Pet Food Regulations

Bamboozled and Lead Day 2 at AAFCO July 2014

Day 2 at the AAFCO July 2014 meeting was a roller coaster ride. Up the hill to reach a point to be able to meet with FDA (and have them actually listen to us), and then crashing down into a black hole when industry and AAFCO duped me and then approved an ingredient for pet and animal consumption allowed to contain 90 parts per million lead. Top this off with an industry representative verbally insulting us. It wasn’t a fun day.

I feel I owe all of you an apology. I let you down on Day 2. I allowed myself to be duped by industry (specifically the Pet Food Institute). I assure you – they will never do this to me/us again. Lesson learned.

What happened. I have volunteered for a sub-committee of the Ingredient Definitions Committee (it is known as a ‘working group’) for several years that has been working on legal definitions for meat meal ingredients. This sub-committee got started because there was no (and still is no) legal definition for lamb meal, rabbit meal, and venison meal. Problem #1 – do you realize how many pet foods out there contain a lamb meal or venison meal? All those pet foods actually contain an ingredient without an official legal definition.

So in this ingredient definition working group – my side of the discussion when we met via conference call over the years was the definitions of these meat meal ingredients never clearly defined to the consumer what was in that ingredient. Example: meat and bone meal. My perspective representing consumers was the definition did not include what species of animals were in that meat meal; consumers deserve to know what they are feeding their pet. So these discussions went on intermittently for several years and then suddenly stopped about a year ago. At the January 2014 AAFCO meeting it was decided our working group would meet again via conference call before this July meeting – but that never happened. Quoting from the Minutes of the January meeting: “Meat Meal Work Group Report – Meagan Davis. They are working and will report again in August.”

But much to my surprise for this meeting, I see on the agenda the item to approve tentative definitions for these ingredients. Huh? When I asked about this prior to this meeting, I was told this was procedure just to save time on the meeting agenda so that we can discuss this again and get the working group to meet again. That is not what happened. Tentative ingredient definitions that were never agreed on (I actually don’t know where they got these definitions from – thin air perhaps?) were discussed – do we want them to become official? As I’ve said for years on this particular topic – I said no. Our working group never completed our discussion for these definitions. And I publicly said – on the record – that ‘our working group never completed this – we are still working on these definitions’. So AAFCO members agreed to delete these definitions.

But – here is when they duped me – towards the end of this meeting, the chair of this committee made the suggestion ‘Do we want to disband the meat meal working group?’ What? No! And I told them no – how could they disband this group when we just deleted tentative ingredient definitions based on us meeting again? Then our friends at PFI – this time it was Jill Franks of Mars Petcare wearing her PFI hat – convinced the AAFCO committee that we might as well disband this meat meal working group because we haven’t met and no AAFCO person was willing to lead the group. Even the Canadian regulatory authority went to the microphone and told AAFCO this was wrong to disband the group – that the ingredient definitions which were deleted earlier in the meeting were deleted based on this group meeting again! But nope…discussion was over. They duped me and AAFCO assisted. The Canadian authority told me later in the evening I was “bamboozled”. We all were.

I really felt bad about this – that I allowed them to dupe me/bamboozle me – bamboozle us. I trusted their word – it won’t happen again.


The next just unbelievable issue that occurred today was the AAFCO approval of this ingredient (bold added):

Zinc hydroxychloride is the hydrolysis product of zinc chloride having the empirical formula Zn 5 (OH) 8 Cl 2 (HO). The particle size must not exceed 100 microns. It must contain not less than 54% zinc and is intended to be a source of zinc for use in livestock and companionanimal diets. It must not contain more than 20% chloride, 90 ppm lead, 15 ppm chromium, 10 ppm arsenic, 10 ppm cadmium, and 0.2 ppm mercury.

My trusted expert on ingredients told me “that source of zinc because it has been used in Florida for years as a coating for roof tiles to prevent algae infested roofs.” And there are “problems associated with Zinc hydroxychloride when exposed to high temperatures such as extrusion and pelleting”. And “The negative affect of this source of zinc on the colostrum of dogs and cats cannot be ignored. The negative effects of the heavy metals in this product must be addressed by scientists and not AAFCO officials not trained in heavy metal toxicology.”

