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Pet Food Regulations

Concerning Change for Human Grade Pet Food

An industry representative has submitted a proposal to AAFCO hoping to change the definition to Human Grade pet food. If this passes, Human Grade pet food would change dramatically.

An industry representative has submitted a proposal to AAFCO hoping to change the definition to Human Grade pet food. If this passes, Human Grade pet food would change dramatically.

Dr. David Dzanis of Regulatory Discretion, Inc. submitted a proposal to AAFCO Pet Food Committee requesting changes in the definition of Human Grade pet food. The upcoming (January 22 – 24, 2018) AAFCO meeting agenda states the changes proposed are “minor edits”but they are far from minor. The proposed changes would dramatically change the quality of human grade pet food. Further, the proposed changes would make human grade pet food in violation of human food law.

To read the proposed changes, Click Here.

The challenge to the current definition of Human Grade pet food boils down to jurisdiction – or at least that is the pretense of argument presented (it is suspected there is far more than jurisdiction behind this issue). To understand just how serious this change could be…a brief understanding of food regulation and agency jurisdiction is required.

With human food…

The FDA is the governing regulatory body over Tomato Soup because it contains no meat. A human food that contains no meat is regulated on a ‘trust’ system where the manufacturer is trusted to abide by food laws. The manufacturing of the food is not inspected by regulatory; the plant itself might be inspected by FDA once in ten years.

The USDA is the governing regulatory body over Chicken Noodle Soup because it contains meat. Law requires the Chicken Noodle Soup to be manufactured with a USDA inspector on site, USDA is responsible for assuring the public all ingredients in the food are human edible and all safety standards are followed during manufacturing.

The concerning change submitted to AAFCO…

Currently, the legal definition (the legal requirements) of a Human Grade pet food requires the pet food to be manufactured by the same laws as a human food that contains meat – manufactured under USDA inspection, assuring pet owners all ingredients are human edible and all safety standards are followed during manufacturing.

The argument for the change – submitted by Dr. Dzanis – suggests that because pet food is regulated by FDA, the requirement of Human Grade pet food being “edible” should be removed. In the legal language of food regulations, the term “edible” is not utilized by FDA; FDA uses the legal language of “human food“. But…USDA legal language does use the term “edible“. USDA requires a food that contains more than 3% meat to be “edible” and manufactured under inspection. If the term “edible” is removed from the definition of Human Grade pet food, the link to USDA is removed, the requirement to be manufactured under inspection is removed. If the term “edible” is removed, consumers lose.

The change submitted would result in this…

The proposed change would result in Human Grade pet foods being regulated as a non-meat human food product. It would be based on the ‘trust’ system, trusting that the pet food manufacturer would abide by regulation, trusting the pet food would be manufactured with 100% edible ingredients. Human Grade pet foods would no longer be required to be manufactured under constant USDA inspection – Human Grade pet foods would no longer abide by human food law (same regulation as human food products that contain more than 3% meat).

The proposed “minor edits” to the definition of Human Grade pet food is a bad, bad proposal. Simply put, it lessens the quality of Human Grade pet food. If approved, the result for Human Grade pet food would be…

  • Instead of constant government inspection, the facility would be inspected by authorities once every ten years. No direct regulatory oversight of production.
  • Instead of government oversight, consumers would have to trust Human Grade manufacturers ARE using 100% edible ingredients.

Certainly, pet foods manufactured to human food non-meat requirements are far better than feed requirements (little to no quality assurances), but this is NOT feed grade pet food. This is food. Should this pass, we can anticipate many more Human Grade pet foods on the market that have not been manufactured under inspection providing consumers with no regulatory oversight to quality – further confusing pet food consumers. Remember, all of pet food legal definitions are private – corporately owned by AAFCO. Consumers will have no access to the definition of Human Grade pet food, most won’t understand that these products would be held to vastly different regulations than human food (with meat).

What can you do?

