In 2006, the National Research Council published the Nutrient Requirements of Dogs and Cats – of which laws governing pet food will soon be based.  Take a guess who paid for this 2006 report?  Three guesses, first two don’t count.

The National Research Council’s 2006 publication Nutrient Requirements of Dogs and Cats, will soon be the foundation for pet food regulation.  Since its publication, members of AAFCO and FDA have been turning this ‘research’ into soon to be pet food regulation.  Regulation that will determine the protein, fat, calorie and nutrient requirements of all cat and dog foods.

Held in the highest regard by many, the National Research Council (NRC) is depended on to provide unbiased science.  Much of the work published by the NRC becomes legal foundation, such as this 2006 Nutrient Requirements of Dogs and Cats.

But does the NRC truly publish unbiased science?

We (Association for Truth in Pet Food) called the National Academies in search of answers asking who funded the 2006 Nutrient Requirements of Dogs and Cats.  We ultimately were led to the Board of Agriculture and Natural Resources (Division of National Academies/National Research Council directly responsible for publishing the 2006 report).   Katie, in this office, stated the 2006 Nutrient Requirement of Dogs and Cats was funded by the FDA, the National Institute of Health (NIH) and…the Pet Food Institute (PFI).  I asked Katie how much each organization paid to fund this report.  She stated: “I cannot provide that information – this was a privatized contract.”

The NRC considers those that hire the institution to perform a study as “sponsors”. Thus, in this case the NRC entered into a ‘private contract’ between sponsors FDA, NIH and PFI.

Just the beginning of the concerns this FDA, NIH, and PFI sponsored research…

  • “Once a project is funded, the National Academies seek nominees for members of consensus study committees from many sources, including the sponsors.”
  • Sponsors are typically invited to make presentations to the committee at its first couple of meetings to discuss the sponsors’ expectations for the study. Also, the sponsor is asked to provide as much information relevant to the study as possible.”

(Source – Click Here)

Thus, the FDA, NIH and the PFI were allowed to nominate study committee members AND discuss what their expectation is for the study.


Conflict of Interest?

The NRC provides the following statement regarding conflict of interest…

“It is essential that the work of committees of the institution used in the development of reports not be compromised by any significant conflict of interest. For this purpose, the term “conflict of interest” means any financial or other interest which conflicts with the service of the individual because it (1) could significantly impair the individual’s objectivity or (2) could create an unfair competitive advantage for any person or organization.”

Ignoring the requirement that reports – such as the 2006 Nutrient Requirements of Dogs and Cats –  must not “be compromised by any significant conflict of interest”, the 2006 study was partially funded by an organization whose members could certainly benefit from the outcome (the Pet Food Institute and its members).  Further to conflict of interest, below is a partial list of the current Board Members of Agriculture and Natural Resources (division of the National Research Council hired to perform the 2006 Nutrient Requirements of Dogs and Cats study)…

Gail L. Czarnecki-Maulden“senior research nutritionist at Nestle Purina PetCare PTC, where she is responsible for development of innovative nutritional concepts for implementation in pet food products. She helped set nutrient standards for dog and cat foods in the United States by serving on the Association of American Feed Control Officials’ Canine and Feline Nutrition Experts Subcommittee.”

Gary F. Hartnell“a Senior Fellow of the Monsanto Company, St. Louis, Missouri, where he has been employed since 1983. Dr. Hartnell is an expert on the nutritional requirements of food animals. As an animal nutritionist for Monsanto, he is responsible for developing strategies and conducting poultry, livestock and aquaculture studies in the evaluation of genetically modified crops and their co-products for regulatory, industry, and consumer acceptance.”

Gene Hugoson“a Senior Fellow with the Global Initiative for Food Systems Leadership (GIFSL). GIFSL was formed in 2009 by the University of Minnesota in conjunction with Cargill, General Mills and several other major food corporations.”

Robbin S. Johnson“retired from Cargill on January 1, 2007. He now is President of the Cargill Foundation.”

Mercedes Vazquez-Anon – “Director of animal nutrition research at Novus International, a leading developer of animal health and nutrition programs for the food animal industry.”

And it seems we are not the only ones who found conflict of interest issues with the National Research Committee.  In 2006 the Center for Science in the Public Interest published a very concerning report finding “serious breaches” to conflict of interest.

