Take a behind-the-scenes look at what goes on in our pet food manufacturing. We’ve accepted Netflix’s Pet Fooled “Talk to Us” nationwide request of pet food companies to lift their veil of operations on an otherwise very secretive industry. With no restrictions, we give you an insider’s look at our farms, plants, sources, and practices. Meet Answers.
Fleetwood, PA, July 8, 2019. – Lystn, LLC d.b.a./ANSWERS™ Pet Food, announced today that the company has filed a Declaratory Judgment Complaint and is seeking Injunctive Relief against the Food and Drug Administration (FDA), in the United States Colorado District Court. The complaint challenges the lawfulness of the FDA’s actions, with cooperation provided by various members of the Association of American Feed Control Officials (AAFCO), by adopting a nationwide, zero tolerance standard for Salmonella in pet food that is noncompliant with federal law, unsupported by science, and beyond the FDA’s scope of power as delegated by Congress.
While the United States Department of Agriculture (U.S.D.A) permits allowable quantities of Salmonella in human food, the FDA who regulates pet food, rather than following federal law as set forth by the federal Food, Drug and Cosmetic Act (FD&C ACT), has instead adopted an unsustainable, zero tolerance standard for Salmonella presence in pet food, based on a “Non-Binding” Compliance Policy Guide (CPG). FDA guidance policies do not establish legally enforceable responsibilities, yet the adopted, supposedly nonbinding CPG has the FDA taking enforcement actions against manufacturers and imposes obligations upon the manufacturer creating legal consequences flowing from it.
The FD&C Act defines when a product is adulterated. It requires in addition to several other steps a suspected harmful substance be quantified, and a Health Hazard Evaluation be performed to determine if the product ordinarily renders it injurious to health. Currently the FDA does not follow the law for the more than 2,500 strains of Salmonella, most of which do not cause illness, but does quantify other contaminants such as aflatoxin in dry pet food, creating allowable tolerances. The Food Safety Modernization Act (FSMA) grants the FDA authority to mandate a recall, but only after following the FD&C Act.
ANSWERS™ approach to food safety and controlling pathogens is unique. In lieu of using high heat, high pressure or irradiation that denatures proteins, ANSWERS™ employs fermentation, Hurdle Technology and other proprietary processes, to preserve the integrity of the food, controlling pathogens and potential pathogens by either eliminating them, reducing them or inhibiting growth whereby good bacteria can survive and out compete harmful bacteria.
Keith A. Hill, President of Lystn, LLC, stated, “ANSWERS™ Pet Food would be the first party to initiate a recall if there was any indication of one of their products being a likely health risk to either pets or their owners, but when the science proves otherwise as provided by federal law, a manufacturer should not be coerced based on administrative policy view in contrast to the law.”
A report published in 2007, “FDA Science and Mission at Risk”, cited the FDA couldn’t fulfill its mission due to such issues as: a weak scientific organizational base and structure, with insufficient capacity and capability, and an inadequate information technology infrastructure. Using the CPG is easy and inexpensive to quote, but expensive for the public to present meaningful science to challenge these guides and deprives persons their due process and right to participate in regulation. As a result, the FDA, AAFCO and participating states are deciding what the public can and should feed their pets based on administrative policy views, not science or the law – taking away the public’s freedom of food choice.
Also addressed in the complaint, is the alleged extensive FDA regulatory abuse. ANSWERS™ asserts the FDA is unlawfully targeting the raw pet food industry, seeking to eradicate true, raw food from the marketplace through discriminatory and selective behavior. The FDA has been open in their bias against the raw pet food industry, despite the fact that the majority of reported illnesses occur in cooked and heavily processed food.
Detoxifying and Nutrient-dense Feeding— treatment combination of fermented raw milks.
Lyme disease, and other tick borne illnesses such as Anaplasmosis, are complicated bacterial infections. Symptoms are not always present. When they do present themselves, they tend to appear long after the tick bite has occurred. When the disease is diagnosed early, antibiotics are not unreasonable, and often eradicate the organism in Lyme. However, chronic Lyme tends to exacerbate into chronic attacks. Furthermore, antibiotics may cause other health-related side-effects that need to be treated as well.
The fundamental cause of disease is inadequate nutrition. AnswersTM raw milks are very high in whole-food probiotics and provide good bacteria, which is instrumental in fighting off inflammation, healing the gut, and rebuilding the body’s immune system. Fermented raw nutrition provides blood plasma much like a blood transfusion. Nutrients go to the far corners where Spirochete, a serious pathogen or bad bacteria that causes these diseases, hides and lays dormant.
