August 7, 2014 Ms. Star Johnson, Consumer

August 7, 2014
Directors
Christine A. Dorchak, Esq.
President
Eric Jackson
Vice President
Greyhound Companions
of New Mexico
Sherry Mangold
Treasurer
Animal Protection of
New Mexico
Kathy Pelton
Secretary
Tom Grey
Stop Predatory Gambling
James Flanagan
Charmaine Settle
Galgo Rescue International
Network
Jeroen van Kernebeek
Directors Emeritus
Dr. Jill Hopfenbeck, DVM
Kevin Neuman
Kansas City REtired
Greyhounds as Pets
Ms. Star Johnson, Consumer Complaint Coordinator
U.S. Food and Drug Administration
Kansas City District
8050 Marshall Drive, Suite 205
Lenexa, KS 66214
RE: Complaint no. 135052
Jason Haynes/Victory Greyhound/4-D meat
Ladies and Gentlemen,
Since my original October 29, 2013 letter requesting an investigation of the
interstate transport of 4-D meat by Jason Haynes and Victory Greyhound Feed, new and
additional proof of Mr. Haynes’ activities has come to light. We officially request that
your office further investigate this situation.
Yesterday, Jeffrey Cassady of the Daytona Beach News-Journal of Florida
reported on the deaths of two greyhounds and the sickening of ninety-seven others in a
suspected “food poisoning” case at the local track. Mr. Haynes’ company, Victory
Greyhound is specifically identified as the source of the meat fed to these greyhounds.
The story states:
“Victory Greyhound, a feed company in LaMotte, Iowa, supplied the
meat to Seminole Animal Supply, records show ... Victory Greyhound’s
feed consists of muscle meat from beef carcasses deemed unfit for human
consumption, but Jason Haynes, the company’s owner, said the meat is
safe for greyhounds as long as it is handled properly.”
Mr. Haynes is specifically quoted at the very end of the piece as well:
Michael Trombley, CPA
_________________________
“If (caretakers) handle the product the way they’d handle meat for their
family, they’d be pretty safe.”
Carey M. Theil
Executive Director
_________________________
Organization Listing is for
Identification Purposes Only
This story and the statement by Mr. Haynes clearly establish that Victory
Greyhound/Haynes is offering and selling an adulterated product to the greyhound
industry in interstate commerce.
P.O. Box F | Arlington, MA 02476 | (p) 781.488.3526 | (f) 781.488.3529
GREY2KUSA.org | info@GREY2KUSA.org
Also since writing to you in 2013, we have obtained further confirmation that Mr. Haynes is indeed
involved in the interstate transport of 4-D meat.

Attached to this letter are two 2012 comments from a forum used by the greyhound racing industry
which reference Mr. Haynes by name as the source for adulterated meat provided to racing kennels
at Ebro and Pensacola Greyhound Parks in Florida.

Additionally, Dr. Sam R. Lamb of the Florida Bureau of Animal Control wrote in a July 2014
report surrounding the deaths of racing dogs at Daytona Beach Kennel Club that frozen meat was
provided to the dogs from suppliers in Michigan and Iowa.

Finally, though dated to 2003, a letter to the FDA from Gary Guccione, executive director of
industry group National Greyhound Association (NGA), confirms that 4-D meat is the preferred
food by greyhound kennels and farms across the country. This is notable because Mr. Haynes was
a longtime industry licensee, former vice president of the NGA and it is reasonable to believe he
would have knowledge of the market for 4-D meat outside of his home state. This letter and Dr.
Lamb’s report are both included with this letter.
Background
Mr. Haynes was a kennel operator and longtime member of the greyhound racing industry. He was
once the president of the Iowa Greyhound Association and also served as Vice President of the National
Greyhound Association (NGA). An Associated Press story of August 1, 2005 reported that Mr. Haynes first
ran into trouble after his name arose as part of a criminal investigation in Wisconsin involving a conspiracy
to sell contaminated meat. A recall of millions of dollars of animal feed products ensued and the Iowa Racing
Commission declined to renew Mr. Haynes’ license thereafter.i
In February 2010, Mr. Haynes and his company were mentioned as the purveyors of 4-D meat to Tucson
Greyhound Park of Arizona in a report prepared by Pima County Investigator Debra Tenkate. Mr. Haynes confirmed to
a local official that he sells the meat of “animals condemned from plants and none (sic) productive animals from farms”
to TGP and had been doing so for “one year.”ii
A news story of September 22, 2011 in the Tucson Weekly described the controversy over the sale of
Mr. Hayne’s meat as follows:
“(Track general manager) Mr. Taylor said it is 4D grade meat not for human consumption," Tenkate
writes in the report. "Mr. Taylor also said the meat can consist of beef, deer, elk, cattle and that the
animals may have been sick, dead (died in truck) or road kill."
Tenkate followed up with a call to the track's supplier, Victory Meat in La Motte, Iowa. She spoke with
Victory owner Jason Haynes, who explained that his product is composed of "animals that are
condemned from plants and none (sic) productive animals from farms."iii
Investigation Requested
We are concerned about the feeding of 4-D meat to greyhounds because it exposes them to pathogenic
microrganisms, including Salmonella, Campylobacter jejuni, and Escherichia coli.iv In the industry
handbook, Care of the Racing and Retired Greyhound, the American Greyhound Council explains that such
meat is commonly used because “it is the most economically feasible for the Greyhound industry at this time.”