Tell the members of the AAFCO Pet Food Committee (those that will vote on this proposal) that you do not agree with the proposed changes. Tell them the term “edible” must remain in the definition, Human Grade pet food should be held to the same legal standards as human food with meat.

Voting Pet Food Committee members are:

Kristen Green, Chair, Kentucky Department of Agriculture – email: kristen.mary.green@uky.edu, phone: (859) 257-4496

Stan Cook, Vice Chair, Missouri Department of Agriculture – email: stan.cook@mda.mo.gov, phone: (573) 751-5501

Lizette Beckman, Washington State Deptartment of Agriculture – email: lbeckman@agr.wa.gov, phone: (360) 902-1942

Dr. William Burkholder, FDA/Office of Foods (OF)/Center for Veterinary Medicine (CVM) – email: william.burkholder@fda.hhs.gov, phone: (240) 402-5900

Kathleen Close, FDA-ORA – email: kathleen.close@fda.hhs.gov, phone: (515) 244-0480 ext 1003

Charlotte Conway, FDA – email: charlotte.conway@fda.hhs.gov, phone: (240) 402-6768

Laura Earhart, Virginia Department of Agriculture & Consumer Services – email: laura.earhart@vdacs.virginia.gov, phone: (804) 371-2667

James Embry, Office of the Texas State Chemist – email: jae@otsc.tamu.edu, phone: (936) 245-9949

George Ferguson, North Carolina Department of Agriculture & Consumer Services – email: george.ferguson@ncagr.gov, phone: (919) 733-7366

Liz Higgins, New Mexico Department of Agriculture – email: lhiggins@nmda.nmsu.edu, phone: (575) 646-3108

Jan Jarman, Minnesota Department of Agriculture – email: jan.jarman@state.mn.us, phone: (651)201-6221

Tiffany Leschishin, Minnesota Department of Agriculture – email: Tiffany.Leschishin@state.mn.us, phone: (651) 338-9951

Eric Nelson, FDA, Center for Veterinary Medicine – email: eric.nelson@fda.hhs.gov, phone: (240) 276-9201

Jo Lynn Otero, New Mexico Department of Agriculture – email: jotero@nmda.nmsu.edu, phone: (575) 646-2676

Suzanne Riddle, Missouri Department of Agriculture – email: suzanne.riddle@mda.mo.gov, phone: (573) 522-6786

Jason Schmidt, Louisiana Department of Agriculture – email: jasonschmidt@ldaf.state.la.us

Austin Therrell, South Carolina Department of Agriculture – email: atherrell@scda.sc.gov, phone: 803-415-5220

 

Below is TruthaboutPetFood.com’s and AssociationforTruthinPetFood.com’s response submitted to the AAFCO Pet Food Committee…

AAFCO Pet Food Committee
Re: Proposed agenda item for “minor edits” to the definition and guidance document for Human Grade pet food.

Representing pet food consumers, TruthaboutPetFood.com and AssociationforTruthinPetFood.com is in disagreement with the proposed changes to the definition and guidance document for Human Grade pet food. The proposed changes would result in Human Grade pet food being non-compliant to human food law.

Human food that contains more than 3% meat is USDA jurisdiction, required to be manufactured under constant USDA inspection. The proposed definition changes ignore proper jurisdiction of a meat based ‘food’ and federal requirement of inspection.

Human food that contains little to no meat (less than 3%) falls under FDA jurisdiction and is not required to be manufactured under inspection. The proposed definition changes attempt to move Human Grade pet food into a non-meat containing ‘food’ product jurisdiction.

As Human Grade pet foods contain more than 3% meat, the proposed changes would – per human food law – produce adulterated Human Grade pet food due to lack of inspection. The term “edible” must remain as it ties Human Grade pet food to the proper jurisdiction for food that contains meat.

