Historical Basis for Illegal Waste in Pet Food
Over many years, whenever I’ve asked the FDA about rendered waste (illegal waste) ingredients in pet foods, the response has always been ‘science’. I’ve been told time and time again, ‘FDA is science based’. So, I asked for the science that proves pet food ingredients sourced from illegal horrendous waste provides quality nutrition for pets. And here’s the FDA’s response…
“You asked specifically about the nutritional quality of rendered materials and whether FDA has any evidence to conclude that these materials are a quality source of nutrition for dogs and cats.
There is a historical basis for the use of these ingredients. Rendering of poultry and other animal tissues has been used for over a hundred years as a means of salvaging valuable protein and fat. Please see http://www.fda.gov/ICECI/ComplianceManuals/CompliancePolicyGuidanceManual/ucm074717.htm for more information.
All rendered animals are subject to certain regulatory standards (i.e., the animal or tissues derived from these animals must be undecomposed; not contain toxins or chemical substances that may cause the feed product to be considered adulterated under section 402 of the FD&C Act; and must be processed in way that ensures the elimination of harmful microorganisms, such as by heating during rendering or canning).
The Association of American Feed Control Officials (AAFCO) provides specific definitions for products from rendering in the AAFCO Official Publication, and many of these definitions include requirements for guarantees for specific nutrients, and some include requirements for tests that indirectly assess digestibility.
There is no FDA requirement for pet foods to be nutritionally complete in order to be marketed. Many states have adopted the model pet food regulations established by AAFCO. These regulations include labeling aspects such as the guaranteed analysis, the nutritional adequacy statement, feeding directions, and calorie statements.”
And interestingly – the subject line of the FDA’s email responding to my nutritional value of rendered ingredients said: “Response on 4D materials”. “4D” by the way is industry language for ‘Dead, Diseased, Dying, and Disabled animals’.
So – there is No science to prove that rendered waste provides quality nutrition for pets. The federal agency that claims ‘we are science based’ has no science to prove that rendered waste provides any quality nutrition to the animals that consume it. They only have ‘history’ – 100 years of history.
100 years ago the Wright Brothers made the first flight in a heavier-than-air aircraft. Since then we’ve walked on the moon.
100 years ago spiral-bound notebooks were invented. Today ‘notebooks’ don’t include paper and can ‘talk’ to someone across the globe.
100 years ago rendered wastes from the processing of human foods didn’t include a slew of antibiotics, steroids, pesticides, heavy metal contaminants and hormones. Today they do.
Rendered wastes in pet food have been illegal since 1938 (with the enactment of the Food Drug and Cosmetic Act). Every day that has passed since, the FDA has enabled pet food/animal food manufacturers to violate federal law (through FDA Compliance Policies).
C’mon FDA, join the modern world.
FDA said: “All rendered animals are subject to certain regulatory standards (i.e., the animal or tissues derived from these animals must be undecomposed; not contain toxins or chemical substances…” It is virtually impossible for 4D animals used in rendered pet food ingredients to be undecomposed. Livestock animals die in the field and often days pass before they are sent to rendering facilities. That farmer did not store the dead cow in a freezer waiting for the renderer to pick up the animal. Rendering company trucks are not refrigerated. And FDA’s statement the rendered pet food ingredients cannot contain toxins or chemical substances is inaccurate – and FDA knows this. FDA’s own testing found dog foods to contain pentobarbital – a drug used to euthanize animals (can’t get more toxic than that).
And lastly, the FDA tries to allude responsibility by stating “There is no FDA requirement for pet foods to be nutritionally complete in order to be marketed.” They try to push the blame on AAFCO/the states. Sorry FDA, the responsibility lies with you. FDA Compliance policies – and ONLY FDA Compliance policies allow pet foods to violate federal food safety law. It’s wrong and you know it.
To avoid rendered ingredients in your pet’s food, avoid the ingredients by-product meal, meat and bone meal, animal fat and animal digest – FDA’s own testing found these ingredients most likely to contain a euthanized animal.
To learn more about FDA Compliance Policies that allow pet foods to violate federal law, Click Here
Wishing you and your pet(s) the best,
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