Equine Euthanasia and Disposal Challenges Dr. Katie Flynn Equine Staff Veterinarian Animal Health Branch CA Department of Food and Agriculture

Extent of the Issue 7.2 million horses in U.S.** 1.4% mortality rate* = 100,800/yr. *2015 NAHMS Equine Study, USDA ** 2017 AHC Equine Economic Survey

Equine Euthanasia Options Chemical Injection with Pentobarbital Chemical Injection alternatives Potassium Chloride Magnesium Sulfate* Intrathecal Lidocaine in combination with Ketamine and Midazolam* Gunshot Captive Bolt *Euthanasia methods not currently approved by AVMA Guidelines for Euthanasia of Animals (2013 Edition)

Equine Disposal Methods Rendering Burial Landfill Cremation/Incineration Composting Tissue Digestion U.S. Equine Slaughter Plants* *No longer available since 2007

Current Rendering Issue: Use of Barbiturate FDA has zero tolerance for barbiturate residues in rendered products Currently, most horses euthanized using sodium pentobarbital Any detection of pentobarbital residues in rendered product is adulterated Responsibility of renderers to ensure their products are not adulterated

FDA Investigation into the Issue https://www.fda.gov/AboutFDA/CentersOffices/OfficeofFoods/CVM/CVMFOIAElectronicReadingRoom/ucm129131.htm Two Part investigation Determine if dog food could contain residues of phenobarbital Determine what risk, if any the residues posed to dogs. Dog Food Phenobarbital findings Detected in dog foods ( 2 surveys in 1998 and 2000) 0-32ppb measured level detected Pentobarbital survives rendering process. CVM detection method down to 2 parts per billion of phenobarbital in dry food Dog Phenobarbital Exposure Findings Dogs were given 50, 150, 500 micrograms/day of phenobarbital for 8 weeks.

FDA Investigation Results (1998/2000) For the purposes of CVM’s assessment the scientists assumed that at most, dogs would be exposed to no more than 4 micrograms/kilogram body weight/day based on the highest level of pentobarbital found in the survey of dog foods. In reality, dogs are not likely to consume that much. The high number was based on the assumption that the smallest dogs would eat dog food containing the greatest amount of pentobarbital detected in the survey of commercial pet foods-- 32 parts per billion. However, to get to the exposure level of 50 micrograms of pentobarbital per day, which is the highest level at which no biological response was seen, a dog would have to consume between 5 to 10 micrograms of pentobarbital per kilogram of body weight. But the most any dog would consume, based on the survey results, was 4 micrograms pentobarbital per kilogram of body weight per day. The results of the assessment led CVM to conclude that it is highly unlikely a dog consuming dry dog food will experience any adverse effects from exposures to the low levels of pentobarbital found in CVM’s dog food surveys

Recent Recalls due to Pentobarbital in Pet Foods 2/16/18: FDA Alerts Pet Owners About Potential Pentobarbital Contamination in Canned Dog Food Manufactured by The J.M. Smucker Company, Including Certain Gravy Train, Kibbles ‘N Bits, Ol’ Roy, and Skippy Products The FDA’s preliminary evaluation of the testing results of Gravy Train samples indicates that the low level of pentobarbital present in the withdrawn products is unlikely to pose a health risk to pets. However, pentobarbital should never be present in pet food and products containing any amount of pentobarbital are considered to be adulterated. Any detection of pentobarbital in pet food is a violation of the Federal Food, Drug, and Cosmetic Act—simply put, pentobarbital should not be in pet food . 4/24/17: Party Animal Recalls Dog Food Due To Potential Presence of Pentobarbital 3/3/17: Evanger’s Pet Food and Against the Grain Voluntarily Recalls Additional Products Out of Abundance of Caution due to Potential Adulteration with Pentobarbital 2/14/17: Against The Grain Pet Food Voluntarily Recalls One Lot of Pulled Beef Due to Potential Adulteration with Pentobarbital 2/3/17: Evanger’s Voluntarily Recalls Hunk of Beef Because Of Pentobarbital Exposure in one Batch of Food

Moving Forward Availability of Rendering for Equine Disposal Communications with FDA regarding the zero-tolerance level of chemical residues Development of a methodology for practitioners to identify euthanasia mechanism Research alternatives for euthanasia Incorporation into AVMA Euthanasia Guidelines. Encourage industry and local regulatory officials to collaborate to address the local carcass waste management issue

CA Equine Euthanasia Working Group September 5, 2018 Representation: Academia Private Veterinarians Rendering Regulatory Veterinary Medicine CA Veterinary Medical Association MPES Branch, CDFA AHB Branch, CDFA Feeds and Fertilizer, Inspection Services

Working Group Action Items Communications with FDA regarding the zero-tolerance level of chemical residues Development of a methodology for practitioners to identify euthanasia mechanism Communicate with pharmaceutical companies to determine alternatives for euthanasia Presentation and discussion of issue at organizational meetings (i.e., CVMA, USAHA, AAEP)

USAHA Draft Resolution The United States Animal Health Association urges the Federal Drug Administration to develop a tolerance level for euthanasia and anesthetic agent residues in rendered products from equine carcasses. Furthermore, USAHA Committee on Equine urges the National Rendering Association in collaboration with equine industry stakeholders to develop a methodology for practitioners to identify carcasses euthanized with barbiturates and a declaration form for practitioners to complete for submission to rendering management acknowledging method of euthanasia.