I told the committee this ingredient was “heavy metal soup” and should not be approved. Three – yes, three veterinarians stood up and told the AAFCO committee to not approve this ingredient – it was a huge risk to animals. AAFCO ignored everything. They approved the ingredient. So make a big addition to your pet food ingredient radar – Zinc hydroxychloride – big red flag!

The industry pushing this ingredient was AFIA (Animal Feed Industry Association – ‘feed’ not ‘food’). In fact, one of their representatives – a Mr. Jon Nelson – was adamant that I agree with his position this heavy metal soup ingredient was safe. When I wouldn’t agree with him – he stomped away trying to sway the opinion of Dr. Cathy Alinovi and Dr. Oscar Chavez – two of the veterinarians that spoke out against this ingredient (the other was Dr. Jean Hofve). He insulted me to them (not knowing they knew me) and when I walked up he got in my face – you know, one of those fun conversations where someone with incredibly bad breath is two inches from your face – and demanded to know my nutritional education background. The conversation went something like this…

Mr. Bad Breath two inches from my face: WHAT IS YOUR NUTRITIONAL EDUCATION?

Me: My education on this ingredient was…

Mr. Bad Breath two inches from my face: WHAT IS YOUR NUTRITIONAL EDUCATION?

Me: My education on this ingredient was provided by…

Mr. Bad Breath two inches from my face: WHAT IS YOUR NUTRITIONAL EDUCATION?

Me: My education on this ingredient was provided by a scientist I…

Mr. Bad Breath two inches from my face: WHAT IS YOUR NUTRITIONAL EDUCATION?

Me: My education on this ingredient was provided by a scientist I trust.

At that point I walked away. But Mr. Bad Breath didn’t. He stayed and proceeded to argue with Dr. Alinovi, Dr. Chavez and Roxanne Stone – telling both women “they must be vegetarians because their hair is dull”. What a fun guy!

Makes you wish you were here doesn’t it? Ugh. Today is the last day – thank heavens. Such evil and reckless concern of animals is challenging to deal with.


Wishing you and your pet(s) the best,

Susan Thixton
Pet Food Safety Advocate
Author Buyer Beware, Co-Author Dinner PAWsible
Association for Truth in Pet Food

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July 27, 2014

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30 COMMENTS ON THIS POST To “Bamboozled and Lead Day 2 at AAFCO July 2014”

  1. And people wonder why so many of us make our own dog foods.

    My last Airedale lived beyond 15 years, eating raw meats and bones her whole life. And yes, the foods are human grade meats and the bones come from the same sources. I have have that dog’s granddaughter who is only eight years old and healthy as healthy can be. For years we have taken our dogs to the vet once a year for a check up and the vet, who is not an advocate of feeding a raw diet, the vet keeps telling us to keep doing whatever we are doing because our dogs are so healthy.

    The only healthy pet foods I recommend are human grade raw meats. And though humans don’t eat bones, our dogs do and their bones come from the same sources. All from human grade meat sources.

    Is our food AAFCO approved? NO! I wouldn’t feed a dog any commercial dog food no matter how good the company is.

    Dr. Joyce Miller

    • Jo Gunter says:

      Dr. Miller,
      Are you a veterinarian by chance?

      And are you saying you feed raw meat and bones but nothing else…such as vitamins or minerals or other supplements to help properly balance the diet?

      Not attacking at all! I am just very interested to know how a simple meat and bone diet results in no serious deficiencies like we have always been made to believe by those against feeding anything but commercial pet food. It would be wonderful and so simple to feed a similar diet to my cats!

      After reading articles such as this, I am quickly growing to HATE the entire pet food, I mean FEED, industry. Most of those involved could care less about the health and well being of the animals for whom they are in business and employed.

      We need to arrange massive consumer protests outside the headquarters of big pet food, AAFCO, PFI and even our nation’s Capitol.

