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Pet Food Regulations

Notes from AAFCO Meeting January 2018

Another meeting. More drama and frustration. Some potential pet food label changes for your review.

Another meeting. More drama and frustration. Some potential pet food label changes for your review.

FDA was not in attendance at this meeting; the government shutdown prevented their attendance in person – however they were in attendance via webinar/phone for meetings Tuesday January 23.

I was also informed that the Hyatt (hotel the event was hosted at) had security in the back of the room – assumed to be related to the potential threat that prevented the attendance of several from this meeting. Kudos to the Hyatt for taking these precautions.

Mr. B.C. Henchen did attend the meeting on behalf of AssociationforTruthinPetFood.com. His first meeting as advisor lands him into an AAFCO working group that wishes to change pet food ingredient names, during the Ingredient Definitions Committee session.

It was shared at the last meeting (August 2017) that industry requested name changes of ingredients that consumers have a poor opinion of. AAFCO used the term “villain ingredients”. No mention of which ingredients those are, but we can all safety guess they are ingredients such as by-products (in the past industry has stated they would like to change the name to “co-products”). Mr. George Ferguson of North Carolina Department of Agriculture spoke for several minutes chastising AAFCO for using the term “villain“. It was determined to now call the ‘villain’ “ingredients of confusion”.

Yes…’they’ believe we (consumers) are confused. They believe the ONLY reason consumers don’t accept with open arms feed grade by-products – such as condemned animal material or material from a dead non-slaughtered animal – is because ‘some’ have misled consumers to believe that recycled waste is inferior nutrition. They believe consumers have been so misled…they must change ingredient names to protect consumers. (Honestly…they believe this.)

We will have to wait to hear what the working group decides on the ‘ingredients of confusion’.

The other meeting of interest to consumers was the Pet Food Committee meeting.

During the Pet Food Committee meeting was the concerning proposal to change the definition of human grade pet food – lowering the standard required of human grade pet foods. Myself, Mollie Morrissette, Dr. Jean Hofve and Dr. Cathy Alinovi (representing human grade manufacturers) all posted comments on the back side of the AAFCO website in opposition to the proposed changes. And many consumers sent emails to all the voting members of the Pet Food Committee in opposition to the proposed changes. When this discussion started in the Pet Food Committee meeting session, it seemed as if some of the voting members had already made up their minds on how they would vote. Mr. Stan Cook – Missouri Department of Agriculture/AAFCO President/Pet Food Committee co-chair – and Ms. Kristen Green – Kentucky Department of Agriculture/Pet Food Committee co-chair – made statements in complete favor of the proposed changes. As consumers and consumer representatives expressed opposition to the proposed changes, it was disheartening that these two AAFCO officials clearly did not ‘hear’ consumer voices.

Things looked grim…and then a miracle happened. Someone from the audience went to the microphone and addressed the committee. He stated he had 30+ years experience working with USDA. In no uncertain terms, this individual told the Pet Food Committee they cannot make these changes. Just as we (consumers and advocates) had told the committee, this individual told them a ‘human grade’ food with more than 3% meat must be manufactured under USDA inspection. He reminded the committee that law requires this. He reminded the committee that FDA and USDA can and must work together on human grade pet foods. This unknown individual was awesome!

AAFCO quickly ended the discussion and agreed that a working group must be formed for further discussion. It was/is a concern that individuals to volunteer for this working group was not allowed to be discussed. We most definitely need our representative B.C. Henschen to be part of that working group. Fingers crossed. This topic will be discussed again, probably at the next public AAFCO meeting (end of July 2018). As more is learned, it will be shared. But for now, human grade pet foods remain as is…a true pet ‘food’ – abiding by all ‘food’ law.

 

The last hour of the Pet Food Committee meeting was providing updates to the work of the Pet Food Label Modernization working group. (I participated in this group up until I was dismissed by AAFCO November 2017).

The following images were shared at the meeting as examples only. No decisions have been made, nothing is final – everything remains in discussion.

