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Minutes from AAFCO Human Grade Meeting

AAFCO just published the minutes from the Pet Food Committee webinar meeting finalizing the requirement of pet food human grade claims. For those that want to understand those requirements for a human grade pet food…

AAFCO just published the minutes from the Pet Food Committee webinar meeting finalizing the requirement of pet food human grade claims. For those that want to understand those requirements for a human grade pet food…

This meeting took place on March 17, 2016 via webinar. The meeting was to finalize and vote (AAFCO members only) on the ‘guidance’ document for pet food human grade claims. The guidance was developed to further explain the legal definition of human grade pet food. As reminder, the approved legal definition of human grade pet food is:

“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.”

In the document posted below, the ‘guidelines’ for pet food human grade claims begins on page 5. To better understand the minutes, you might want to read the guidelines first.

[gview file=”https://truthaboutpetfood.com/wp-content/uploads/2016/03/PFC-Webex-Human-Grade-Minutes-Final-Minutes-3.29.2016kv1284929-1284930.docx”]

 

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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13 Comments

13 Comments

  1. Dianne

    March 31, 2016 at 2:43 pm

    Is there a way to get these minutes from an AAFCO or FDA website? I would like to pass this on, but want to get it from a place that won’t be doubted by the “unbelievers”? Was time about 50/50 for time given specifying the size of the label and the definition?

    • Susan Thixton

      March 31, 2016 at 3:03 pm

      I got these minutes from the AAFCO website – but the back side of the AAFCO website. It is public information for those that have an online subscription to AAFCO’s Official Publication (the AAFCO book of animal feed regulations). While minutes from the big meetings AAFCO has twice a year are public and on the front side (public side) of their website, it doesn’t like like they post these.

  2. Jane Eagle

    March 31, 2016 at 4:05 pm

    Can you clarify something? If a pet food is ““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.”
    then why would it not be safe for humans to eat?? I saw some chicken treats at Costco the other day, made in USA, human grade, NOT FOR HUMAN CONSUMPTION. Why would that be? Thanks.

    • Susan Thixton

      March 31, 2016 at 4:19 pm

      If the label said human grade – it would be/should be suitable for human consumption. The product sounds like it was mislabeled (should not have made the human grade claim). But – there’s a catch…it could be that treat was made with human grade ingredients in a USDA facility under USDA inspection (just like what human meat is required to do/come from), but unless a pet food or treat is made in a FDA inspected human food facility (not USDA) the treat or pet food cannot make the human grade claim. Example of this is raw pet foods and some jerky type treats. Some are 100% human grade, meet every requirement of human food, but they can’t make the pet food human grade claim unless they are made in a human food plant inspected by FDA. FDA has no authority over human grade meats or meat processing facilities, that’s USDA. And USDA won’t get involved in the pet food process (they say that is FDA’s responsibility). So some companies/pet foods might meet the requirement – all but that FDA inspected human food facility part. But unless they meet that last part – they can not/should not make the human grade claim.

      • Dianne

        March 31, 2016 at 4:34 pm

        Looks like another errant video. Maybe some companies should make food for people and label it as suitable for pet consumption. If need be, they could separately manufacture a product that just needs to be added to the suitable for pet consumption food. Actually, not a bad idea for people who are always feeding their pet from the table anyway. This is in no way meant to be a criticism of people who do home preparation, but I can’t come up with an explanation of who I mean.

      • B Dawson

        March 31, 2016 at 7:54 pm

        Either I’m just too tired from all the gardening I did today or I’m missing something here.

        …”can’t make the pet food human grade claim unless they are made in a human food plant inspected by FDA. FDA has no authority over human grade meats or meat processing facilities, that’s USDA. And USDA won’t get involved in the pet food process (they say that is FDA’s responsibility).”…

        So there’s no way a pet food manufacturer can meet the “made in an FDA inspected facility” requirement? Is this something that FDA is going to address? If not, then the new “human grade” designation is pointless and would seem to be nothing more than an attempt to thwart any company making good quality food.

        • Susan Thixton

          March 31, 2016 at 8:49 pm

          It is confusing – I was in on all of these meetings, and it’s still confusing to me. There’s no way a raw pet food – at the moment – can use the human grade claim. That is all because raw meat is USDA’s territory, not FDA’s. FDA has jurisdiction over all pet food, but not raw pet food manufacturing. FDA governs the raw pet food on store shelves, but not its manufacturing (because it is raw meat). Because FDA doesn’t have oversight of the manufacturing, they can’t (won’t) allow raw pet food to be considered human grade. It’s a mess, but they have agreed to bring this back into discussion in the future for raw pet foods.