This proposal is far more than “minor edits”. This proposal suggests a dramatic change to the definition and guidance document for Human Grade pet food. Consumers should be provided with the same quality and safety standards of ‘food’ with a Human Grade pet food.

Susan Thixton
TruthaboutPetFood.com
AssociationforTruthinPetFood.com

 

There are numerous consumer advocates that are working together to try to stop this proposal. Consumers can help us by telling any or all of the above voting members of the AAFCO Pet Food Committee you disagree with the proposed change. Consumers deserve at least one pet food option that abides by law! The current definition of Human Grade pet food abides by law, the proposed definition would not (and most feed grade pet foods do not abide by law).

For all Human Grade pet food manufacturers, please make arrangements to attend the January AAFCO meeting and voice your opposition to these proposed changes. And/or contact Dr. Cathy Alinovi of Next Generation Pet Food Manufacturers Association for representation on this issue at the meeting.

 

Wishing you and your pet(s) the best,

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


Become a member of our pet food consumer Association. Association for Truth in Pet Food is a a stakeholder organization representing the voice of pet food consumers at AAFCO and with FDA. Your membership helps representatives attend meetings and voice consumer concerns with regulatory authorities. Click Here to learn more.

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30 Comments

30 Comments

  1. Follower

    January 7, 2018 at 3:35 pm

    I see 2 motivations:

    One, removing the word “edible” is so that no one assumes human grade PF versus livestock feed grade, is allowed to be consumed by people as a possible “meal.” (And yes, people are that dumb).

    Two, by lessening the manufacturing oversight perimeters over human quality PF, opens the door for more companies to upgrade, or add to, their products, with a more expensive “human grade” PF line. Probably because they see a new trend coming, and understand how PF consumers are becoming more informed.

    Regarding PF, the problem will become, if and when meat (all protein) is not required to be USDA Inspected and Passed, as we assume it is now for “Human Grade Edible” PF products. That’s the real matter!

    And THAT requirement should be protected at all costs!!!

    Otherwise owners (looking for assurances) will just give up on anything commercial no matter what! (Got that, all you PF Manufacturers reading this site??) If you want to push the rationale for feeding only raw and home cooking, go ahead and remove the word “edible” from the human grade definition … then see how that works for you!

    Buh, Bye!!

    • T Allen

      January 7, 2018 at 4:35 pm

      Human Grade PF should be edible by people! That’s what we expect and that’s what we are paying for! If people want to eat it why not? It’s a little expensive and not balanced for a daily ration but people are eating canned pet food now because of the price. 🙁 And I totally agree that if this passes more and more people will switch to homemade. I’m not worried though because people know the Purina’s of the world are not trustworthy and won’t buy it no matter what they call it. The Honest manufacturers will continue to do what is right and work around this BS to provide us with healthy PF! In the meantime we can tell AAFCO exactly what we think of them. (Sad because I remember when they were depended on too.)

      • anonymous

        January 7, 2018 at 8:17 pm

        Please, please write a letter to someone above. Liz Higgins would be my suggestion…

      • Follower

        January 7, 2018 at 8:37 pm

        Thanks for the reply ?. I’m not being combative or argumentative, honestly. Am just curious! The PF HGE products I do see listed are packaged in every way except canned. So what would be an example of a canned PF “human grade edible” product? I see where one is mentioned on The List, but if you read closely it’s still “feed grade” but “trustworthy.”

        In the meantime, especially at the price of ANY canned PF so distinguished as being “human grade edible” I would encourage folks to buy a canned meat or fish product manufactured for …. people.

        • T Allen

          January 8, 2018 at 7:37 am

          I absolutely agree! It’s cheaper to buy real canned people food than the garbage in a can for ridiculous prices for pets. Once people realize that the PF companies are out of business. The only reason people buy now is price and when show people in the store the price per pound they are paying they put the can down and go buy a chicken. 🙂

      • Pet Owner

        January 7, 2018 at 8:51 pm

        This proposed change in language is very significant! Do NOT underestimate what it means. I am not so sure the “honest” manufacturers will continue going out of their way, to produce the same product as is currently being regulated now! Particularly if their revised price point isn’t continuing to be competitive in the market place.