Fermented raw milks are nutrient-dense and contribute to healthy flora in the digestive system. Correcting leaky gut will allow the inflammatory response to turn off which can profoundly improve any condition permitting the immune system to work the way it was designed and not in a state of constant inflammation.
For more information about our recommended diet, click here: APF_1258_LYME_SellSheet
YEAST— BALANCING THE IMMUNE SYSTEM
Having Proper Flora Levels
A balanced, healthy immune system helps eliminate yeast infections that are caused by an under-active immune system, or pets that are immuno-suppressed. Our raw diet formulations will establish the proper pH balance, preventing yeast overgrowth, and reducing inflammation triggered by an underactive immune system. Kefir has Saccharomyces yeast that covers the cell preventing Candida from entering the cell.
AnswersTM raw formulas are very high in whole-food probiotics and healthy yeast. They’re low in carbohydrates, have only trace amounts of naturally occurring sugars, which is a main component in feeding yeast, and has the natural balance of nutrients that your pet needs.
This all contributes to healthy flora in the digestive system, boosts the immune system, and regulates proper pH balance, eliminating yeast.
For more information on recommended daily diet, click here:
This press release by Lystn, LLC d.b.a./ANSWERS Pet Food is in response to the January 14, 2019 Food Drug and Administration Warning Notice: “FDA Cautions Pet Owners Not to Feed One Lot of A+ Answers Straight Beef Formula for Dogs Due to Salmonella”.
Before addressing the history and investigation behind the events leading up to the FDA’s posting of this Notice, please allow Lystn to correct a number of errors in the FDA’s Notice:
(1) The Best Use By Date (BUBD) is incorrectly listed as 20/08 20. The correct BUBD is 02/08 20.
(2) The statement that Lystn has recalled the affected lot in Nebraska is not correct. Lystn stopped further distribution of the lot in question working with Lystn’s distributor, retail stores and the Nebraska Department of Agriculture who reported the follow-up that the product was removed from retail store shelves.
(3) Just one reason Lystn has not implemented a nationwide recall is because the product was only tested by the State of Nebraska and Lystn for which the test results were contradictory addressed below, and not tested by the FDA.
The FDA Notice comments that the reason why the FDA issued this warning is because it (the product in question) represents a serious threat to human and animal health and is adulterated under the Federal Food, Drug, and Cosmetic Act (FD&C Act). It is important to note that neither Lystn nor any government agency has received any report of animal or human illness. Neither the State of Nebraska nor the FDA quantified the alleged finding of Salmonella which is just one factor for consideration when defining adulterated food under the FD&C Act. The FDA uses a Compliance Policy Guide which contains Nonbinding Recommendations of a “zero tolerance” of Salmonella for enforcement. In contrast to human consumed products inspected by the USDA, a certain percentage of Salmonella is allowed (some of the same sourcing Lystn buys as ingredients for its pet food). For just some of the reasons stated below, Lystn disagrees with the FDA “zero tolerance” policy, based upon our understanding of science and the FD&C Act. For additional information on our response to the FDA and Lystn’s position on these and other raw pet food industry issues, please visit our website. Additional information is forthcoming through continued updates.
Because Salmonella is prevalent throughout much of the food chain and in our environment, Lystn formulates ANSWERS Pet Food products to protect the pets and their owners from potential harmful bacteria using what is referred to as “Hurdle Technology”. One step of Lystn’s Hurdle Technology uses natural competitive inhibition through fermentation by inoculating our products, which favors growth of desirable (good) bacteria but inhibits the growth of pathogens (bad bacteria). This avoids destroying the benefits of good bacteria needed in the gut of the pets ingesting ANSWERS Pet food and continues to protect the pets post ingestion and the household environment from potential pathogens.
One (1) random test by the Nebraska Department of Agriculture was sampled 12/10/18 and revealed the presence of Salmonella in the Straight Beef Formula 4lb. Pounder for Dogs. Lystn requested a split sample of the product in question and while a confirmation of Salmonella was detected on the initial sample supplied by Nebraska, there was insufficient quantity to run all the quantitative tests. Lystn requested and received a subsequent larger quantity and all 4 samples tested negative for the presence of Salmonella. It is Lystn’s belief (as well as our science advisors) that the initial sample sent from Nebraska may have been cross contaminated in the lab, transport or elsewhere and should not be considered a representative sample. Even if Salmonella was present in the initial sample, equally important was that the quantification of Lactic Acid Bacteria in the subsequent samples was significant in quantity (greater than Log 7) confirming that our fermentation process was working and therefore evaluated as a safe product by Lystn’s team of scientists and advisors.