We believe and again assert that Mr. Haynes and his company/ies are conducting business in violation
of 21 USC §644 (Regulation of transactions, transportation, or importation of 4-D animals to prevent use as
human food). We again request that action be taken under Compliance Policy Guide § 690.500 (Uncooked
Meat for Animal Food).
Section 690.500 reads:
“CVM is aware of the sale of dead, dying, disabled, or diseased (4-D) animals
to salvagers for use as animal food. Meat from these carcasses is boned and the
meat is packaged or frozen without heat processing. The raw, frozen meat is s
shipped for use by several industries, including pet food manufacturers, zoos,
greyhound kennels, and mink ranches. This meat may present a potential
health hazard to the animals that consume it and the people who handle it.”
(emphasis added)
The Section explicitly affirms that uncooked meat from 4-D animals is considered “adulterated” under the
Food, Drug and Cosmetic Act, and “its shipment in interstate commerce for animal use is subject to
appropriate regulatory action.”
Thank you for your attention to this matter. I may be reached at the address and phone number below
or by e-mail at christine@grey2kusa.org.
Sincerely,
Christine A. Dorchak, Esq.
President
cc with enclosures:
Florida Department of Agriculture and Consumer Services
Florida Department of Business and Professional Regulation, Division of Pari-Mutuel Wagering
Iowa Racing and Gaming Commission
Iowa Department of Agriculture and Land Stewardship
i
ii
iii
Associated Press, Nationally known greyhound breeder acknowledges illegal deal, August 1, 2005 available at
http://tinyurl.com/n32cr85.
The full Pima County investigative report is included here.
Tim Vanderpool, Selective Enforcement, Animal Advocates say Tucson Greyhound Park is still dodging the law, Tucson
Weekly, September 22, 2011 available at http://tinyurl.com/lm7t6n4.
iv
Linda L. Blythe, James R. Gannon, A. Morrie Craig and Desmond P. Fegan, Care of the Racing and Retired Greyhound,
American Greyhound Council, (2007), 151.
2 d o gs d ie, 97 sick ened at Dayto na B each
gre yho u nd tra ck
By Jeffrey Cassady
jeffrey.cassady@new s-jrnl.com
Published: Thursday, August 7, 2014 at 5:30 a.m.
DAYTONA BEACH — Two greyhounds died and
97 others fell ill at the Daytona Beach Kennel
Club & Poker Room this spring in what state
officials suspect was a case of food poisoning,
according to recently released documents.
On April 6, kennel staffers found a greyhound,
Cherokee Rock, dead at the bottom of its crate,
lying in a large pool of blood, state records show.
New s-Journal file/JI M TI LLER
Grey hounds race at the Day tona Beach
Kennel Club & Poker Room in Day tona
Beach.
A second greyhound, Long Shadow, was found
in a pool of blood as well, but the dog was still
alive, records indicate. Long Shadow was sent to the track’s veterinarian who tried to
treat the dog. However, treatment was unsuccessful, and the dog was euthanized,
according to the records.
State reports show that 97 other dogs in the same kennel exhibited either vomiting
or diarrhea or both.
The dogs began showing symptoms after they were fed a mixture of raw beef — First
Choice 100% Ground Beef and Lucky Dog 100% Frozen Beef — and dry dog food,
according to records.
State officials have puzzled over what caused the illness, with some in the Florida
Department of Agriculture suspecting food poisoning. They’re also not sure if the
problem was with the food itself or its handling.
The Florida Department of Business and Professional Regulation Division of PariMutuel Wagering, which regulates commercial greyhound racing, is still looking into
the issue.
The incident occurred just weeks after a News-Journal report showed that the
kennel club led the state in greyhound deaths with 15 from May 2013 to February of
this year.
Roughly 900 greyhounds are based at the kennel club, said Todd Byers, a kennel
operator and president of the Daytona Beach Greyhound Association.
The club consists of nine kennels, all of which are independently operated.
The state takes the lead in investigating deaths and illnesses.
“We don’t get involved in the investigation,” said Dan Francati, the Daytona Beach
Kennel Club & Poker Room’s general manager.
“Typically, these things are turned over to the state, and they investigate because
they have testing labs for the food.”
A necropsy performed on the euthanized dog failed to indicate a specific cause of
death.
Both dogs that died were found in a pool of blood from their rectums.
The agriculture department received four samples of the meat-and-kibble mixture
for testing, but was unable to analyze them.
“We did obtain samples of the feed but were unable to proceed with testing due to
the timing and condition of the samples received, which were not suitable for testing
purposes,” said Erin Gillespie, press secretary for the department of agriculture. “We
were not able to make any final determinations on the feed because of the time
elapse and chain of custody, as well as the lack of labeling.”
Miguel Valenzuela, who operated the affected kennel at the time of the incident, has
since moved out of the country, Byers said. Valenzuela couldn’t be reached for
comment.
