Pet Food Regulations

Our Meeting with FDA

I would give just about anything for all of you to have been a little bird in the window to have witnessed our meeting with FDA. We left feeling at the very least FDA heard the complaints of consumers – they listened – they really listened. It was a good first step. And you might as well have been there listening…because others listened (even took notes) of our entire conversation with FDA.

I had asked FDA to change the name ‘pet food’ (cat food, dog food) to ‘pet feed’ (cat feed, dog feed). My reasoning is…with most pet foods the ingredients are not held to ‘food’ standards, the manufacturing of the pet ‘food’ is not held to food manufacturing standards, as well as transportation of ingredients or warehousing…they are considered ‘feed’ – not food. Consumers deserve to know what they are buying – is it ‘feed’ or ‘food’? – let’s call it what it is. Dr. Dan McChesney and Dr. Bill Burkholder of FDA agree to meet with me, Jan Jarmon of Minnesota Department of Agriculture who is also the chair of AAFCO’s Pet Food Committee joined them – and I asked Dr. Cathy Alinovi (holistic veterinarian), Roxanne Stone of Answers Pet Food, and Dr. Oscar Chavez (veterinary nutritionist) of Just Food for Dogs to join too.

We all sit down and after introductions I explained to the regulatory folks that my concerns were the detective work that consumers are forced to do to discover the quality of the pet food they are purchasing. And compliments of FDA Compliance Policies, the variations of quality of ingredients can be dramatic. FDA listened to everything – and they seemed genuinely understanding to the consumer dilemma. But…

My concern for consumers is – the pet food label isn’t clear to the quality of the ingredient (shows real meat or grilled meat and it could be meat from rejected for use in human food animals). FDA turned that around and said regardless the food is ‘safe’. There was uniform disagreement from us on ‘safe’. How can it be safe it the food is made from rendered animals that have laid out in the sun for days? To which we were told those ‘food ingredients’ were processed to a level to be safe – killing all bacteria (rendering). Our response – but how can this be safe if rendered ingredients such as these animals that have laid out in the sun for days are ONLY allowed in animal food? If this process was so safe…why isn’t a commercial human food being made like this to cheaply feed the masses of hungry people? FDA responded – because it probably wouldn’t taste very good.

This back and forth went…back and forth. They listened – we listened. They did have an answer to just about everything – which I can’t say we always agreed with – but for the most part we each understood the challenges of the other. Except with my issues of the consumer being misled. They never quite believed the consumer was actually facing that much of a challenge to find a quality pet food. So…impromptu survey.

I got up from the table (the others were still talking) and the only people I could see that were not AAFCO related were the employees of the hotel working behind the desk. I walked over and asked if any of them had a pet. Two did. I asked them for just a couple minutes of their time – can I ask them some questions? They agreed and followed me back to the table to our regulatory meeting.

I asked…do you buy your pet food from a pet store or grocery store?

They both responded yes.

Me: Does the pet food have pictures of ingredients on the front of the bag?

They both responded yes.

Me: Do you believe those pictures of ingredients on the bag are what the pet food is made from?

They both responded yes.

Me: How would you feel if you learned it wasn’t? How would you feel if you learned those pictures which showed chicken breasts on the pet food bag were wrong – and that actually the pet food contained dead chickens rejected for use in human food that sat out in the sun for 3 days before they were pushed by a bull dozer into a big pit along with a couple of bloated dead horses along with some used restaurant grease?

One had to go back to the desk…the other said “I’d be mad”.

This was exactly my point. Consumers are mad – and they don’t deserve to be treated this way and regulators need to do something about it.

The meeting turned to…FDA telling us they probably are not going to be able to clearly clarify the grade of ingredients (feed or food) on pet foods for consumers. The regulatory water is very muddy – there is federal law and state law (50 different states all with different laws!) that would have to be addressed. But perhaps there was another way. They suggested we (consumers) do something similar to the Non-GMO project, where Association for Truth in Pet Food would raise the bar one more level on our Pledge to Quality and Origin by certifying the Pledge – verifying the information on the Pledge for consumers. We – consumers – could make happen what we need with transparency and honesty with pet food by giving pet foods our consumer ‘seal of approval’ if they meet our transparency and quality requirements. And – this part is huge – FDA said they would commit to working with us on this project.

There is a great deal to be worked out – but I can tell you we left the meeting feeling this was a good beginning. FDA heard us and even provided us with an option/method to make happen what we/consumers deserve to have happen.

One last thing on this meeting with FDA. During almost the entire meeting – we had two people actively listening to our entire meeting. One was texting updates to someone the entire time – another (who turned out to be with the renderers association) was listening on the other end of our meeting table and even asked me a question when it was over. There was even another that I caught taking a picture of us all. Our little meeting was more than a little meeting to some – ‘they’ were listening. I’m sure ‘they’ didn’t like what they heard.