          • B Dawson

            April 1, 2016 at 10:33 am

            Thanks for letting me know my mind hasn’t completely gone! And thank you for sitting through endless meandering meetings to bring us this information. I keep swearing I’m going to attend just as a warm body to show support, but I’m not sure I could remain mum over some of the abuses you and your team have endured.

            I hope FDA will move quickly to develop their jurisdictional guidelines and allow the raw meat folks to proudly market their food.

          • Jane Eagle

            April 1, 2016 at 11:17 pm

            Thank you for the info..I think! Perhaps if you are at the next meeting, you might clarify for the FDA et al., that to consumers, “human grade” means it is safe for humans to eat. If that is not true of a pet food, it should not say “human grade” on the label.
            This is why I make my own pet food, from ingredients bought at my market, that I can eat.
            I appreciate everyone’s comments; I generally read all.

  3. B Dawson

    March 31, 2016 at 8:32 pm

    Here’s something that bugs me about AAFCO documents. The wording constantly vacillates between the term “feed” and “food”.

    Stan Cook presented information on developing a FEED term for “human grade”.

    The work group developed “FEED grade” and “human grade” FEED terms, yet that work group belongs to the Pet FOOD Committee.

    The “Guidelines for “Human Grade” Claims” says in the first sentence ‘…guidelines for the use of the term “human grade” in the labeling of pet FOODS…’ and then under (1) says “…AAFCO defined FEED term “human grade”. The document continues from there to use the term FEED until (4) when they again revert to FOOD.

    Human Grade Feed. Is this to distinguish it from Human Grade Food so consumers won’t think it’s the newest pate from some celebrity chef? It’s being sold in a pet food store or in the pet food aisle at the grocery. Next to the kitty litter and rawhide. I worry that creating a separate but equal category will only allow the big companies with dollar signs in their eyes to exploit the marketing.

    Either humans can eat it or it’s not human grade food, I mean feed, no wait, food.

  4. Marilyn

    March 31, 2016 at 11:05 pm

    When Wellness Cat Food first came out, it was listed as using ‘human grade ingredients’. I was delighted to find it. Somewhere along the way, I believe the company was sold, my cats refused to eat the kibble. I still feed them the canned variety and they eat it. I now feed them Orijen kibble for breakfast and the Wellness canned for dinner. I was under the impression that if something is labeled “human grade feed/food” that humans can eat it safely. It seems as though this AAFCO meeting has only made confusing statements to mislead the pet owners further and not make a clear statement. Either it’s suitable for humans to eat it or it isn’t. A simple ‘yes’ or ‘no’ would be sufficient. Don’t double talk – just answer the question!!

    • B Dawson

      April 1, 2016 at 11:17 am

      When Wellness first came on the pet food scene in the 60’s they were a small private company owned by Jim Scott. The food was baked in their own kibble plant in Lowell, MA, contained human quality ingredients and was a good product. They were yet another company who swore to remain loyal to the independent pet store and never go into big box stores. Just as with campaign promises, that didn’t last.

      Wellness was bought out by Catterton in the early 2000’s, then almost immediately sold to the Berwind Corporation and is now part of WellPet which also includes EaglePack and Old Mother Hubbard (the company that originally spawned Wellness). I’m working off memory on those dates, but they’re close. Berwind made their fortune in the 1800’s in coal and real estate and is now a diversified holding company. Google them to see what other companies they “hold”. It will clear they see pet food as just another profitable company in their portfolio.

      Years ago, when wholesome pet food was in it’s infancy, many companies used the “human grade” claim on their labels. A few companies got caught in occasional enforcement sweeps – brought on by complaints from competitors I’m sure – and soon the “human grade” claim disappeared from labels to avoid getting crosswise of regulatory agencies. Even sales reps were reluctant to use the words “human grade” in private conversations. Part of the reason was the processing. While the ingredients might be human grade, as soon as they enter a pet food manufacturing plant, they are no longer considered human consumable because of the lack of sanitation among other things. So reps would cover themselves by saying “the ingredients were human grade at slaughter”, or “until they entered the plant”. Obviously not something you can put on a label.

      This is another reason the misleading and outright fraudulent labeling that abounds today is so intolerable. Where’s the enforcement now? Obviously if you’re big enough, you get a free pass. It’s the little guys who always get squeezed. That’s one reason these small companies keep selling themselves to larger ones. How long can you endure biased enforcement before the joy of doing a good job gets sucked right out of you?

      • Marilyn

        April 1, 2016 at 11:43 pm

        Thank you for the info regarding Wellness. What a shame that companies that start out with all of the good intentions about manufacturing a superior pet food, crumble under when money enters the picture.

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