Lystn’s Hurdle Technology and labeling addresses the concerns expressed by the FDA regarding product exposure and handling risks to children and immune compromised individuals, in that the good bacteria from the fermentation process continues to compete with bad bacteria, regardless of manner of exposure. Lystn’s labeling conspicuously identifies the products as being in the raw state and states – “For Pet Use Only: Not for human consumption. This product has not been pasteurized and may
contain harmful bacteria.” The labeling also contains – “Safe Handling Instructions: Keep raw meat separate from other foods. Wash working surfaces, utensils, hands and any other items that come in contact with raw meat with hot soapy water.“
We advised the FDA of Lystn’s extensive third party test results and science based evaluation that the food is safe and not a public health risk, in accordance with the assessment of an independent Ph.D. science expert in concurrence with Lystn’s science team. Nevertheless, the FDA proceeded to issue this Warning Notice without further consultation with Lystn.
Many of our distributors, customers, and retailers alike understand Lystn’s use of competitive inhibition through the process of fermentation to protect our foods from pathogens. But, if after presenting our customers with our views, if a customer is uncomfortable with an ANSWERS’ product, they may return it (or any unused portion) to the place of purchase for a full refund. The Straight Beef Formula 4lb. Pounder for Dogs product comes in a cardboard milk carton box marked with lot code 2018 and a Best Use By Date (BUBD) of 02/08 20 sticker on the carton. The above referenced lot number and BUBD Lystn product was distributed at various times from 8/17/18 to 9/14/18 and sold through retail stores within the United States.
ANSWERS Pet Food continues to be at the forefront as a leader in transparency and is committed to keeping you informed. We are in the process of creating a page on our website for the web and social media for our customers to go see the latest information concerning state and federal regulatory matters applicable to ANSWERS Pet Food and the raw pet food industry. To learn more about ANSWERS, our unique process, and the raw pet food industry, please visit our website at www.answerspetfood.com.
The above comments and observations by Lystn are the current view and understanding of Lystn and not intended to be a statement of law nor contain all details that may apply. Thank you for time and understanding.
Lystn, LLC, Manufacturer of Answers Pet Food
Roxanne Stone, VP of Quality Assurance/Quality Control (801) 707-2175 or email@example.com
By Roxanne Stone, Vice President of Research and Development for Answers Pet Food
At Answers Pet Food, our philosophy on pet nutrition is fairly simple. We believe Mother Nature is the best authority on proper animal nutrition and it’s difficult to argue otherwise. A quick glimpse into observing the diets of canine ancestors, as well as their wild counterparts—the wolves, is all that is necessary to gain a good understanding of their basic diet and what makes them thrive.
Once most pet owners do even a small amount of research on dog or cat nutrition, the decision to feed raw is obvious. We encourage all pet owners to become educated on the basics of pet nutrition so they have the knowledge and tools to make the best choice in feeding their pets.
Historically, it has only been in recent years (about 80 years ago), that our pets have been introduced to the highly processed, sterile, grain based, enzyme deficient, modern diet. Prior to this, they consumed a raw, protein-based diet either through hunting smaller animals and rodents or from the raw bone and meat scraps they received from their human caretakers.
It isn’t surprising that we can observe a parallel in the same degenerative diseases and allergies in our pet populations that we see in our own human population, as humans have also moved to this highly processed, high carbohydrate diet.
Dr. Karen Becker, DVM and licensed Naturopathic Medical Doctor, clearly explains that the short G.I. tracts of dogs and cats (carnivores) are not designed to digest large amounts of carbohydrates, which unfortunately are the base of most commercial pet foods. Rather, they are intended to digest raw protein based diets. Dr. Becker links many of the following diseases to the high carbohydrate, grain based pet food diets including;
• chronic skin conditions
• auto-immune diseases
• urinary tract infections
• kidney stones
• degenerative joint disease
• and cancer
…just to name a few.
Many pet owners who see the nutritional benefits of raw are reluctant to try it for fear of harmful bacteria. Dr. Doug Knueven, DVM and author of The Holistic Health Guide, Natural Care For The Whole Dog, mentions that in his experience, pathogens such as E. Coli and Salmonella, are rarely a problem for dogs and they are able to handle these bacteria much the same way their ancestors have for millennia.
We agree that healthy pets with well developed gut micro-flora should not experience any ill effects from consuming raw meat. However, Answers Pet Food also takes food safety and manufacturing to the highest level when sourcing and preparing our products. We understand that reducing the risk of harmful bacterial contamination starts at the farm, and in the manner the livestock are raised, fed, and handled. All of our raw meat ingredients are sourced from livestock that are free-range, pasture-fed, and have never ever been administered growth hormones or antibiotics. Our raw meat ingredients are from USDA inspected facilities and are passed for human consumption.