Wishing you and your pet(s) the best,

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

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July 27, 2014

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15 COMMENTS ON THIS POST To “Our Meeting with FDA”

  1. Thank you so much for your diligence Susan! It sounds like you really made some headway with the FDA! I hope those few certainly were listening. It is exciting news. Let’s see where it goes. I am looking forward to updates on this subject.

  2. Susan Mercer says:

    Thank you for making these huge efforts on behalf of pet consumers and our lovely babies. Also, I am extremely grateful that you report back to us on what is happening. Hopefully this was a step forward in our fight for transparency and better quality food.

  3. Carol North says:

    Thank you, Susan Thixton, for your diligence on the subject of pet food safety. I write a blog,, and often refer to, and quote your work in my own writing. Your work at this AAFCO meeting is certainly helpful and enlightening for the rest of us consumers.

  4. Laura says:

    What did the representative of the renderer’s association ask you?

  5. Kelley says:

    The FDA may be “late to the table” (in terms of doubting consumers are challenged about choosing PF) but nevertheless the table has been “set.”

    Obviously the PFI is well ahead of them witness the success of the BB advertising campaign. For consumer’s thoughts to be articulated in the media (such as how owners are being duped by big brand names, and want to treat a pet like family) is HUGE. Because it’s finally being recognized that buyers have “some” level of discretionary intelligence!

    The business of Advertising doesn’t just take a bright silver box off the shelf and say, oh hey let’s try this approach. The market is evaluated to identify purchasing trends. Surveys are taken to understand why people make choices. They develop a campaign strategy to target their client’s product. And do focus group testing to make sure the message is effective! Their biggest goal is simply, will people remember the product?

    Your hotel workers only confirmed what the Industry ALREADY recognizes as the future! Which is, consumer awareness, in step with people who are more health conscience in general. Now this doesn’t mean the PFI is going to reform entirely (until they are forced to) but they will expand product price points accordingly. The secret door to the PFI’s evolution (isn’t about forcing them into compliance) but for them to discover what the market will support. As I’ve mentioned before, the industry can’t promote (what we would expect to be) the highest quality PF ever, without them being left with the problem of explaining why ALL products aren’t! Apparently, market research wise, there must be a ceiling to what pet owners are willing to pay for PF currently …. AT LEAST … (and here’s where our Association comes into play) there is a greater educational outreach, including more revelation of existing status, and putting more control into “Truth in Advertising!” Those are very, very big factors.

    This is encouraging though. Because the Consumer Advocacy work being done (particularly) during this meeting, is pushing in the exact direction that’s needed. Painfully tedious yes, but monumental change is always cumbersome.

    No doubt “interested” parties are taking careful notes!!! Could it be that the Association for Truth in Pet Food has even more impact … than was ever expected?? (Wink!)

  6. Karen Davis says:

    Thank you Susan for your informative report. As you and your readers know, the pet food industry is a dumping ground for millions of tons of chickens and other farmed animals who died prematurely (before slaughter) of undiagnosed diseases, along with slaughter parts too evil, diseased and slimy even to be hidden in sausages, patties and other processed human food products. TV ads increasingly target people who love their pets and they are being encouraged indirectly by these ads and directly in other advertising to want to eat the same types and gigantic amounts of meat protein as their sedentary dog or cat is said to require. There are three grades: human food, pet food (“feed”), and livestock & poultry feed. Anything that can be artificially made to smell, taste and look appetizing will go into pet food and farmed animal rations (and into human food too), because all of the animal “waste,” byproducts, excess, etc. has to go SOMEWHERE. What better way to recycle a lot of it than into people’s dogs and cats. The current advertisements proclaiming the MEAT in pet food products signals how much of it there is to dispose of. Again, thank you.
    Karen Davis, PhD, President, United Poultry Concerns

  7. Lori S. says:

    This is seriously encouraging. You are really making a difference. You should be very proud. This gives me hope.

  8. Judy B says:

    I am glad y’all are involved in holding manufacturers to task. Their only concern is profit and if the “feed” is not regulated, they will not do what is morally right. I recently had to discard two bags of food because it was infested with moth eggs and those eggs were hatching. I wondered if the infestation occurred at the Pet Store or the manufacturer. An employee at the store said they had to throw out food all the time due to this problem.

    My other gripe is the addition of GMO in pet foods. I have two cats that experienced allergic dermatitis due to foods. I had to switch them to grain-free as a result. After all these years, we are now seeing allergies and now a rise in grain-free pet food. This cannot be a coincidence and with this evidence, they’ve approved GMO for human consumption?!? Our pets are being used for testing purposes without our permission.

