands in the marketplace.

In the end, more than 1,000 brands of pet food were recalled over a period of about four months, and two chemicals, melamine and cyanuric acid, were blamed for kidney failure that killed thousands and sickened tens of thousands of pets from what came to be called melamine-associated renal failure.

Once the contaminants were identified, the reason they ended up in pet food was clear: profit. Melamine and cyanuric acid falsely show up as proteins in certain tests of food ingredients. They were added to plain wheat flour in China, enabling it to be sold as more expensive, higher-protein ingredients like gluten.

I didn't guess when I began covering this story with Gina Spadafori at Pet Connection that it would turn into the largest consumer recall in history, trigger an international trade scandal, launch congressional hearings, spur proposed legislation on food safety and get both American and Chinese businesses owners indicted. I couldn't have foreseen that the incident would put a spotlight on Chinese imports which would eventually reveal lead in children's toys and toxins in toothpaste, and prompt the recent recall of the drug heparin.

But it's equally hard to believe that after all that, the answer to the question "Could it happen again?" is probably "Yes."

The reason for that is simple: None of the changes that might prevent a repeat of last year's pet food recall have been implemented. There have been no improved inspections of pet food plants, no comprehensive overhaul of the patchwork of state, federal and industry manufacturing standards and regulations, no increased transparency and accountability — not even something as simple as printing the name and contact information of the actual manufacturer on pet food labels — and no revisions to pet food labeling laws. The Food and Drug Administration still does not have the authority to issue mandatory recalls.

Most of us closely involved in this story find all that hard to understand. "In this age of potential bio-terror and random cross-species crossover horrors like the avian flu, this is incomprehensible," said Pet Connection editor Gina Spadafori. "Our animals are the canaries in the coal mine, and as bad as the death toll was in our pets, it could have been much, much worse, in both animal and human populations. So why is there still not a national veterinary reporting system for a nationwide emergence of disease that is not only killing animals but could also potentially already be in or emerging in the human population? And why are we still unable to inspect all but the tiniest percentage of imported foods?"

Dr. Marion Nestle, a professor of nutrition, food studies and public health at New York University and a well-known author of popular books on food safety, food politics and nutrition, has a new book, "Pet Food Politics: The Chihuahua in the Coal Mine" due out in September. "I'd like to think that fundamental changes have occurred," she told me. "The pet food industry as a whole took a big hit and everyone learned some lessons. Companies across the board are looking more carefully at sources, demanding and doing more testing and upping their quality controls."

Unfortunately, she said, that's not enough: "The industry's responses are voluntary and they need to do more to restore trust. Food industries cannot be counted on to regulate themselves, and until there is better regulation — including FDA recall authority and better labeling — there will still be grounds for distrust."

Nestle isn't completely pessimistic, however. "I'd like to think that some good will result from this mess, and I do see hopeful signs," she said. "Lots of companies say they are using better ingredients in their products, being much more careful about where their ingredients come from, and demanding higher standards from suppliers and co-packers. Companies say they are testing for melamine and other toxins. Some of the testing is driven by retailers. Pet Food Express, for example, only sells products from companies that provide actual test data."

If the pet food industry or the FDA had put that kind of testing in place earlier, the 2007 recall may not have happened at all. The adulteration of protein concentrates with melamine and cyanuric acid was found to be both longstanding and widespread in China, so it seemed unlikely something like this hadn't happened before.

And in fact, it had. The Journal of Veterinary Investigative Diagnosis recently reported that melamine and cyanuric acid contamination was responsible for the deaths of thousands of pets in 2004.

Researchers working with tissue samples from animals who died in the U.S. recall compared them to samples from pets who died in a number of Asian regions including the Philippines, Japan, South Korea and Hong Kong. Those deaths led to a recall of Pedigree dog foods and Whiskas cat foods, and were blamed on mycotoxin contamination. But the study found that both groups of pets had the unmistakable crystals and damage in the kidneys caused by melamine and cyanuric acid.

While there's no evidence any other mycotoxin-attributed food recalls, pet or human, were misidentified, it does put the pet food recall squarely in the big picture of this country's broken food safety system.

A fix for that broken system may be coming, even if it's a bit slow. The FDA recently announced a meeting where it will discuss changes in the regulation of pet food ingredients, processing and labeling with representatives from the pet food industry, government agencies, veterinary medical associations, animal health organizations and pet food manufacturers at that meeting. One group not on that list is pet owners, but they have asked to hear from us. Comments should be made on docket number 2007n-0487.

"The recalls exposed deep problems with food safety regulation in China as well as in the United States, and I see many signs of efforts to do something about them," said Nestle. "Lasting improvements won't happen overnight, and they won't happen at all unless people who care about these issues keep pressuring the industry and the FDA to do what they say they will do."

Please include the docket #2007N-0487 along with your comments. The available means of submitting comments to this docket are:

(1) via FAX at 1-301-827-6870;

(2) mailing hard copy to the Dockets Management Division:

Walt D. Osborne, M.S., J.D.
Regulatory Policy Analyst & Ass't. Editor, FDA Veterinarian
Policy & Regulations Staff (HFV-6)
Center for Veterinary Medicine
7519 Standish Place, Rm. 174
Rockville, Maryland 20855

(3) hand-delivery of hard-copy comments; or

(4) e-mailing them to walter.osborne@fda.hhs.gov.