Answers puts strict quality control measures in place at our manufacturing facility (also USDA inspected) to control pathogens. In fact, many of our ingredients are delivered fresh and processed upon arrival to deliver the highest quality end product. In addition, we use one of the most traditional methods in the history of food preparation for reducing the potential growth of harmful bacteria—fermentation. We add fermented green tea (decaffeinated kombucha) into each batch of our Detailed formula. This decreases the overall pH of the product, provides a competitive environment of “good, beneficial bacteria” and reduces the growth of any harmful bacteria.
On the consumer level, raw products should always be handled with the utmost care and concern. We recommend following the same safe handling procedures as you would when preparing your own meals using raw ingredients. Always keep raw food separate from cooked and ready to eat products. This can be as simple as dedicating one of the lower shelves or drawers in the refrigerator to raw products only. Wash all surfaces, utensils and hands thoroughly with hot, soapy water after they come in contact with raw products. Keep raw products frozen until you are ready to thaw and serve them. Once raw products are completely thawed they should be kept refrigerated (<42°F) and consumed by the pet within 7 days. We recommend not to re-freeze previously thawed raw foods if at all possible. Following these safe handling practices and using good hygiene is the best defense in keeping both humans and pets in the household healthy and happy.
Preparing your own homemade, nutritionally complete, raw dog food can be expensive, inconvenient, and time consuming. Specially created by a nutritional scientist, Answers Pet Food developed one of the most nutritionally-dense lines of raw dog food. No calculations, guessing, preparing, or mess—Answers raw, fermented food is available in several sizes and forms. These formulas come in an environmentally-friendly, recyclable package. It’s a convenient, nutritious source of naturally raw food for pet owners to choose and feed with ease.
We are here to help support and share our knowledge with all pet owners and provide their pets with a safe, nutritious, high quality, 100% raw, whole food diet.
Judy Dethloff, guest blogger
Over the past year I have talked to many pet owners who do not regularly, or ever, clean their pets’ teeth. Oh, did I hit a nerve? Are you one of them? Let February 2018 be the beginning of this important element of your pet’s life.
Yes life. Just like humans, serious diseases and even death can occur from neglecting those pearly choppers. Death, are you kidding me? I’m not. Many years ago my vet told me a story about his own mother’s dog dying because she never took care of it’s teeth. Over time the dog’s gingivitis escalated, became septic and died. That is an extreme case, however, it’s not an isolated incident.
You’re in luck! I can help you get past the procrastination of starting this fun task. Yeah, make it fun! You’ll be surprised once you begin how happy and excited your pet will be when it’s teeth cleaning time. For those of you who already brush your pet’s teeth regularly….you rock.
In the past twelve months I have gone from three dogs to one. Nick is a 5 year old Norwegian Elkhound. When his sisters were alive, boy did we have fun at brush time. All three lined up, not as interested in the act of brushing, but more about getting to the yummy toothpaste.
When Nick sees the toothpaste tube he literally comes running. I have to clean him on the carpet or he slides all over the place. He sits between my legs and as I reach for his mouth, he tilts his head. I grab his lip and go all the way back to his molar and scrub. I do the canine mainly to humor him as I have been told the main objective is the back molars. Off to the other side, I finish with a squirt of toothpaste on my finger that he licks off thinking it’s a treat.
I only have two hands, all of which is handling Nick’s mouth, so I’m unable to guard the toothpaste tube away from the others and clean him at the same time. Several times Sam would chew the tube while the Black Labrador had her head under my arm waiting for me to finish with Nick. Long story to an easy task.
Regarding the toothbrush itself, none of my dogs did well with the brush on each end of the handle. Their heads spun around as if they were trying to follow the brush in order to get the goodies off the end. Instead, I switched to a brush that would fit on the end of my finger which allowed me to have better control.
My dogs were 17 ½ , 13, and Nick who is 15 years old. None of them ever had a dental visit in their life nor did they need one. Over the years, I’ve been fortunate enough to know Jacqueline Hill, Vice President of Operations and Product Development for Answers Pet Food. Jacqueline educated me, providing excellent guidance on pet nutrition and care, along with my own veterinarians’.
OK kids! Off to fun, happy, and healthy brushing. Please don’t get discouraged if it doesn’t go like clock work at first. Honestly, I don’t think it will take long before your pet enjoys it. It didn’t take long for mine, and they were adopted adult rescues. Oh, I forgot, be prepared for the occasional spit flying!