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Consumer Input Requested – Definition of Feed

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  1. Lynn Felici-Gallant

    Hmmmm. I feel like we’re trying to fit a square peg in a round hole. Why aren’t we starting with a definition of pet, then moving to “food” as the only acceptable “material” for a pet to consume? It seems to me the bigger problem is that pets are in the same category as chickens or cattle, for example, and therein lies at least part of the problem. The only acceptable “feed” for pets, to my mind, is “food”. Thanks for all of your work, and for seeking our input.

  2. karen

    Susan Thixton, are you going to submit our remodification to these definitions to the September 21st meeting? If so, then i will put in some input on #4…

    (4)Inedible and Edible matter(s) which are consumed by animals other than humans and contribute energy and/or nutrients to the animal’s diets. (1) Substances fed for a nutritive effect in the animal (e.g., providing one or more nutrients and ,artificial nutrients or other nutritive effect, and (2) substances that have technical effects in the food (e.g.,artificial anti-caking agents, artificial fillers, binders, emulsifiers, enzymes, mixing aids, artificial preservatives, processing aids, including heat processing, artificial stabilizers, and substances added for aroma, flavor,(artificial vitamins,minerals,and other artificial nutrients), or other technical effects) rather than actual clean, disease-free nutritive results in the animal. It includes pet food, specialty pet food, animal feed, and raw substance and raw and artificial ingredients. This is intended to be equivalent to the substance also described as food in 21 USC 321.

    I dont like at all the word “materials”, sounds like they are eating, paper, clothing, wood, glue , ect. also should there be something in there about outsourced substanses? (which they are under “feed”) i would like some “feedback” (no pun intended), comments, suggestions on my revisions or do you feel its even worth putting in the revisions. thanks, have a great day!

    1. Kathryn S

      they are, in some cases, eating wood and paper, and I’m sure somehow or another ‘clothing/toweling’ etc. has found it’s way in to some livestock products.

  3. Jackie

    Those (so-called) definitions are nothing but political double-speak. There are no definitive guidelines. As I was reading through it, I got the feeling that it was specifically written to leave loop-holes for pet food manufacturers to include “feeds” that were not healthy for our pets. The word nutrition was used. Yes, you can “feed” a companion animal on garbage; but it will not be a healthy animal.

  4. Tracey

    If the definition of “edible” is included then it needs to be defined and assuming that it is the same as the USDA definition, enforced. That in itself would eliminate a lot of materials from the feed supply. I assume the PFI would not allow that to happen.

    # 1 is ridiculous because animals eat a lot of stuff they shouldn’t, rocks, shoes, knives, etc.
    #2 Leave out “which are consumed” or change to “which are normal to consume”, eliminates plastic and 4D (unless you have a pet vulture).
    #3 Only if enforced as per “food law”. I agree with Susan, no use of the word food unless it is food.
    #4 Is what we have now, calling feed, food. Which it clearly isn’t, unless they change the definition of edible.
    #5 No, even if change edible. “Usually” is a loophole.
    #6 Change the word food to the word eat.
    The definition would be:

    A product or substance including raw materials and ingredients, which is intended to be used by animals other than humans, to eat or drink for nourishment.

  5. K.E G

    I think this whole conversation is mute, until the government quits using the pet food industry as a dumping place for all the “4D”, and euthanized animals, etc. They are going to continue to word things so that they can CTA (cover their ass) , and continue to let anybody, put anything in food/feed, so they don’t have to deal with it. As far as your choices for definitions above: #1 won’t work–too many dogs eat EVERYTHING-shoes, patio furniture, etc. I don’t understand why it can’t be: ingredients provided for animals to eat, that contribute to increasing/maintaining, their health, without causing harm. What’s wrong with that? The other thing that needs to change is that pets/animals need to quit being considered our possessions-like a lawnmower, and be considered something we are the guardian of–like another human–you know something of value, that should be guarded, and cared for. I deal with all these same issues in my industry, when it comes to fertilizers for gardening/farming–THAT’S WHY I’M IN THE ORGANIC GARDENING BUSINESS!!!! And why we ONLY carry pet food made by companies with, commonsense AND scruples.

    1. Dianne & pets

      Without causing harm is a problem, we already know that many things that have been included in feed do indeed cause harm.

  6. Holly

    I object to the term “man” (uppercase mine below). Why not use the word “human”?

    (3) All food and/or food ingredients which are consumed or intended to be consumed by animals other than MAN.
    (5) Edible material(s) which are consumed by animals and contribute energy and/or nutrients to the animal’s diet. (Usually refers to animals rather than MAN.)