To explain the above…

In the green box is the consideration of how to list ingredients. This potential ingredient listing is grouping ingredients – though they will still be required to be listed in order of weight (pre-cooking). Notice there is a “Contains 2% or Less of” section.

Pet food labels are considering using a nutrition facts box similar to that of human food. The goal is for the nutrition facts box to replace the current Guaranteed Analysis on pet food labels. It is unknown if the nutrients displayed in the nutrition facts box image above (those below Moisture) will be the nutrients required to be displayed. One thing consumers did want from pet food labels – carbohydrate information – is provided in the nutrition facts box. Notice the 3rd section from the top – “Calories Per Cup…” Under that line is calorie content obtained from protein, fat, and carbohydrates.

The next change discussed was the complete and balanced seal you see above in the middle of the image. The working group decided that the seal would be required to be placed in a similar location on all pet foods, easy for the consumer to see. All complete and balanced pet foods would be a round seal, treats would be a square seal, and veterinary pet food products to be a octagon shaped seal. All seals will be white background, black lettering. And there will be variations to each depending on the intended use (adult, puppy, kitten…). Below are a few more examples of seals.

Also from the above proposed changes, consideration is being given to including ‘safe handling instructions’ for all pet foods. Several spoke out against the requirement for safe handling instructions on kibble or canned, Chelsea Kent of Hero’s Pets (pet store) provided information that kibble pet foods indeed should require safe handling instructions per FDA data of many kibble recalls due to bacterial contamination.

Here is an example provided of a pet food label (including front, sides, and back panel)…

Here is an example provided of a treat label…

Here is an example provided of a prescription pet food label…

And here is an example provided of a small can pet food label…

Note with the small can label, the small size of the label prevents placement of the nutrition facts box. It was explained that the information from the box IS included on the label, but not in ‘box’ form.

AAFCO stated that they intend to survey “3,000 consumers” in the future for comment on these label changes. But I would like to know your sentiments on the above label changes. Do these potential label changes provide information that you want or need from a pet food label? You can provide those in comments below.

The next AAFCO meeting will be end of July/early August.

 

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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The 2018 List
Susan’s List of trusted pet foods. Click Here to learn more.

 

Have you read Buyer Beware?  Click Here

Cooking pet food made easy, Dinner PAWsible

Find Healthy Pet Foods in Your Area Click Here

 

32 Comments

32 Comments

  1. Donna C

    January 24, 2018 at 2:44 pm

    sounds like this group is well on their way to a career in politics

  2. Dan Bilancio

    January 24, 2018 at 2:52 pm

    The most important ingredients that the consumer should know, should be in bold type.

    • Cheryl Mallon-Bond

      January 31, 2018 at 8:27 pm

      I second that!

  3. Fred St Clair

    January 24, 2018 at 2:55 pm

    Unfortunately our government is bought and paid for by the large corporations. I really don’t think they believe consumers are confused, they just want to make more money, and one way to do that is change the definitions we know. I wish I knew what we could do to change things, but I am at a loss.

  4. Rebekah R Page

    January 24, 2018 at 2:56 pm

    The ingredient label; Was that just an incomplete label I read corn twice in the first 4 ingredients, are we feeding this to a cow??
    Carnivores eat meat, Herbivores eat vegetation. My cats go out and hunt feathered and small furry creatures, never have I seen one drag an ear of corn home…
    Also I see nothing about Taurine or Carnitine and bare minimum for vitamins and minerals.
    Love the ‘COMPLETE and balanced diet’ to make the unaware consumer feel safe and get complacent.
    Hope to hear back from you, and thank you for sharing!!!

    • Susan Thixton

      January 24, 2018 at 3:18 pm

      It is just an example label – nothing is real. It was just used as an example for the proposed label display updates.

  5. Janet W Velenovsky

    January 24, 2018 at 3:05 pm

    Bless all of you for the wonderful work you have done and continue to do. And thanks to the masked crusader who came in to support the truth!!