  9. Peter says:

    You are correct to ask the questions that you did. Exaggerating the contents of a prepared food on the package is a marketing practice that is accepted by consumers. The best examples are frozen foods that appear on the box very carefully arranged in a studio photo, perhaps even “photoshopped,” and we don’t really react indignantly when the stuff inside doesn’t look much like that when we empty it onto our plates. Some of that is the result of automated processing. There is a difference, however, in the way that pet food manufacturers take effort to openly deceive consumers (such as the issue of “grilled chicken” you recently discussed here). In the case of the former, the package represents an “idealized” image of the food product. Pet foods, however, misrepresent what the ingredients are, in a dishonest way that is intended not only to convey an image, but to deceive about the ingredients.

  10. Donna says:

    If regulatory waters are “muddy”, it should not matter if there are federal and 50 different state laws. Those regulatory issues should be addressed and clarified.

    As far as the packaging and advertising of these pet foods – this is an issue that could be addressed. Packaging and advertising used to be photos of dogs/cats and the actual kibble or canned product. Now these photos are delicious looking meats, veggies and fruits. It presents a picture in the consumer’s mind that is nothing short of misleading. In the human food market it is false advertising. Why not with pet foods? Even advertising slogans are misleading.

    I am thankful you have a voice with FDA and AAFCO. I am thrilled that you were resourceful and pulled two employees from the hotel to give non-biased responses to questions.

    We have a long way to go. Thank you for your work, Susan.

  11. Donna says:

    (Quoting from above) Rendered animals that have laid in the sun for days …. “probably wouldn’t taste very good.”

    This is why we have the industry of palatants – correct? They put palatants on pet foods in order to make them “taste” good to the pet otherwise they would not eat the food.

    What they do to pets is no more than sustaining industries from financial loss by using meats and other ingredients that are “not good” for human consumption. The pretty pictures on the pet food packages are misleading and should be illegal. But then a dead horse and dead chickens in the field would not look as good on the bag of kibble. It really makes one wonder what are we really eating if there are permissible levels of toxins allowed and substances used in roofing tiles are used in foods.

  12. terri janson says:

    Yes, thank you Susan for all your hard work! You are an angel!

  13. Sandra Barbier says:

    The idea of GMO-like certification is wonderful. I support it totally. I’ve been researching dog and cat foods for more than a year now and it is very frustrating. I imagine there will be tremendous backlash from the industry, so good luck, and thank you for all your work.

  14. Ellie says:

    Pet food companies have been making a huge profit by turning garbage into “pet food” for many years. It is a gold mine for people with no ethics. They are not going to be easily convinced that they need to mend their ways. I’m sure they were listening and preparing ways to prevent any changes being made.
    The FDA has worked with these people for a long time. Up until now there has been no formidable adversary to challenge them.
    There is obviously good reason for these companies to hide their manufacturing processes from the public. To call their methods “false advertizing” would a generous description of what has been going on. The FDA is complicit in this conspiracy. Consumers buy a product that is totally misrepresented with the full knowledge of the government agency that is supposed to represent the consumer. They function with the tax dollars of the American citizens.
    I’m sure that people would be mad if they found out the truth about pet food but I wonder if it would change their buying habits. They continue to buy unhealthy food for themselves so would they stand up to an industry that is slowly poisoning their pets?Personally I think many would. Many pet owners think of their pets as they would a child and feel a great need to protect them. The information must be made public in a big way with veterinarians and scientists that will refute the misinformation of the pet food industry..

    • Kelley says:

      In agreement.

      Food for thought: How many decades did it take to convince people that smoking causes cancer? Now at least we’re left with the subset of the population who realizes that it does, but still subscribe to the addiction anyway. How many decades did it take MADD to convince people not to drive and drink? Now it’s no longer socially acceptable to do so. In the above cases there were organizations and lawsuits dedicated to proving those points. Regarding the PFI there is just one consumer advocate, and those of us who support her. What we need are more studies showing the origins of cancer in pets. You know, like testing one group of dogs fed commercial, and one group fed the nutritional equivalent of fresh whole food diets? It seems like a no-brainer doesn’t it? Except that pets in the world of science pet animals are still considered the equivalent of livestock. Remember the PF we feed now was based upon the formula for livestock feed, meant only to ~ sustain ~ the animal until its term life expectancy, which is unfortunately in agricultural terms, a very short period of time indeed!

      When will the PFI get it? And what will it take … to make them get it??

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Susan Thixton, Dr. Cathy Alinovi, Mollie Morrissette and Dr. Jean Hofve.

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Susan Thixton's author is a founding partner of the international pet food consumer association - Association for Truth in Pet Food. Through our consumer association, Susan has advisory position to AAFCO's Pet Food Committee and Ingredient Definitions Committee.