  7. Kathryn S

    I’m not 100% convinced that products offered to be consumed for nutritional benefit by humans actually fits these definitions – and when there are only 8000 FSIS (USDA Food Safety Inspection Service ) nationwide ??? take a look at the USDA map! woefully understaffed.

  8. Patricia Thompson

    I read all
    Labels on dog food bags. Thanks to your good advice I only feed my dog top quality food such as, Acana & Fromm made in Canada & America.

  9. Patty Janiszewski

    I don’t understand why the definition has to change from what it previously was! From what I read of all the other descriptions none of them conform to a description that allows me to trust the food I am paying out money to purchase for my animals; dogs and cats. If i choose to go to a store or go online and purchase my animals feed, I should be able to trust our Government who pays good money out for agencies and departments to provide accurate laws about that feed that I can trust and is acceptable to what I chose for my animals feed!!!

    1. Sharon Oh

      do you regularly read this post?
      ???? really ????trust our Government who pays good money out for agencies and departments to provide accurate laws about that feed that I can trust . . . . THEY ARE LYING TO US and NOT following the laws that should protect us!

    2. Tracey

      Yes Patty we should be able to but unfortunately we can not. The US Gov is corrupt, bought and paid for by bribes, “donations”, and although some employees are doing their best they are working against a rigged system. I worked in that system until my ethics were worth more than the paycheck. It’s worse than you can imagine (even on the human food side) and all you need to do is go back to the archives on this website and do some reading to see that you are paying a lot of money for garbage. This includes the expensive, top name brands. They all get there meat “protein” from the same sources. Rejects from the human food supply are really garbage because they are not rejected unless they are really bad ( know the source of your meat) and then they are handled like garbage, minimal to no refrigeration, flies, non-edible materials etc. Better than the cheaper non-human sources like rendering plants but still not good. Please educate yourself, your pets life depends on it!

  10. Jane Eagle

    “Material fed to animals which is unsafe for humans to eat due to contamination or putrefaction”
    – love to see THAT on the bags of garbage they sell!

    1. Sharon

      Count me in on this definition!

  11. Jane Eagle

    Reading the other comments reminds me that back in the 60s, maybe into the 70s, one of the ingredients in pet feed for dogs at least, was sawdust: a bulk filler with no nutritive value. When consumers found out and complained, they switched to using grains: more cheap filler, also indigestible for dogs and cats.

    1. Tracey

      Currently Hills Science Diet Z/D Prescription dog food contains cellulose. Usually made from wood chips.

      This is the most disgusting thing I’ve seen in a long time. Especially for the price per can!

      Ingredients: Water, hydrolyzed chicken liver, corn starch, powdered cellulose, soybean oil, dicalcium phosphate, potassium citrate, calcium carbonate, vitamins (vitamin E supplement, ascorbic acid (source of vitamin C), etc, etc.

  12. Mary C. St. Mary

    Can I vote for none of the above? I guess #2 is the definition I would least object to.

  13. Pat Lee Carignan

    MY DEFINITION OF FEED: products that meet the minimal requirements animals need as sustenance.
    (which means…It’ll keep them alive but not necessarily nourished with regards to health.and thrivabilty).

  14. Rhonda Lucich

    Doing a little brainstorming here. Would this work?

    Animal-grade “feed”: Ingredients intended for consumption by pets and other animals for the primary purpose of providing nutrition and energy. Feed may also include non-nutrtional substances, such as anti-caking agents, binders, emulsifiers, enzymes, mixing aids, preservatives, processing aids, stabilizers, and aroma/flavor/color enhancers.

  15. pat chesney

    animal feed contains materials which are not suitable for human consumption, but are deemed acceptable to be given to animals for their consumption

  16. Juno's mom

    Pet food and human food should not be differentiated. Keep it simple.

    1. Lynn Felici-Gallant

      Amen, Juno. This is my exact position. Pet food for companion animals (and others, really) used to be simply food — human food. That’s the direction we should be heading, not trying to determine what non-human “feed” is acceptable.

  17. Gitta

    Feed: all materials/ingredients unfit for human consumption but eaten by animals.

    1. Dianne & pets

      but fed to animals (because they can’t read labels and have no choice)

  18. Nancy D.

    I would like to see specific ingredients listed and do not find anything else acceptable. Whatever it is, should be what it is labeled. For example, if it is chicken, than the part of the chicken. If it is chicken by-products, than what by-products. We have the right as consumers to know what we are purchasing and what we are feeding our companion animals. We are their caretakers and should not have to call companies, ask for and wait for responses as to what is in the food they are producing. If they are producing it, they should know where it comes from. I do agree with Susan that it should not say food unless it is human grade food.

