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Final Proposed Definitions Feed Grade and Human Grade

After many meetings, a few arguments, and several stress related headaches – we have finalized the proposed definitions of feed grade and human grade.

After many meetings, a few arguments, and several stress related headaches – we have finalized the proposed definitions of feed grade and human grade.

These are still proposed definitions; they will be presented to the Pet Food Committee and the Ingredient Definitions Committee for a final discussion and vote (by AAFCO members) at the January 2016 AAFCO meeting.

“Human Grade: Every ingredient and the resulting product are stored, handled, processed, and transported in a manner that is consistent and compliant with regulations for good manufacturing practices (GMPs) for human edible foods as specified in 21 CFR 117.”

This translates to: each ingredient including each supplement is human grade (humans could consume it) and each ingredient and the final product has been manufactured, warehoused, and transported per legal requirements of human food. Pet foods that meet these requirements will be allowed to state on the label ‘Human Grade’. Basically, human grade = food.

“Feed Grade: Material that has been determined to be safe, functional and suitable for its intended use in animal food, is handled and labeled appropriately, and conforms to The Federal Food, Drug and Cosmetic Act unless otherwise expressly permitted by the appropriate state or federal agency.”

The same definition as Feed Grade will be used for ‘Suitable for use in animal feed’ (which also applies to Pet Grade).

The Feed Grade definition translates to: ingredients might meet the legal requirements of food (per The Federal Food, Drug and Cosmetic Act), or ingredients might be considered illegal (per The Act). Illegal feed grade ingredients – allowed by FDA Compliance Policies or allowed by any State that decides to give permission to a supplier to sell an illegal ingredient (adulterated ingredient per The Act) to pet food or animal food – will NOT be required to be disclosed to consumers the illegal ingredient quality. Feed Grade pet foods will be classified as pet ‘food’ even though they do not meet the legal requirement of food.

We (consumer advocates) proposed including the words “determined to be safe and functional through valid scientific evidence” in the feed grade definition. However no one else agreed – we were shut down with this request.

I believe the definitions are about the best we can do. We won’t know until January what a stir they will cause at the meeting – when the vote to finalize them takes place (of course, I will share every word after the meetings in January).

Something new learned from these meetings: any U.S. state – at their own discretion – can individually approve a feed ingredient to be used in any animal food (livestock or pet). The perfect example of this is euthanized bird flocks (chicken, geese, turkey) diagnosed with avian flu. Each state – at their own discretion – can allow these euthanized birds to be sold as feed ingredients or each state at their own discretion can require the euthanized birds to be destroyed (and not sold as feed ingredients). And at each state’s individual discretion – a feed ingredient can be sold to pet food or livestock food even if it does not have a legal definition. The perfect example of this was pea protein, pea flour, and pea starch. Individual states allowed these products to be included into pet food for years prior to being a legally defined pet food ingredients. This ‘individual discretion’ is written into law in many states. And of course, no consumer is told what is ‘discreetly approved’ by their state or why it was approved. In other words…individual states (and FDA) can do whatever they want.

It will be significantly important for all pet food consumers to educate other consumers on the legal definitions of feed grade and human grade (and their translations). Once these definitions are finalized (scheduled for the January meeting in South Carolina) – I will work on providing tools for pet owners to help share these definitions.

We – consumers and their AAFCO advocates – did an amazing thing getting ‘feed grade’ to the table to be defined. And I have to thank AAFCO President Richard TenEyck for getting feed grade to discussion. The term feed grade has been used in pet food/animal feed for decades – never having a legal definition, never being held to a particular standard. Soon, it will be legally defined. This is a very good first step. We have many more steps in front of us, but this one was/is a very good start.

 

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

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18 Comments

18 Comments

  1. Anthony Hepton

    December 9, 2015 at 3:48 pm

    Good work Susan. I am still bothered by the phrase “determined to be safe” as this can be any one of a number of agencies, FDA, CVM, AAFCO, or a state agency saying “we consider that ingredient to be safe” with absolutely no data being available for review. It will be interesting to see how those at the next meeting address their process of determining each ingredient is actually safe.

    • Susan Thixton

      December 9, 2015 at 3:55 pm

      Thanks Anthony – and I agree with you. We really wanted the scientific validation to be included.