Seminole Animal Supply in Altamonte Springs supplied the meat to the affected
kennel and others at the kennel club, said Mark Nichols, who manages the store.
Seminole Animal Supply also sells raw meat to other tracks throughout Florida and to
walk-in customers, Nichols added.
State records show that no other kennels reported problems. Nichols said none of his
other customers have informed him of any similar illnesses.
Victory Greyhound, a feed company in La Motte, Iowa, supplied the meat to
Seminole Animal Supply, records show.
The Florida Department of Agriculture generally looks into these types of cases to
determine if others who bought from the same lot of meat should be concerned.
“Handling procedures utilized in the preparation of the food provided to the affected
greyhounds would significantly increase the risk for rapid development of pathogenic
microorganisms that may not have otherwise been present in the individual products
in their original state,” said Shaness Thomas, the agriculture department’s
environmental manager for its Feed and Seed Compliant Section, in a June 10 memo
to Brian Wall, an investigator with the Florida Department of Business and
Professional Regulation.
The agriculture department is no longer looking into the issue because no other cases
of illness have been reported.
Carey Theil, executive director of Grey 2K USA, an organization that is working to
abolish commercial greyhound racing, said he would like to see the racing industry
re-evaluate how it feeds its dogs.
“We will never know definitely what the exact cause of death in this case was,” Theil
said. “We do know for a fact that the industry uses a cheap meat product from
downed animals as a way to reduce costs ... Whether or not that was the case here, I
think it is a bad idea for the industry to use (such) meat.”
Victory Greyhound’s feed consists of muscle meat from beef carcasses deemed unfit
for human consumption, but Jason Haynes, the company’s owner, said the meat is
safe for greyhounds as long as it’s handled properly.
“If (caretakers) handle the product the way they’d handle meat for their family,
they’d be pretty safe,” he said.
Copyright © 2014 News-JournalOnline.com — All rights reserved. Restricted use only.
Dockets Management Branch (HFA 305)
Food and Drug Administration
5600 Fishers Lane, Rm. 106 1
Rockville, MD 20852
Re: Docket No. 02D-0468
To Whom It May Concern:
On behalf of the more than 3,000 Greyhound owners and breeders in North America that
register their Greyhounds through our organization (the National Greyhound
Association), we wish to comment in regard to the recently released “Guidance for
Industry” document entitled: “MANUFACTURE AND LABELING OF RAW MEAT
FOODS FOR COMPANION AND CAPTIVE NONCOMPANION CARNIVORES
AND OMNIVORES.”
First, by way of background, the NGA was founded in 1906 and is the oldest Greyhoundrelated organization still in existence in this hemisphere. We are located in Abilene, KS.,
and are the official registry for racing Greyhounds in North America. Our membership is
comprised of the owners and breeders of racing Greyhounds on the continent.
The so-called 4D meat used by Greyhound owners at farms and in racing kennels has
been a tried and proven practice for many decades now. (We note that “dog racing
facilities” were mentioned-along with zoos and mink farms and “other professional
establishments”-as a market for such products in the report.) We are pleased to report
that the use of this meat has more than adequately served the purposes of Greyhound
owners across the country for many years. We offer some statistical information that
substantiates the industry’s confidence in the use of this meat.
There are approximately 33,000 Greyhound pups born each year in North America
(verified by NGA registry records). Average value of a young, Greyhound pup growing
up on the farm is approximately $2,750; it will cost just under that figure to raise the pup
from whelping to track-age (appoximately 18 months of age). The average value of a
Greyhound in a racing kennel at the 48 racetracks nationwide is approximately $6,000.
Our semi-annual auctions in Abilene sell young track-ready pups at an average price of
just over $6,000. Last fall, a promising young pup actually sold at auction for $55,000.
It is significant that owners feed these very valuable Greyhounds--even those that are
stake champions or that sell for substantial five-figure prices-the very same 4D meat as
is fed to the entire farm or the entire racing kennel. This underscores the confidence
owners have in this product, as a result of their experiences with it over the years. The
NGA is unaware of any professional Greyhound kennels or farms that use any other
classification of meat as a major part of their Greyhound feeding programs.
Owners, breeders and trainers know how to safely feed and handle the meat fed to their
Greyhounds. If there were significant problems or complaints regarding the meat, the
NGA-as the only national organization representing the owners and breeders---would
certainly be hearing about it.
Such complaints have been extremely rare in recent years. Fifteen or twenty years ago,
we’d hear an occasional complaint about a temporary sickness that passed through the
pups in a kennel or on a farm, assumedly caused by the meat. I must say, however, that
such complaints or problems have been drastically reduced in more recent years-in fact,
the complaints are practically non-existent these days. This leads us to believe that the
quality of the meat provided by the manufacturers to Greyhound kennels and farms has
actually improved in quality in the last five to ten years.
Because of these facts and observations, we respectfully request that the draft guidances
of the FDA clearly permit the continued use of this meat by Greyhound owners and other
professional industries.
Thank you for your consideration; ifat any time you have any questions or seek further
information, please contact me.
Sinceply,
,, -
Exec. Director ’