  6. Peter

    January 24, 2018 at 3:20 pm

    The statement of “complete/balanced” is meaningless to me and would be so to anyone (such as readers of this site) who has a meager understanding of how AAFCO operates, what their goals are, and how manufacturers gain their “stamp of approval” (AAFCO definitions of “ingredients,” how foods are “tested,” etc.).

    Consumers need information on carbohydrates, but we already know that AAFCO deems that information of no need or use to consumers, so they discourage manufacturers from listing it on labels.

  7. Dianna

    January 24, 2018 at 4:08 pm

    Glad you were able to stay safe and that an angel stepped in on our behalf. Win/win!

  8. Lee

    January 24, 2018 at 4:19 pm

    SO SAD IT IS ALL ABOUT THE MONEY NOT THE PETS, LIVES

    • Teresa Johnson

      January 25, 2018 at 12:44 pm

      And one would think companies would want to make the best quality food and keep “customers” (pets) healthy and long lived assuring more purchases. After all, deceased pets don’t consume much food!
      Or maybe I’m just not of a good logical business mind?!

  9. Jackie Earnshaw, CPDT-KA

    January 24, 2018 at 4:25 pm

    The proposed changes look like improvements. I’m not an expert on nutrition but am always learning. (So much to know!) I do like the idea of clearly labeling “Complete and Balanced” or “Supplemental” or “Veterinary Diet”, though I don’t like that term, not sure how else to specify special diets. This topic deserves a great deal of thought.

  10. Jackie Earnshaw, CPDT-KA

    January 24, 2018 at 4:27 pm

    As an addendum to my earlier post, “Complete and Balanced”, according to AAFCO, is basically meaningless, so while I think these proposed changes are a set in the right direction, it is a baby step.

  11. MrsK

    January 24, 2018 at 4:48 pm

    Thank you once again for all your hard work! You all rock.

  12. Pet Owner

    January 24, 2018 at 6:12 pm

    Thank you for the updates.

  13. Sandra

    January 24, 2018 at 7:33 pm

    Thank you for caring about TRUTH

  14. T Allen

    January 24, 2018 at 8:40 pm

    Cracks me up every time these Corps and groups change their name or product names or ingredient names. Monsanto et al can merge or call themselves whatever they want, we know who they are. So re: Monsanto, we now pay extra attention to avoiding all Bayer products. Thanks to the Internet it is a quick Google search to get answers. What do they think will show up when someone Googles “co-product ingredient”? “Used to be called by-products until consumers got smart and figured out what kind of garbage it was.” See TruthaboutPetFood.com. Thanks Susan!

  15. T Allen

    January 24, 2018 at 8:46 pm

    In regards to the label. I’d like to see the percentage of carbs vs the amount of calories. I really don’t care about the calories because I feed to maintain the desired weight. I can figure out the percentage of carbohydrates now but it would be a lot easier if it was listed. I realize the reason it is not given in percent is people would see just how much is in the product. Thanks to Rodney and others people don’t have to calculate, they just look at the ingredient list!

  16. landsharkinnc

    January 25, 2018 at 6:33 am

    I like the concept of the changes in the labeling — especially the ‘nutrition’ box as it is on most ‘human’ foods; this won’t change the content of the ingredients however — a 4D cow is still a 4D cow … that must still be addressed —

  17. Bernadette Postle

    January 25, 2018 at 7:27 am

    “Keep this product out of reach of infants and small children” This makes the food sound toxic. I wonder if people will call poison control if their child should consume this food.

    • T Allen

      January 26, 2018 at 2:25 pm

      A more important question might be “should they?” If it’s on there they should and should e asking why as well!

  18. Fiona

    January 25, 2018 at 8:58 am

    The label is better but still not what I’d like to see. Most consumers don’t even know how to read a human label much less a dog food label. The inclusion of “carbs” is much better but it’s under presented. If AAFCO is going to mimmic a human nutrition label, they need to follow suit…which they haven’t done. It still reads like a “Guaranteed Analysis”, which most consumers do not understand.