  2. Dean

    December 9, 2015 at 3:50 pm

    Looks good as long as 21 CFR 117 does not explicitly deny the use of product with the bone ground into it… if that is determined as ‘inedible’ and thus rejected as ‘human grade’ this would effectively eliminate most commercial raw diets from using the term… despite meeting all other criteria… IMO : ) … good work…

    • Susan Thixton

      December 9, 2015 at 3:53 pm

      We need USDA to get involved in these discussions and then perhaps we can easily include bone. Currently, USDA just passes the responsibility to FDA. For you, as a manufacturer, I would suggest approaching FDA on this. Asking them to include bone (same requirements of human grade). Don’t be intimidated by them – just talk to them.

    • Jane Eagle

      December 10, 2015 at 2:36 pm

      If bone becomes an issue, perhaps the label could read something like “human grade EXCEPT for the addition of ground bones” so consumers will know what we are getting. I only feed raw, and make my own, but would love to be able to purchase ready-made food that I could trust.

  3. Sarah Jane

    December 9, 2015 at 4:12 pm

    I can’t thank you enough for what you do. I became a member of the ATPF and receive your bulletins as they’re posted. I consider myself a very concerned consumer.

    There are millions of existing pet owners and future pet owners out there who have no idea of the impact these proposed changes will have on the lives of their animals. Great, great work.

  4. Marsha

    December 9, 2015 at 4:36 pm

    I agree with Sarah.

    You have fought long and hard for all of us Pet parents. I know you will continue to fight for our pets. I also agree that the USDA needs to be involved in this. I thank you for everything you do. You are one that is trying hard to make our pets live longer and have a better choice of FOOD, not FEED. superb work Susan!

  5. Cherie Holverson

    December 9, 2015 at 5:09 pm

    Thank you so so much for all you do for our animal babies.

  6. Nina Wolf

    December 9, 2015 at 5:17 pm

    What a long fight this has been – hats off to you and Dr. Jean Hovre for all your work. It isn’t nearly as condemnatory of feed grade as I know you and a lot of us would like, but it is a big step in the right direction. And you learned some valuable things along the way too. Think about how many years it has taken just to get AAFCO to let you have a real voice! You have worked so hard in the face of such overwhelming adversity, and the results keep all of our animals safer and healthier every single day. Lead on, Susan, we’ve got you back!

  7. Cheryl

    December 9, 2015 at 7:51 pm

    Thanks once again to all involved with this process. You have all worked so hard. I appreciate each and every update. Be blessed!

  8. Teresa

    December 9, 2015 at 10:49 pm

    As a new member who has been reading here for a while as a concerned pet owner, I applaud you, Susan, for the tireless work you do for our beloved pets. Agree with Nina on everything she said. This is a big step in the right direction and know you will always keep on fighting on our pets’ behalf. Thank you so much.

  9. Pat P.

    December 10, 2015 at 5:50 am

    Susan,
    It is a really a shame that they didn’t include the statement “determined to be safe and functional through valid scientific evidence” and that they added the phrase “unless expressly permitted by the appropriate state or federal agency”–which could include almost anything.

    It seems that unless a pet food states “human grade”, I can’t/won’t even consider feeding it to my pets. It will be interesting to discover how many pet food companies, actually, include that phrase on their labels. I imagine very few. I, also, feel sorry for farm animals that can be fed almost any inappropriate garbage and toxins, and many humans then consume those poor creatures. Of course, I don’t believe in any animal consumption, other than for my cats.

    You worked hard and faced incredible frustrations, but you aren’t a miracle worker, especially, dealing with people who don’t care for animals and just want profits. Considering what you have to work with, you should be proud that you even get them to listen.

    Thanks for all you try to do and have accomplished to protect our pets.

  10. Susan Thixton

    December 10, 2015 at 8:38 am

    Thanks to everyone.

  11. Jane Eagle

    December 10, 2015 at 2:40 pm

    Thank you Susan, and Dr. Jean Hovre, for all your work to protect our loved ones.
    I am currently engaged with my Congressional Rep in regards to violations by the FDA in several areas. I plan to push for de-funding this agency which we pay for and which does virtually NOTHING to protect us.

  12. Michelle

    December 10, 2015 at 3:19 pm

    Thank you Susan for all that you do!

  13. Gypsy

    December 10, 2015 at 11:44 pm

    Just have to thank you for everything you do. You cant even imagine how many people I refer to your website

  14. Janet Velenovsky

    December 17, 2015 at 7:37 pm

    Congratulations and thank you!! These are very important steps toward future definitions that will make us all happier.

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Human Grade & Feed Grade
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