A new White Paper, “Raw Safety: Mitigating the 20x FDA Recall Risk of Fresh Pet Food“, was recently published in an industry website, written by a food irradiation company. Due to the many misleading statements made in the paper, we assume it was published to scare pet owners so badly they would be open to having a raw pet food treated with irradiation.
The most concerning statement in the White Paper is this: “Raw Pet Foods Are 20x More Likely To Be Recalled.”
To make their shocking claim, the White Paper lumps pet foods into two style categories; raw and non-raw.
We did the same thing. All of the data we provide here is segmented into the same two categories of pet food – raw and non-raw.
Regarding this shocking claim “Raw Pet Foods Are 20x More Likely To Be Recalled”, the Irradiation Industry White Paper states that “despite being < 10% of the market they are responsible for ~67% of recalls, making raw pet foods over 20x as likely to be contaminated with pathogens as compared to non-raw pet foods.”
However, considering market share or not considering market share – no matter how we tried to calculate it, we could not determine how they arrived at their shocking ’20x’ claim regarding the risk of raw pet foods.
Based on FDA recall data – number of recall incidents – and specific to pathogenic bacteria recalls from 2018 through 2025:
Non-raw recalls – 42%.
Raw recalls – 58%.
Definitely NOT 20x more.
The misleading White Paper discusses the number of recall incidents only. However, recalls can vary in size (pounds recalled) dramatically.
As example, in 2022 Primal Pet Food issued a recall (raw pet food) for Listeria. This one particular recall involved 2,376 pounds of pet food.
As compared to…in 2021 Midwestern Pet Food issued a recall (dry pet food) for Salmonella. This one particular recall involved 6,509,819 pounds of pet food.
Without doubt, six million pounds of contaminated pet food can pose a higher risk than two thousand pounds of contaminated pet food. Regardless of the cause of a recall, more pounds of pet food recalled equals more potential exposure to pets and people. Basing a shocking and industry damaging claim on the number of recalls without disclosing the actual number of pounds of pet food involved in each recall is misleading.
Based on the FDA Enforcement Reports, we have been documenting and totaling pounds for each pet food recall since 2012.
When we total the pounds of pet food recalled for pathogenic bacteria over the same time frame the white paper referenced – it tells a very different story.
Based on pounds recalled from 2018 through 2025 for pathogenic bacteria:
Non-raw: 8,478,207 pounds of pet foods recalled for pathogenic bacteria were non-raw.
Raw: 1,512,655 pounds of pet foods recalled for pathogenic bacteria were raw.
When looking at all of the causes of recalls from 2018 through 2025 in pounds, again it tells a different story.
Based on FDA Enforcement Report records, more than 173 million pounds of non-raw pet foods were recalled from 2018 through 2025, with only 1.5 million pounds of raw pet foods recalled.
While irradiation might sterilize a pet food sufficiently to prevent pathogenic bacteria recalls, irradiation cannot prevent the following non-raw pet food recall concerns that we experienced over the past 8 years.
From 2018 through 2025.
Pounds of pet food recalled for excess or insufficient vitamins or minerals, the largest example in this time frame was for excess vitamin D which resulted in many pet deaths:
Pounds of pet food recalled for aflatoxin contamination which resulted in many pet deaths:
Pounds of pet food recalled for pentobarbital contamination (the drug used to euthanize animals):
This irradiation industry White Paper needs to fully explain their math, fully explain how they made the shocking (and damaging claim) “Raw Pet Foods Are 20x More Likely To Be Recalled.”
They also claim in the Paper “2025 Is the Highest Number of Preventable Pet Food & Treat Recalls, Ever”. Again, we cannot explain their math. In 2025, a total of 166,071 pounds of pet foods and treats were recalled. Far lower than many other years.
Is this Irradiation Company trying to shock/scare pet owners into trusting irradiated raw pet food? Would you purchase an irradiated raw pet food?
Susan Thixton
Pet Food Safety Advocate
Author Buyer Beware, Co-Author Dinner PAWsible
TruthaboutPetFood.com
Association for Truth in Pet Food
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