  19. Janet

    January 25, 2018 at 9:51 am

    In the facts box, the percentage of carbohydrates should be listed under Nutrients with protein, fat, fiber, and moisture. Fat is listed on 2 lines, with a minimum and a maximum line. However no other nutrient has both a minimum and a maximum line. There should be a maximum for carbohydrate.

    I see that the amount of calories includes carbohydrates, fats, and proteins, which is a step in the right direction. But if carbohydrates are the majority of calories, that should come first..

  20. Janet

    January 25, 2018 at 9:55 am

    On packages, in the guaranteed amounts section, I’ve seen a value for Ash, with no explanation of what Ash is. Was there any discussion of including or eliminating the Ash information?

  21. Michele Little

    January 25, 2018 at 11:38 am

    It would be great if the label could be in English only. I can’t read 1/2 of the labels on an antacid because there are 4 languages of instructions.
    Good job, keep it up, you’re on our prayer list.

  22. Marjorie Blaine

    January 25, 2018 at 11:54 am

    The “Pet Nutrition Facts” should actually be called “Food Nutrient Analysis” and should be required to be either the “as-fed” or “dry matter basis” values. Currently, to get this information from most pet food companies, one has to call them and hope they will provide it. Before I made the switch to a raw, balanced diet for my cats, my policy was to never feed my cats a food that the pet food manufacturer refused to provide me with the as feds or DMB values….no matter if the food was actually human grade or not. This information is really important to know for pets that’s have specific illnesses….for example, diabetes. Thank you all for all you do!

  23. Teresa Johnson

    January 25, 2018 at 12:34 pm

    I have to agree with Peter about “complete and balanced”. For us humans a pizza containing meat, cheese and veggies could be marketed as complete and balanced (it would contain all food groups recommended daily) but I doubt sincerely that many of us confused consumers would make it our regular or only food source. And I wonder if a food is “complete and balanced” why the additional labels breaking down groups such as pregnant & nursing, etc. Diesn’t that negate the idea that one brand’s food line is complete and balanced from the beginning.
    I like the idea of the nutrition box info – easy to read and understand, calorie & carb info is helpful for folks like myself who feed a food labeled and marketed for one species to another species. Specifically, I care for rescued pet African hedgehogs, insectivores in the wild, but as pet companions we feed high quality cat and/kitten foods. Having that easier to read nutrition box would make like much less complicated when dealing with some special needs hedgies…and I’m betting for cat caregivers too!
    Off my soapbox, done preachin’ to the choir.
    Glad the meeting had been safe for attendees and thank you, Susan, for remaining so vigilant.

  24. Janice

    January 26, 2018 at 9:14 am

    In addition to calories per cup, I favor retaining kcals/kg, which I believe is more precise. Also, for those companies who are transparent enough to provide a complete nutrient analysis on their websites, a statement to this effect would be helpful. “Complete and balanced” isn’t enough. There are products that make this claim because according to AAFCO requirements they are complete and balanced, but according to the NRC guidelines some of their nutrient ratios are not correct. Who knows what damage this can do over time? So I would like somehow to encourage companies to provide a complete nutrient analysis so consumers can decide whether or not the food is adequately balanced for their pets.

  25. Leslie Rosenbloom

    January 26, 2018 at 3:27 pm

    I would like to see Carbs, Ash, Calcium, and Phosphorous %’s on the label. I work at a pet food store and these few things are one of the biggest numbers I look for on the packages. Either for Large breed puppies, or figuring out how ” Quality” (loosely) the meat is. I like that the Carbs should be listed as a Maximum!

