ECFR pet food aflatoxin CPG 555

FDA's aflatoxin action levels for pet food are set by Compliance Policy Guide Sec. 683.100 'Action Levels for Aflatoxins in Animal Food' (CVM, March 2019 — replacing the August 1994 version). Key facts from the CPG: (1) Aflatoxins (B1, B2, G1, G2) are toxic by-products of mold growth on certain agricultural commodities; in 1969 FDA set a 20 ppb action level for all foods including animal food, later revising levels for beef cattle, swine and poultry based on feeding studies. (2) The action level for pets (dogs, cats, rabbits, etc.) OF ALL AGES is 20 ppb total aflatoxins in corn, peanut products, cottonseed meal, other food ingredients and complete pet food — there is no separate, higher puppy/kitten level. (3) Higher livestock levels: 300 ppb (corn/peanut products for finishing feedlot beef cattle; cottonseed meal for beef cattle, swine or poultry), 200 ppb (corn/peanut for finishing swine ≥100 lb), 100 ppb (corn/peanut for breeding beef cattle, breeding swine, mature poultry), 20 ppb for immature animals, dairy animals and unknown intended use. (4) To take regulatory action FDA must confirm intended use and show aflatoxin levels support an adulteration charge under FDCA section 402(a)(1); samples are analyzed per current AOAC Official Methods of Analysis, with identity confirmed by chemical derivative formation. (5) The CPG itself records that in 1998, 2005, 2011 and 2013 aflatoxin contamination of dog and cat food caused illness, dog mortalities and extensive recalls; the 2005 event was the Diamond Pet Foods recall (FDA received reports of at least 76 dogs believed to have died, per AVMA JAVMA News 2006). Note: 'CPG 555.100' cited in the earlier version of this topic does not exist for pet food aflatoxins (CPG 555.400 covers aflatoxins in HUMAN food); the '100 ppb for puppies/kittens (more cautious)' claim was both unsourced and self-contradictory.