Below you will find FDA’s unacceptable and misleading proposed definition of “feed grade” and my response.
Please note: this is not a final decision, this is all in ‘discussion’.
In preparation for another online meeting next week, FDA submitted the following definition of feed grade to our small working group…
Feed grade: material that is safe, functional, handled, and labeled appropriately for its intended use in animal food.
The FDA also stated that they didn’t feel it was “especially useful” to include any mention of Compliance Policies in the feed grade definition, sharing that “Those substances are atypical feed ingredients, and are handled on a case by case basis.”
(FDA Compliance Policies allow feed ingredients/pet food/animal feed to violate federal law. Federal law requires a food – defined as what humans and animals consume – to be sourced from a non-diseased animal and a slaughtered animal. FDA Compliance Policies allow pet food and animal food to source meat from diseased animals and animals that have been euthanized or died in the field. Some Compliance Policy allowed materials are “handled on a case by case basis”, but most are not.)
My response to this definition from FDA…(posted on the AAFCO website within our group)…
From the consumer perspective, this definition is completely unacceptable and misleading. Why would FDA want to hide from the pet consumer public the inferior quality of some feed ingredients with this definition? Why can’t the definition of feed grade be honest and transparent? Your/FDA’s definition is protecting feed grade ingredient providers, instead of protecting the consumer (and the consumer is who has to deal with the consequences of inferior feed grade ingredients).
Feed grade ingredients are not labeled to the consumer. They might be labeled to each manufacturer (by the supplier), but they are not labeled/disclosed to the consumer. Yes, you are correct – they should be “labeled appropriately”. “Labeled appropriately” to the consumer. Will consumers be provided this information on pet food labels?
Justifiably so, human grade is required to jump through multiple hoops to make the claim. On the other hand, feed grade accepts almost any waste material, in almost any condition, and FDA wants to define it with a far less than transparent definition. This definition is not serving the consumer, it is serving industry.
We have provided sufficient evidence that not all feed grade material is “safe”. Was that information just dismissed?
What does “handled appropriately” mean? Extremely vague.
We are asking for transparency. If regulatory authorities wish to believe that diseased animal tissues and tissues from 4D animals are safe for animals to consume – fine. If regulatory authorities wish to believe that pesticide and chemical laden ingredients are safe for animals to consume – fine. But at least be honest about it through legal definitions. Transparency will allow the consumer to make up their own minds to what quality of ingredient pet food they wish to purchase.
Again – this definition lacks transparency, is misleading to the consumer, and unacceptable.
Click Here to view the detailed information that Dr. Jean Hofve provided to this working group in reference to terming ‘feed grade’ as “safe”. What Dr. Hofve provided to this group (included FDA) has 2 1/2 pages of citations from scientific studies and published literature. All of her evidence to the questionable “safe” claim of some feed grade ingredients – to this point in the discussion – has been ignored.
(Please know that the information provided by Dr. Hofve above is included in her new e-book and so much more. The e-book “What Cats Should Eat” is available on Amazon.com and from Dr. Hofve’s website. This information is published here with her permission as she too believes that consumers should be informed of what they are purchasing. Please support Dr. Hofve’s work and her efforts advocating for consumers!)
The next meeting on this subject will be Tuesday November 24, 2015. I will post another update after that discussion.
Updated information: Thanks to an idea from one of you wonderful consumers, the following additional comment was provided to our ‘discussion’ group on feed grade this morning (11/21/15)…
Several quotes from Merriam-Webster seemed appropriate in response to FDA’s proposed definition of feed grade…
Full Definition of DEFINITION
1 : an act of determining; specifically
2 a : a statement expressing the essential nature of something
b : a statement of the meaning of a word or word group or a sign or symbol
c : a product of defining
3 : the action or process of stating the meaning of a word or word group
4 a : the action or the power of describing, explaining, or making definite and clear
b (1) : clarity of visual presentation : distinctness of outline or detail
(2) : clarity especially of musical sound in reproduction
c : sharp demarcation of outlines or limits
Full Definition of VAGUE
1 a : not clearly expressed : stated in indefinite terms
b : not having a precise meaning
2 a : not clearly defined, grasped, or understood : indistinct; also : slight
b : not clearly felt or sensed : somewhat subconscious
3 : not thinking or expressing one’s thoughts clearly or precisely
4 : lacking expression : vacant
5 : not sharply outlined : hazy
Full Definition of MISLEAD
: to lead in a wrong direction or into a mistaken action or belief often by deliberate deceit
: to lead astray : give a wrong impression
Wishing you and your pet(s) the best,
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