        Oversight AND consequences are what’s keeping them honest. Let’s be real here. The whole point of compliant labeling, as human EDIBLE, is in making sure meat is USDA Inspected. And that PF buyers (including third party handlers) aren’t transacting with any businesses who aren’t being constantly inspected!

    • Debi

      January 8, 2018 at 9:10 am

      So well said my friend, have been making our own foods forever ! hope more people will do the same for the love of their pets

  2. Marc

    January 7, 2018 at 5:54 pm

    This is absolutely disappointing news. I buy only human grade based on the law and definition. I spend a lot of money monthly based on current law, ingredients etc. It’s flabbergasting that these government employees and organizations are ultimately paid by us consumers and they seem to disregard our needs and are rarely advocating for improvements in the industry or for our pets. At what point can we ever get control of this industry? “Draining the swamp” is a dream not likely to ever happen. The incompetentance and corruption is infuriating.

  3. Agnes Horowitz

    January 7, 2018 at 7:10 pm

    People in my circle have more and more distrust in the PF industry and hold them responsible for a lot of disease in pets. We are shifting to home made or other fresh alternatives. Most of the PF industry has lost our respect.

  4. Donna Muse

    January 7, 2018 at 8:10 pm

    Susan,

    I am befuddled as to why anyone who listens to you buys any dog food. Even before I came across your info I was cooking for my dogs and had a lot to learn regarding nutrition. I never go down the dog food aisle nor to any Pet Food store unless it’s to buy a toy. In the long run it’s cheaper and easier than trying to figure who is lying this week about their ingredients.

    • T Allen

      January 8, 2018 at 7:44 am

      Convenience. It’s 100% convenience. It’s 1000% easier to dump kibble in a bowl than make a fresh meal. And the high quality frozen and dehydrated products are very expensive but people are learning they can feed their pets the real food (we used to call leftovers) and their animals are healthier than those feeding kibble!

  5. anonymous

    January 7, 2018 at 8:17 pm

    What I would like to know, Susan, is why did Dave Dzanis submit this suggestion? Which company out there paid him enough money to submit this to AAFCO as a good idea? I think that Dave Dzanis should be compelled to disclose exactly which company paid him and how much to push this though. Corruption at its finest.

    • Susan Thixton

      January 7, 2018 at 8:37 pm

      I would agree with you. My gut feeling too is this change comes directly from someone in industry that wants to cut corners for a human grade product.

  6. Jill Chambers

    January 7, 2018 at 9:23 pm

    The government just doesnt make sense. Food with meat needs regular inspections but food without meat gets inspected every 10 years? OK so Cambels tomato soup is garbage anyway, but foods that dont contain meat dont get inspected every year???? I am floored over this. Am disgusted actually. We are eating this??? And now those same guidelines will be given to a food that DOES contain meat? pet food or not, dont they see the holes in their logic?

    • T Allen

      January 8, 2018 at 7:30 am

      This has nothing to do with food safety, it’s all about profits. That is where the public has to deeply understand and change their thinking. When people can comprehend that the Gov is now in the pockets of big money and all that matters is lining their own pockets,
      then we can start electing different people and making changes.

  7. Elizabeth Montgomery

    January 7, 2018 at 11:33 pm

    I’ll make calls tomorrow. This is disgusting. I had know idea human food without meat is not made under any inspection. Is there more inspection when buying organic products?

    • anonymous

      January 8, 2018 at 9:43 am

      No. It’s all the same. The idea is that there is less inspection with non meat/poultry/egg products because the risk of food borne pathogens is lower and typically will arise from the supply-side (think of the peanut and spinach recalls from years ago- they didn’t originate with the companies that used the ingredients in making soups etc. but originated with the supplier/farm). Whereas with meat products, there is a very high risk of salmonella and bacteria etc.