  • “Nearly one out of every five scientists appointed to an NAS panel has direct financial ties to companies or industry groups with a direct stake in the outcome of that study. This consistent pattern of appointing scientists with conflicts of interest clearly violates the spirit of the Federal Advisory Committee Act amendments that apply to NAS.”
  • “NAS did a poor job of balancing points of view on a majority of the study panels  examined. The NAS does not appear to consider information about potential bias or conflicts of interest prior to nominating individuals to a committee.  As a result, about half the panels examined had scientists with identifiable biases who were not offset by scientists with alternative points of view.”
  • “The NAS provides brief biographies of nominees to its committees on the agency’s website. Such biographies could assist people who were considering commenting on a committee’s composition. However, those biographies are woefully inadequate because, in a majority of cases, they fail to provide crucial data regarding conflicts of interest and points of view.”



The nutrient requirements for cats and dogs that was relied upon previous to the 2006 NRC report was published in 1985 and 1986 respectively. The funding for these studies were provided by the FDA, CVM, Department of Health and Human Services, USDA, and the Agriculture Research Service – all government agencies.  Some “additional support” to these earlier studies was provided by Pet Food Institute (dog report) and American Feed Industry Association (cat report).

The Office of Agriculture and Natural Resources told me “additional support” in 1985 and 1986 meant that AFIA and PFI were not sponsors, thus they were not provided with the bonuses of sponsorship (hint: a great deal of influence to the outcome of the study).

But with the 2006 NRC study, the Pet Food Institute became a sponsor of the study which provided the organization with the privileges of sponsorship (the ability to nominate committee members and provide information to the committee).

On the opening page (Overview) of the 2006 Nutrient Requirements for Dogs and Cats we are provided with this telling statement…

“This edition contains the latest data on requirements that are based on the utilization of nutrients in ingredients commonly produced and commercially available in dog and cat foods rather than only on purified diets.”

We asked for clarification from the NRC to the definition of “purified diets”, they did not respond.  To be clear, the NRC responded promptly to all other questions except this one – to define ‘purified diets’.  However we found this definition online…(bold added)…

“Purified diets use refined ingredients such as casein, sucrose, cornstarch, and cellulose. These human food grade ingredients have relatively simple chemical compositions (predominantly one nutrient classification) and this feature is important for manipulating individual nutrients for research purposes.”

Key words – “human food grade ingredients”.

The 1985 and 1986 Nutrient Requirements for Dogs and Cats were based on “purified” human grade ingredients.  The 2006 Nutrient Requirements for Dogs and Cats – partially funded by the lobby organization Pet Food Institute – was not based on human food grade ingredients.  The 2006 NRC report – which will soon become pet food law – is based on the “utilization of nutrients in ingredients commonly produced and commercially available”.  Common ingredients such as genetically modified grains and rendered meat meals including those sourced from 4D animals (dead, diseased, dying, and disabled).


Complete Problem(s)

At the upcoming January 2014 AAFCO Meeting, the Model Bill Committee will receive updated nutrient requirements based on the 2006 NRC report partially funded by the Pet Food Institute – nutrient requirements based on non-human grade ingredients.  When these nutrient requirements finally make it through the AAFCO process, they will become law.  Law that all pet food manufacturers will be bound to – even those using human grade ingredients, and whole foods (not supplements) – IF they wish to state on their pet food label “complete and balanced”.

Complete and Balanced – one size must fit all law.  One set of nutritional requirement law (based on science partially funded by an industry trade group and based on non-human grade ‘commonly produced’ ingredients) for…

  • kibble foods made from heavily processed by-product meal powder meats;
  • canned foods made with rejected for use in human food meats;
  • lightly cooked pet foods sourced from USDA inspected and approved meats/vegetables;
  • raw pet foods sourced from USDA inspected and approved meats/vegetables.

The ‘Complete and Balanced’ pet food statement is (unfortunately) held in the highest regard by most veterinarians and many consumers.  The pet food consumer has been trained (brain washed) over many years to search for this statement on the label.  Sadly, we now know that Complete and Balanced statement is founded on many misgivings.

The legal requirements of the Complete and Balanced statement you see on pet food labels is supposed to protect the consumer and their pet.  But does it?  Does a Complete and Balanced nutritional statement based on what appears to be biased science really protect the consumer and their pet?  Or is it just another way pet food consumers are manipulated and lied to?

The very foundation that commercial pet food nutrient law is based on – new regulations will be based on – is (at best) flawed with bias.  A one size fits all regulatory attitude cannot be the best for all the pets that consume far from ‘commonly produced and commercially available’ ingredient pet foods (human grade ingredient pet foods).

This investigation has been one of the most discouraging things Mollie and I have discovered thus far.  The more we dug into this, the worse it got.  And we’ve only scratched the surface.  We have been consulting with numerous experts and are beginning to plan a strategy that best meets the needs of all pet food consumers that feed their pets human grade foods (all types of human grade pet foods – raw, cooked, can, kibble).  We will keep everyone posted as this progresses.


Wishing you and your pet(s) the best,

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

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