  19. Linda Saslow

    I agree with Nancy D. – just tell us what is in the products we fed our pets and country of origin.

  20. Cecilia Barnett

    I have a problem with “which are consumed or intended to be consumed” and I’m not sure how to define my thoughts on the subject. When a child drinks a poisonous liquid, he ‘consumes’ it and when they spray plants ‘intended to be consumed’ with pesticides and the pesticides are left to soak into the skin of the fruit or vegetable, what are the underlying intentions? IF this is acceptable practice for ‘human grade’, what will be done to the poor second and third class victims of the ‘feed’ category?

  21. Dr. Oscar Chavez

    Feed: materials eaten by animals, not intended or allowed for human consumption.

  22. Jeri

    I think there needs to be an emphasis on the fact that 1) Food and FEED are not the same thing, legally. For example, #1 could read “Materials eaten by animals, rarely food-grade. 2) is fine, but I would like to see, “may not be food-grade unless specified”.
    3) Not food. Cannot be used in definition in my opinion without a deliberate attempt to mislead the consumer. So…. #3: Feed and/or Feed-based ingredients fed to cattle, livestock and pets. (Let’s call it what it is without trying to make it out to be what it is not!) #4: In my opinion, given that many of the “edible” things have been declared dangerous and certainly of dubious nutritional value, I think all reference to nutrition needs to be struck. It should not be used since that has not been established to be the case. #5: Same objection as #4. References to the effect it is supposed to have on the animal is not in evidence and should not be referenced. #6: Feed grade materials fed to animals. No mention of “food” since legally that is not what it is. No mention or reference to “edible” or “nutrition” or “energy” since much of that is soundly disputed by experts and has not been proven decisively by the industry. Endotoxins do not provide energy or nutrition. Much of what is in feed grade pet feed is neither edible nor nutritious. No definition should be allowed which blurs that line. Any attempt to create such a definition is simply a bait and switch on the consumer and should be called out as illegal.

  23. Roger Rittenhouse

    The whole problem is that AAFCO is trying to distort the concept of food. Trying to define feed separately from food is a non sequitur. Why should animals eat products of less quality than humans? This is pure speciesism. Granted cattle eat different foods than humans because their stomachs and digestive systems are different, but why should what they eat be of less quality than grains and greens we eat? I recommend not playing this game with AAFCO. Instead just stick to our guns that food is food and not feed.

  24. Reva Crump

    Definition 2 has my vote. It avoids attempting to define food and/or nutritional value. “Feed” should do no harm; do we need to address ingredients consumed should be scientifically tested to do no harm to the intended animal or those that consume the animal?

  25. Linda Horn

    I agree it is difficult to define “feed” as something which doesn’t meet human food requirements, without appearing to give permission to industry to violate the FD&C Act. With this in mind, I think definition #6 might work, if they change the wording so it doesn’t include the word “food”, for example:

    An article intended to be consumed by animals other than humans, including raw materials and ingredients.

  26. Lewis Turner

    Perhaps I’m missing something, with regards to the appropriate wording that should be utilized. But, just as your post states, the individual State regulatory agencies can merely decide to ignore whatever definition is agreed upon. Just as they ignore vitally important legislation.

    Besides letter writing, are there other avenues we can take that would ultimately lead to forcing the approrpiate government agencies to Enforce current legislation?

  27. Shirley Bryant

    Won’t happen because AAFCO and FDA don’t have the guts to make a stand but what I’d love to see, on each package, bail, batch of veggies, or can, is:

    “Commercially processed feeds and foods, including those for pets, factory farmed animals and human consumption, may contain ingredients that are injurious or even poisonous to living creatures.

    “See complete list of ingredients, including any medical ingredients contained, method of processing, ingredients added during processing, and country of origin and of processing on this can, batch, or package before making your decision to buy it to eat yourself or to feed to another living creature.”..

    1. Tracey

      Love it! Maybe on another planet or different millennium this would work!

  28. Christine

    Edible – I too have difficulty with this term. Reasons: over 20 years ago I read in Birder’s Digest that researchers had observed wild birds feeding bits of plastic to offspring, over 5 years ago while driving along a rural road I saw, with no time to successfully react, a young calf in a large field snatch a plastic bag that had been caught in the barbwire fence, in Southern Arizona a type of locoweed grows….Now, one wonders if the baby birds died, likely; did the calf die of a horribly painful blocked digestive track, likely; locoweed is palatable to livestock if the field has been eaten down of more palatable vegetation – were all of these items “edible”? Yes. Are they detrimental, YES. Is chocolate “edible” to dogs, yes; will it kill them, yes. Edible ain’t the word!