      But even if someone is not thinking about pets, think about yourselves and your children. Here is an example- THIS IS ONLY AN EXAMPLE AND NOT CURRENTLY HAPPENING: You feed your baby Gerbers carrots and peas (under FDA inspection). Pet food company X approaches Gerbers and says “hey, you shut your plant from 6pm-6pm because there is no potential for FDA inspection. How about you let us make our dog treats here.” Gerber thinks its a terrific idea and they will earn a ton of money letting their plant run 24/7. So Pet Manufacturer X brings in meat and poultry- some of it drops on the floor, some of it is stuck to the bottom of the workers boots- and there is no one to inspect how the treats are being made. And it goes into the pet chain and gets labeled “human grade”. The next morning at 6am, Gerbers cleans the plant but there is residue of chicken that doesn’t quite get washed off and in it goes with the baby food, slamonella and all.

      I hope that more consumers write emails and call all the names and numbers listed above. This change can lead to sicknesses all over the food chain!

      • T Allen

        January 8, 2018 at 11:01 am

        Highly likely scenario considering what they are planning! The average person thinks USDA inspected meat is “safe”. It’s not. That’s why there are minimum cooking temps on all labels! Now imagine the quality of meat that was inspected and didn’t pass. It’s still USDA inspected (failed)! Came from a USDA plant… That doesn’t mean it couldn’t be a useful product if handled correctly, it could. But there are no regs that apply once it fails USDA inspection. It can then be purchased by Company X and taken to the FDA inspected plant for use in a Human Grade food? This is appalling on so many levels!

  8. Adriana

    January 8, 2018 at 1:52 pm

    Done – sent my “protest” emails to the folks above. Thank you Susan for your hard work and providing us with good talking points on this issue. Let’s keep up the good fight!

  9. Anna

    January 8, 2018 at 8:55 pm

    I’m not sure where this article got their info but FDA regulated manufacturers get inspected every two years if they are domestic. Every 9 of foreign but there were a whole slew of new regulations sent down for foreign importers in the Food Safety Modernization Act FSMA.

    • Pet Owner

      January 9, 2018 at 3:09 am

      I don’t think the issue is necessarily foreign or domestic. But whether the product contains less than 3% meat (under FDA jurisdiction, every 10 years inspection) or meat products under USDA jurisdiction under constant inspection. So we’re referring to PF products, containing meat protein, currently so called labeled as “human grade EDIBLE.” If (and how) the Food Safety Modernization Act FSMA, has impacted this distinction currently, (and would, considering the proposed change) please be specific with your response. Thank you.

      This is a VERY important issue.

    • T Allen

      January 9, 2018 at 7:22 am

      FSMA was signed into law on Jan 4, 2011. Seven years later, to the day, the FDA still isn’t in compliance because of fiscal constraints and released a notice stating “it intends to exercise enforcement discretion for certain provisions in four of the rules that implement the FDA Food Safety Modernization Act (FSMA). This means that during the enforcement discretion period, the agency does not intend to enforce these provisions as they currently apply to certain entities or activities.” https://www.fda.gov/Food/NewsEvents/ConstituentUpdates/ucm590667.htm

    • anonymous

      January 9, 2018 at 1:22 pm

      It doesn’t even matter if it gets inspected every 2 years or 7 years. That inspection will never occur when the pet products are being manufactured at the FDA plant- the plant will make sure of it so as to not get cited. I don’t know about you but I am certainly not comfortable with feeding my baby some baby food that had meat for pet food running on the same conveyor an hour earlier and the possible contamination that could result. This not only affects our pets but our children and ourselves. There is a reason USDA inspects facilities that make meat products daily/ very frequently. Because meat products are loaded with pathogens.

  10. Janice

    January 8, 2018 at 11:47 pm

    Our best friends need our voice them in order to see they get the best food and care.