      More importantly…and I keep saying this but it bears repeating…we MUST get national media involved! They are the single most powerful group that can shed huge light on what is actually happening in the pet food industry and educate the public on the disgusting, inexcusable ingredients pets are being forced to eat. How about some good ole investigative reporting?!

      The national media holds THE power to bring this issue to the forefront of the American consumer. Susan is beyond awesome in every way–GOD BLESS HER COMMITMENT AND TIRELESS EFFORTS TOWARD THE CAUSE–but she will be fighting this uphill, no-win battle till the day she dies…and big pet food, the FDA, AAFCO, PFI, et al KNOW it and, thus, they sit back on their asses and do nothing but collect more of our hard-earned money in the form of profit or taxpayer-supported salaries while ignoring the health and LIVES of our beloved family members.

      I am FED UP with all of them. And Mr. Nelson? You–with your unimpressive bullying tactics and embarrassing bad breath–can go to HELL!!!

  2. Cathy says:

    Why not start petitions. When these government agency’s realize we are contacting our senators and representatives and the public is tired of no representation, then perhaps they’ll cease ignoring us.
    This works to great effect for Greenpeace and others.

  3. Let’s not forget the existing mustard meal definition that remains on the books even after discussion. Brassica spp. is a known toxin to ruminants and can cause reproductive problems and thyroid problems. Yet the “argument” for keeping the existing (undefined Brassica species type) definition was because “significant industry projects were in the pipeline.” Shouldn’t that be a reason to stop any further use right now!? No – industry trumps consumer and animal protection any day.

    In fact a comment was made by a government representative that they get accused of “being in bed with the consumer” by industry. She said this as though it was a comment she resents. Hold on – why wouldn’t the government be closely tied to the consumers that it protects? Is that not the role of the FDA/USDA – protect the public, ie: consumers? Why would you say you resent being told “you’re in bed” with your constituents.

    I’m very confused. I feel like it’s all very clear to me, but they have a completely different world. Almost makes you start wondering – am I wrong? Then of course, we’ll go home and be proud of what we do, sleep well, and not worry about putting lead and arsenic in the food we make. And that’s when I’ll say – no…. I’m not wrong.

    Thank you Susan for a very enlightening experience. Our table may have been half full this time, but give us a few more meetings, and we’ll need a few tables! 🙂

  4. Les says:

    Stay strong. What a jerk. Maybe you carry some mints if you meet up again. Was his breath similar to a dog who’s been eating brown pellets for years? LOL

  5. Mary Sue says:

    If I found the correct Jon Nelson, he is Executive Vice President of Nutrition and Quality Assurance, Southeastern Minerals, Inc.
    – Southeastern Minerals, Inc. manufactures and markets agricultural chemicals and minerals. The company provides trace minerals premixes and ingredients and phosphate mineral products. Additionally, it offers amino acids, chlorine, chloride, yeast culture, and urea. The company has strategic alliances with Eastern Minerals, Inc., Marshall Minerals, Inc., and SEM Minerals, L.P. Southeastern Minerals was incorporated in 1961 and is based in Bainbridge, Georgia.

    • Susan Thixton says:

      You found the right Jon Nelson.

      • Now let’s find out which pet feed/food companies use his product and then call or write them letting them know we will no longer buy their products. Guess the problem with that is those of us on here aren’t likely to already be using any of those. What a jerk. Just goes to the lack of care these industry people have. Thank you Susan for being our watchdog! We know you are doing you’re best!

      • Amy Renz says:

        Susan, You are one of animals’ and pet parents’ biggest champions.

        Never let the Bad Breath Nelsons of the world get you down. He’s a bully to hide his weaknesses; his questions are always traps. You’ve gotta hit him and his ilk between the eyes. Answer his question with your own:

        Him: “what’s your education?”
        You: “What’s your motivation?”

        Or: You: “How much do you stand to make on approval of this toxic soup?”

        I think policy advocacy efforts may benefit from press (like was mentioned here) and the joining of pet parents in a class action against the FDA. Sue them for breaking the federal laws of the Food Drug and Cosmetic act.