  29. Art

    I’m sorry, but I am completely confused by what you’re asking for here. None of those definitions is what I would want them to be.

  30. traci vallone


  31. Pacific Sun

    The exercise AAFCO is proposing is a Trap!

    The short answer is “Feed” is a verb and “Food” is a noun.

    Therefore any “edible nutritional material” intended for the sustenance of animals IS food, and it can’t be changed into a word called feed. The one instance (by definition) where the verb feed is given the status of a noun is by using the phrase “food for animals, especially livestock.” Therefore Feed is STILL Food by accepted definition!

    AAFCO doesn’t have the power or the authority to change words in the Dictionary!!!

    We also have to remember that AAFCO never does anything for the benefit PF Consumers (or animals). It protects Industry. That’s why Industry pays a fee to belong. I question why there is now a big push to redefine these words, instead of focusing on the standard of WHAT MATERIAL constitutes being “edible, suitable, nutritional sustenance” for animals.

    What animals eat should not be sub-classified (or separated) into anything less or different than real food. Even if Ag-Business Consumers already use the slang term of (Animal Feed) to denote a product being sold to feed livestock, it is still food! We’re just in the habit of saying “chicken feed” instead of “chicken food.” But it doesn’t change the reality of what the words actually mean!

    I think if AAFCO is successful in reclassifying (by terminology) “edible nutritional material” that animals eat from the word Food into the word Feed, then what animals do eat will no longer be subject to the FDA’s definition of Food (see below) and will therefore eliminate what little protection PF Food currently has.

    • Section 201 (f) provides the definition of food: “The term ‘food’ means (1) articles used for food or drink for man or other animals, (2) chewing gum, and (3) articles used for components of any such article.”
    • Section 402 Adulterated food: “A food shall be deemed to be adulterated – (a) Poisonous, insanitary, or deleterious ingredients.” (a)(5) “if it is, in whole or in part, the product of a diseased animal or of an animal which has died otherwise than by slaughter;”

  32. Shirley Bryant

    Won’t happen because AAFCO and FDA don’t have the guts to make a stand but what I’d love to see, on each package, bail, batch of veggies, or can, is:

    “Commercially processed feeds and foods, including those for pets, factory farmed animals and human consumption, may contain ingredients that are injurious or even poisonous to living creatures.

    “See complete list of ingredients, including any medical ingredients contained, method of processing, ingredients added during processing, and country of origin and of processing on this can, batch, or package before making your decision to buy it to eat yourself or to feed to another living creature.”.

  33. Alicia

    Boy! This is a tough one. I absolutely agree that the term food should not be in the definition of feed when referring to our pets. In fact, if you read the definition of “feed” in the Cambridge Dictionary it defines it as: “food for animals, especially animals that are not kept as pets.” NOT kept as pets – says it all. Seems ridiculous that we have to use the term in relation to our pets.

    1. Pacific Sun

      It’s not my preference to create an argument here. But every situation does have an exception. I understand the intention of the Cambridge Dictionary. But there’s no definition (really) for a “pet” either. Some people keep little pigs, or friendly goats, or chickens (without raising them for slaughter). “Companion” pet might be a little more specific. But a pet is a pet to whomever has a particular affection for the animal.

      Simplicity is the best route to clarity. Real food is food and it should be that way. Food can feed livestock as it is manufactured to meet each species’ specific nutritional requirements. “Feed” can be an Agri-Business product description, but it should NOT become a legal reference, or else the FDA will have a loophole to exempt Pet “Feed” from it’s standing regulation.

  34. sonia

    Feed – Food that is inedible for humans, i.e., diseased, euthanized, rotten, road kill, etc., but allowable for animal consumption. Burn the garbage instead.

  35. Lynda

    I find this very confusing so I guess I would vote for the most simple–the first definition. However, it is immaterial to me because since the 2007 pet food recalls due to melamine in pet food, I have simply fed grocery store human meat to my cats. The only hard thing about that was locating a source for an organ meat other than liver. Once I found a place that sells kidney, my little meat-and-bone eaters were good to go. 🙂

  36. DArcy Dent

    Feed is a food alternative intended for the use of maintining animals in a living state, which may or may not contain substances considered safe or edible for human consumption.

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