  11. Gloria

    January 11, 2018 at 2:49 pm

    I would love to see pet food regulated the same as human food but I have some questions about sustainability. If all the meat used in pet food were exactly the same as the human food version, where would that meat come from? Wouldn’t we have to increase production in crazy amounts? And what would happen to those parts of the carcasses that we typically don’t eat? Would that go to landfills? And all that increased production – wouldn’t that lead to some real ecological implications? (I am thinking about the already crazy amount of methane produced by cattle and the additional land that would have to be allocated for raising chickens and pigs) Just how would this work?

    • T Allen

      January 11, 2018 at 8:09 pm

      We aren’t taking about using the same cuts of meat for pet food, we are discussing the method of inspection and handling of the parts that aren’t suitable for humans. I get my dog’s food from a slaughter house that is USDA inspected and the owner saves the “edible” meat, fat. organs and bones under sanitary and refrigerated (or frozen) conditions until blending it and grinding it for dog food. The rest is handled as “inedible (diseased organs and carcasses) which are sent to a renderer. Most of this meat could be eaten by humans but some is rejected that is still suitable for animals. This is a much different process than the pictures on Truth about Pet Food and FB showing dump trucks filled with meat waste sitting in the hot sun and covered with flies outside of pet food manufacturers! Removing the word “edible” shifts the Human Grade Product from what I described first to the garbage described in the dump trucks that should be rendered and NOT fed to any living thing including chickens and hogs!

    • Pet Owner

      January 11, 2018 at 8:33 pm

      The questions are many. Actually.

      For example, is livestock production responding to the needs of the PFI? Well they *might* be, if PF wasn’t a substandard product in the first place. (Hmmm, which is a function of greed right). Or is the PFI supplying a solution to the failure of livestock production’s best practices? (Greed and the inhumanity of factory farming right). Your comment is a loaded discussion. Including the presumption feeding an already risky product, in the name of efficiency (sustainability) addresses associated problem. Including whether or not our society is producing (and for that matter, living) under the conditions of excess and surplus. Do humans require the abundance of red meat and other protein currently being consumed? Or is it someone else’s right to tinker with the consumer’s free market preferences? So first, let’s ask why is meat becoming (or is) contaminated, the quality of livestock feed? Can that failure be corrected? And will the cost be affordable? (Not suggesting that it shouldn’t be the goal of course!). Maybe a start would be to examine the principles of redistribution, education and consequences being enforced for the failure of safety and regulation in the food chain. Rather than (at this point in time) denying the natural instincts of companion animals’ diets.

      But then I suspect the foundation of your comment, comes from a PETA based argument, that pets (or ANY animal) should not be the property of humans. Not being sure how this conviction aligns with evolution. Or tries to simplify a higher purpose being assigned to the responsibility of living well! Not that it isn’t a noble goal, within a complicated predicament.

      So in the meantime let’s just enforce the laws already on the books, including truthful labeling and marketing. Allowing PF consumers to make informed selections! And I suspect the problem will correct itself.,

      • Rochambeau

        January 13, 2018 at 7:11 pm

        Sustainability (and affordability!) are two very pressing issues not only for the US but the world as well. (And NO! I am NOT a PETA person – as a matter of fact, far from it! I have dogs, cats and livestock – and I worry… really worry!)

  12. rsdgotme080058

    January 23, 2018 at 5:52 pm

    I just saw this article and have quickly emailed all of the members listed hoping they get before any final vote.

  13. Terri

    October 8, 2018 at 1:17 pm

    If Pet Food isn’t human edible, then it should not be labeled as such. Our pets are being fed enough “junk food” without the industry making it even worse. Not all pet owners are as aware of the facts as others. Don’t be a part of taking advantage of the well meaning pet owners who trust the AAFCO, primarily because their veterinarians tell them to look for that label. Shame on you.

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