    • Perhaps he could incorporate some of his company’s offerings into a personal dental health regimen.

    • Catherine says:

      The whole company’s political contributions are interesting… The principals and their family members all contribute to the same campaigns, even some out of state ones. I would sure look at how those politicians vote on agribusiness and fda items. No real use writing to them, may be in industry ‘s pocket.

  6. Ann Vanderlaan says:

    I have just converted one of my dogs to raw food. I do buy my raw meat from a processor that our local raw food coop uses. I hope that I’m doing the right thing, since finding beef with bones seems to be almost impossible in grocery stores. I converted my boy because of serious environmental allergies, MRSE, and a very sparse coat.

    When I read about the 90ppm PB, my first thought was recycled road kill.

  7. Peg says:

    Ah, Susan i am so sorry Mr. Badbreath made your eyes burn and your nose hurt.
    I can send you some breath freshening spray that my vet gives to her clients for their pets.

    One of the advantages to your posting from AAFCO is that I can then forward this information to friends, family, co workers, anyone I can get to listen and to Vets!! You can tell Mr. Badbreath that some of the vets I know have quit selling products because of your invaluable information.

    Also tell Mr. Badbreath that my birthday present from my husband was the very expensive “Nutritional Requirements for Cats and Dogs”. There are many ways we can educate ourselves outside the classroom.

    Obnoxious fool.

    Oh and Susan, you NEVER let us down.

  8. Lori S. says:

    I guess that if they can’t get what they want by using science and safety protocols, they get it with intimidation and lying. What an awful experience that must have been. Thank you for fighting the hard but good fight!

  9. Tracie says:

    Brilliantly handled, Susan.
    You are blowing this whole industry wide open and exposing all of their B.S. to the consumer, and we are eternally grateful.

  10. Dana says:

    I am crying for you reading about the definitions group debacle and the harmful ingredients approved.

    And that guy getting in your face? You’ve caught these people with their pants around their ankles. They’re going to trip over themselves unless they pull up their own pants. If they don’t, I hope I live long enough to see it.

    These experiences are exactly the same as I’ve run into advocating against ag gag laws and for enforcement of animal care standards in high-volume commercial dog breeding facilities.

    Breath normally and carry on.

    Best regards,


  11. Jan Beardsley-Blanco says:

    Susan, you will ALWAYS be my heroine……….you’ll get them – maybe not this time, maybe not the next, but you WILL win them over.
    keep on keeping on!

  12. Deborah Stone says:

    If they think all this stuff is so good for the animals, then why don’t they eat it and lets see their reaction to this stuff-
    Susan-thanks for all you do to try to protect our animals-We appreciate all you do.

  13. darlene says:

    exactly what i’d expect from a government administration climate that asked legislators & taxpayers to accept & enact a health care program but refused to make its contents known. remember ‘pass it then read it’????? once they got that past, they have no limits. that attitude has completely permeated ALL facets of the government, pet food ingredients included.

    the heavy metal content in pet food minerals does not surprise me either as i have seen & read indications that many human grade minerals & supplements are being found to contain heavy metal concentrations. again, those containing the most questionable metals are grown/produced or sourced outside the USA, but ingredient source of origin may not be indicated on the label. sound familiar?

  14. Denise Moitoza says:

    You never let us down. After all – You represent the CONSUMERS! If anyone can send a message, it’s us. I choose to spend my money buying the ingredients to make my own dog food. And not one red cent on anything approved by them. Through the years I have found that is the fastest way to show or not show your support. After all that’s what they want. Our money. Choose to spend it wisely and really drive the message home.

  15. Tracey says:

    Thank you Susan for all your hard work! I know how frustrating this is for you but we are behind you and we will succeed in taking all of them down! Their bad behavior has worked in the past but thanks to you we are getting the word out. They are only trying to intimidate you because you are a real threat, otherwise they wouldn’t care! Take care of yourself and don’t let these guys get to you because we NEED you on the front lines for us. I’m eternally grateful.

