Last winter, the headline virus was H5N1 “bird flu.” This year, the virus has mutated – as influenza reliably does every year. The current concern in wild birds appears to be H5N5. H5N5 has been detected off and on since the 2010s, and so far it seems less lethal to commercial poultry than last year’s H5N1 strain, but that does not make it irrelevant to our industry.
Recently, a person in Washington State with a personal outdoor flock and multiple serious underlying illnesses became infected with H5N5 and unfortunately died. This case highlights a basic point about influenza: for most healthy individuals, flu viruses alone are usually manageable, but in people with significant comorbidities, flu can be dangerous or even fatal.
Washington State is an interesting focal point for these issues. It sits beneath a major wild bird migration route, which likely increases the chance of detecting avian influenza there. It is also the same state where a high-profile raw pet food allegation around Christmas 2024 was later shown to be false and the manufacturer vindicated. State regulators there appear particularly aggressive on avian influenza and raw pet food. (Apparently, these are not mutually exclusive in the state of Washington.)
In their communication about H5N5, Washington State authorities are appropriately telling the public that wild birds are the primary source of exposure risk. However, they also feel compelled to add “do not feed raw poultry meat to pets.” That kind of language has become almost automatic in some US messaging, especially in Washington State, and it reflects a broader bias toward raw pet food rather than data specific to this strain.
At the same time, some experts now insist H5N5 will not cause a human pandemic because it does not spread efficiently between people. Others go even further and claim H5 viruses in general do not spread between humans. That raises an obvious question: if H5 viruses don’t spread well between people, why was there such intense drama around H5N1 last year? Fear can be useful for justifying budgets and workloads.
International reporting often does not even mention transmission to pets or other companion animals. US messaging does, which suggests that the US – not the virus itself – may have a particular problem with how it frames flu in the context of animals and raw diets.
So what does all of this mean for pet food manufacturers?
The FDA’s recent admonitions were written specifically around H5N1. Even so, this is an excellent time to review your food safety plans and consider how you address avian influenza in general, particularly H5-class viruses, before new requirements are imposed from above.
For manufacturers of raw pet food products:
– Engage your poultry suppliers to understand what surveillance or assurances they can provide regarding avian influenza status in their flocks (for example, programmatic testing, official certifications, or attestations).
– Where you can substantiate it, consider publishing clear, factual information about your sourcing controls and avian influenza considerations on your website so customers and regulators can see you have active measures to address this hazard.
For manufacturers using cooking or HPP:
– Thermal processing and properly validated HPP inactivate influenza viruses.
– Ensure that your hazard analysis and preventive controls explicitly address avian influenza, and that your validations, critical limits, and monitoring records are organized and easy to present if asked.
Regardless of format, every manufacturer should:
– Revisit the biological hazard section of the food safety plan to confirm that avian influenza is appropriately considered based on your ingredients, suppliers, and processes.
– Document your rationale clearly, including why your preventive controls (e.g., sourcing requirements, kill steps, environmental monitoring) are adequate for this class of viruses.
– Stay alert to state-level messaging (like Washington’s) and be prepared to explain how your existing controls manage the risks they highlight.
The virus will keep mutating; that is what flu does. Regulators will keep reacting; that is what regulators do. Your job is to stay ahead of the curve with a defensible, well-documented food safety plan that already accounts for avian influenza, rather than scrambling after the next press release (which tends to come out on a Friday or just before a holiday weekend).
References:
https://pubmed.ncbi.nlm.nih.gov/41158675/
https://www.woah.org/en/disease/avian-influenza/
https://www.sciencedirect.com/science/article/pii/S1477893923000984