  26. Ed

    January 30, 2018 at 10:27 pm

    I must say I’m confused. I may be missing something but saying that “human grade” pet food will lose its continuous inspection under USDA, if the definition is changed, makes no sense. While human food requires products that are comprised of more than 3% meat to be under constant USDA inspection… and the way the “human grade” pet food definition reads, this should be the same for “human grade” pet food, USDA does not inspect pet food. Even products manufactured under the Certified Pet Food program (USDA) are not considered fit for human consumption. With this, wouldn’t that mean that changing the current “human grade” definition would not actually change the way these products are inspected? They already aren’t inspected. Again, if pet food is not inspected by USDA right now, how would changing the definition stop inspections? While the meat (chicken) itself may be USDA inspected in some pet foods, “human grade” also states, “all ingredients in the product must be human edible and the product must be manufactured, packed and held in accordance with federal regulations in 21 CFR 110, Current Good Manufacturing Practice in Manufacturing, Packing, or Holding Human Food.” From reading that, having USDA inspected chicken means nothing if the other ingredients AND the manufacturing process is not up to human foods standards. Given that USDA does not inspect pet food… there is no way (right now) for pet food that is comprised of more than 3% meat to be “manufactured” just like human food (because human food comprised of more than 3% meat is under constant inspection). This sounds like a USDA regulation change, to include the inspection of pet food, would be required to truly meet the “human grade” pet food definition that is currently in place. My question to those that feed only “human grade” pet food, do you ask the company for proof or simply trust what they are telling you? Do you ask for their human food facility license(s)? Do you ask for letters stating their ingredients hold human edible status? Do you ask for documentation to prove they are manufacturing products “in accordance with federal regulations in 21 CFR 110”?

  27. Kelley

    February 1, 2018 at 11:39 am

    Your’s is such a long, complicated comment, it took awhile to respond, because I had to pull it apart. First, there are so few examples of truly (certified) “human grade” PF, it would seem easy and under the radar, for this change in definition to sneak by. However “The Honest Kitchen” worked exceptionally hard, for a very long time, to establish their reputation as such. (To new or casual readers) this doesn’t mean the food is applicable to a human diet. But is made up of quality ingredients equal to those found in “human grade” products. I am presuming their percentage of protein is about 3% (as I only use the Base) but if so, being “human grade” quality is a critical criteria.

    And that’s the really the point. Protein, if not USDA Inspected and PASSED (for human consumption) is the most important part of (continuing) scrutiny. That means toxic, cancerous, crappy meat isn’t (and can’t be) going into Dog Food, as is now the case. And no, cooking canned meat PF, doesn’t solve the problem, see the discussion about “endotoxins.”

    Long story short, the problem with shifting the criteria, as Susan’s very detailed article really explains, is making it so manufacturers (never truly interested in “human grade” food for pets, such as THK) will be able to skirt the line, and use the claim on packaging “Human Grade” …. Pet Food. And consumers who don’t know TAPF exists, will obviously jump to the wrong conclusion.

    In terms of attention, cost, and process, I’ve always believed that labeling is what matters. Because some owners will always choose to feed, what they believe is food good enough for animals (as in “feed”). But the rest of consumers want to know, or should learn, what options are better than feed. And there could be degrees, as long as the protein is safe!! Human Grade (protein) MUST continue to be reserved as an absolute truth.

    Your actual question: do you (or when do you) even ask for proof, just doesn’t even function in the food industry, no matter how broad, and totally depends on what the manufacturer chooses to offer. I think THK would be willing, because they’ve gone to so much trouble to be certified. But even a company like Campbells Soup … would we ever really know how perfect every piece of chicken is, going into millions of tons of product. I think their only goal (as is most food manufacturers) is to avoid an outright, deadly illness. No inspection process could possible have “eyes” on the system 24/7-365. But then, that’s just my personal cynicism!!

    • T Allen

      February 1, 2018 at 2:04 pm

      Well said. And as someone who has worked for USDA/FSIS I can assure you it’s not the number of “eyes on the system” but but the mouths that aren’t duct taped shut by management who only care about money. You can ask all the questions you want but you will get lies and platitudes from the ignorant people answering the phones. Illness and the courts are the only way we will actually know the quality of foods unless someone forms a third party organization to do testing on pet foods. That will take some big money with some big guns behind it due to the issues Susan has run into already. “We the people” have the power to help make this happen!

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