  16. darlene says:

    CLARIFICATION: i do realize that AAFCO is not governmental. i meant to indicate that the attitude of control without question that seems to have permeated many facets of government is also being assumed by other organizations, including the pet food industry. and especially if money/profit is involved

  17. Diane says:

    Thank you for all the work you do, on behalf of all of us and our pets.

  18. Catherine says:

    Plus, I cannot find one iota about his education. When he was quoted in a research paper it was as a “personal conversation” because he has no academic initials after his name, nor publications to quote. He was bullying you as a way to protect his own lack of education. Being in industry does not make you an expert. Yet he has written letters to the editor about feed issues and is frequently at conferences on panels as if somehow his position gives him credentials. There are none that I can find.

  19. Kenneth Kalligher says:

    Susan, I am so sorry for your experience with the wizards of the pet food industry. Bluster is ignorance! That guy is a bully! I love going at it with people like that. At the same time I am not surprised and expected nothing less. When I think I spend too much time preparing food for my dogs and cat it is episodes like this that renew my willingness, passion and desire to continue to prepare my own food. You know, having operated manufacturing facilities for large companies and later in life my own facility. I know it is very easy to do things the right way, but when billions of dollars are at stake, and these are public corporations, it is the cheapest way that counts. The food industry has been responsible for the deaths of tens of thousands of americans by getting them hooked on processed and dangerous foods. Can we really expect the pet food industry to do any better? Without the indomitable spirit and self-educated activists like yourself the pet food industry may be even worse that it is. Puts me in mind of the words of Mark Twain, “It is easier to fool people than to convince them they have been fooled.” Those snazzy ads they spend billions on are designed to do just that! And, unfortunately, it seems to work. Just stop at Petco or any large dog food vendor: Wal-Mart, feed stores or wherever; and watch what people buy. Don’t you just wish there were enough people to create a co-op to manufacture really great products for our pets? I think about it often. The merging and buyout fever among multi-national manufacturing conglomerates is restricting choices and given the political bent on allowing our country to be bought out by monied companies it doesn’t look good for improvement.

  20. Helen Savadge says:

    Bless you Susan for your heroism! People who do NOT have truth to back up their position become Very Defensive. (And probably affects their breath as well.) THANK YOU for being on the Front Line for ALL of us to protect the innocent animals we love.

  21. cherie says:

    Thank you so much Susan for all your hard work!!!!! You are amazing!!

  22. Terry says:

    Susan, Very simply, thank you. You are so brave in your advocacy for pets – and you truly walk the walk. Your efforts are appreciated!

  23. Amanda says:

    “First they ignore you, then they laugh at you, then they fight you, then you win.” – Mahatma Gandhi

    Thank you for all you do. You are voice for countless animals and people who depend on transparency and integrity in the industry. You didn’t fail us, the system has. A system you and others are trying so desperately to rectify. You practiced far more self-restraint than I could have, and for that I applaud you.

    I encourage you not to look at this as a failure on your part. It truly is not. I think you have the right idea in seeing this as a clearer image of exactly what caliber of ruthlessness these people resort to in order to get their way. It’s despicable, childish, and unproductive.

    As for Mr. Nelson… I pity his lifestyle if he feels he needs to use name-calling, deflection and borderline physical harassment to get his point across. I sure hope he is not married, and doesn’t have any children and/or animals living in close proximity.

  24. Ellie says:

    It seems the pet food industry has been allowed to become a disposal source for rubbish. Where else can a company use garbage to produce a product? Add a few manufactured “vitamins” and you can sell your product to the unsuspecting public and make a huge profit.
    These people are not easily going to let go of this very profitable business. This has nothing to do with the health and well being of pets.. It is about money and lots of it going into the pockets of greedy business owners.
    I admire Susan’s dedication to the cause. It takes a lot of dedication to continue dealing with the sort of people involved in this industry.

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Susan Thixton's author is a founding partner of the international pet food consumer association - Association for Truth in Pet Food. Through our consumer association, Susan has advisory position to AAFCO's Pet Food Committee and Ingredient Definitions Committee.