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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…

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,

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

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15 Comments

15 Comments

  1. Pingback: 4D’s in your commercial pet food | Whole Earth Pets

  2. Reader

    April 1, 2013 at 1:09 pm

    I used to think that wet meat for my dog was too rich. Even mixed with dry kibble it gave him messy stools more often than not. This happens when my friend’s mix wet food in with their brands of dry kibble. It’s happened over many past years. When I go back to feeding actual pieces of meat (either raw or minimally cooked) with whole foods my dog’s stools go back to normal. I think the PF companies have becomes masters of making canned food “look” and “smell” decent to humans, but only heaven knows what’s really in that STUFF!!

    • Ellie

      April 2, 2013 at 1:02 am

      I think if you read the ingredient lists of most canned pet food you will have a hard time finding any real nutrition there. Also raw meat or lightly cooked meat is digested much more quickly than kibble. Kibble is hard for pets to digest so mixing raw with kibble will usually result in more difficulty for the dog’s digestive system to work properly as it is trying to dispose of two entirely different food types that digest at different rates.

  3. Peter

    April 1, 2013 at 2:51 pm

    There is an “historical basis” for many ugly and embarrassing aspects of US history: slavery, segregation, discrimination, and disenfranchisement of women from their right to vote come to mind as a notable few to recall. The FDA seems to invoke the same laziness as a framework for government inaction. The FDA should look into securing some public relations advice to filter their commentary. Their response shames any free-thinking citizen.

  4. Alan

    April 1, 2013 at 11:43 pm

    When I first started reading this, I thought it was another April Fools article. I mean “Historical Basis for Illegal Waste?” C’mon, you have to be kidding. Heck, there’s an historical basis for robbing banks, too, but that doesn’t make it okay. (Except in Cyprus.)
    Before I got to the end, though, I knew the only fools were those who believed anything the FDA says. Thanks for all you do for us and the pets we love. But really, Susan, you need to lighten up a bit at least one day a year so you don’t become a grumpy old lady.

    • Reader

      April 2, 2013 at 5:53 pm

      Obviously Susan is perfectly capable of speaking for herself. Therefore it’s only my opinion that she exposes the readers to only one tenth of what she really knows, and shares only some of the horror stories that pet consumers report. Being the communication is day in and day out, it must be a grim business. The only consolation being, the ability to educate and warn pet consumers continuously. Personally I like that Susan has a very consistent,serious journalistic style. It confirms credibility, accuracy and professionalism. I don’t really need to be “entertained” on this site. Though some cute stories are occasionally posted. And, as a side note, I can only hope that Susan’s pet companions provide her with all the well deserved comic relief she needs!!! The Pet Food business is indeed made up of people who are perpetually acting as “fools” year round, with April 1st hardly being any more of an excuse than normal.

  5. Ellie

    April 2, 2013 at 1:10 am

    My grandfather was the manager of a rendering plant many years ago. I remember asking my mom what a rendering plant was. She told me they took the bodies of dead animals and cooked them to make soap. I’m sure it was more complicated than that but that was enough to make me cringe. I never looked at that bar of soap the same way after that! Farmers who who have to put down an old horse or cow used to call the truck to pick up the dead animal as soon as possible to take it to the rendering plant. They would get a small amount of money for the body of the dead animal.
    Now with our modern progress these places can receive the dead bodies of thousands of dogs and cats that have been put down at animal shelters to throw into the goo of dead bodies. Can it get anymore disgusting!? Why would anyone feed their beloved pets this muck?

  6. Pingback: What's Really in Pet Food - Fox Terrier Network

  7. Ruth

    April 4, 2013 at 10:13 am

    Not only have I seen livestock laying out in the extreme heat for over a week before being picked up by the local rendering facility, but I am also aware that most of those animals were showing signs of illness and pumped full of anitbiotics in the days prior to their death. Most of these animals were also sprayed for flies with chemicals and or have eartags in them which go into the grinder with them.

    • Athena

      April 8, 2013 at 4:24 pm

      You are spot-on, Ruth…I’ve seen the videos of dead cows lying in the heat outside of a farm, waiting to be picked up by ‘the truck’…and who knows how many days they’re lying out there with more bodies being added to the heap…and they’re obviously sick, because if they weren’t they would still be in the barn being made to produce whatever it is the humans want from it…so sick and disgusting…I hurt for the way animals are treated…

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