Pet Food Regulations

This is So Wrong

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 – myself and Mollie Morrissette) 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…(drum roll please)…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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September 14, 2013

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20 COMMENTS ON THIS POST To “This is So Wrong”

  1. MarciaH says:

    This is dreadful, and sadly just one more example of the corporatization absolutely EVERYTHING. Fortunately, for my dog, I home prepare her meals, so personally this will not affect me. I do dog boarding in a very affluent area and am constantly shocked by the poor quality kibble my clients feed their dogs. Dogs they apparently care enough about to board them with me. The public is already brainwashed. Now it will only get worse for our pets.

  2. Brit says:

    Well I think this is the final kick in the butt to switch my cats to a 100% raw diet.

  3. Lori S. says:

    This is very important journalism. Thank you for doing it.

  4. Joanne Bates says:

    I sure applaud your fight for the health of all pets. I have lost several to bad health and do realize how detrimental poor quality pet food had a huge part of my pets declining health. Pets are no different than humans for quality food. I have done my own share of research on probably all pet food ingredients,including Vet. so called Prescription Diets. I have read reviews by many including Breed specific, Vet. websites, forums. I do think to be in complete control it is time NOW to somehow inform ALL the pet people about what is in the food we continue to feed our pets. Most do not know the ingredients and where they come from nor all the additives. I would love to see a MASS SURVEY done with questions showing concerns and opinions filled out by consumers and their comments on ALL the poor quality brands.This could be a start of Companies that produce substandard food see that people mean business. I also suggest that once educated on ingreedients, recalls that EVERYONE simply stop purchasing these products. To me this is the only way there will every be a change that benefits the pets. I would suspect that would not leave many products on shelves anywhere. These companies really need to be exposed. With NO SALES for their crap products my guess is they will become non-existant. After all it is the public who keeps them in business. Perhaps to start a Demonstration would be in order. It would get the attention of all who care. Do it across Canada and USA for starters. Once out there it will grow.I wish I could shut these guys down that market this what they call food for pets. I may just email each and everyone of them and let them know from my research that many people have not good things to say. What would it be like if we fed our children sub-standard food. Must admit alot of people are no aware what is even in their food. Every wonder why Dr.’s offices and Hospitals are so full of unhealthy people. Sayng stands YOU ARE WHAT YOU EAT.

  5. Audree Berg says:

    Thank you for continuing to do this important reporting.

  6. Athena says:

    I am absolutely sickened by this…thank you so much for keeping us informed…you do absolutely incredible work!

  7. Marge Mullen says:

    Forget trying to influence the government. They have circled their vested interest wagons, denied the dangers, and ignored the solutions. We have to take protection upon ourselves.

    Excellent work Susan and crew!!

  8. Kenneth says:

    Beautiful work Susan, I find this very distressing, but not surprising. I have long known that neither the FDA nor the USDA can be expected to advocate for anyone but the people they regulate. I find this as ridiculous as including both coal and oil industry executives to investigate the causes of global warming. Sadly, the general public is unable to rely on their governments to provide safe and efficacious products. The consolidation of large industry which has taken place over the last 40 years has formed monstrous companies with billions of dollars. That clout has made most regulation a joke; there is so much corruption in ours, and the rest of the worlds, governments that it is like a Hollywood set: all a front. What I see happening, for those pet owners that truly care, is a movement to raw feeding. It is really one of the last ways we can control what our furry children eat. I am a huge supporter of that movement, but I do know that there is tremendous pressure to discourage the switch. Between the drug companies, most veterinarians, the pet food industry, the cereal grain giants and the government agencies, I find little hope our pets will enjoy a life free of man-made illnesses and healthy years.
    You are the best, Susan. keep the faith and your courage!

  9. Susan Thixton says:

    I want everyone to know that the above investigation was done by Mollie Morrissette and myself. This couldn’t have been done without Mollie (her research abilities are unbelievable!). So please – thanks go to her too. Her site

  10. Nina Wolf says:

    Horrifying. What is being regulated here, except our access to companies other than Big Pet Food? Who is being protected with this “science”, except Big Pet Food?

    This article is tremendous. Very well done, Susan and Mollie, and although it is angering and frustrating, it can only be seen as a rally cry to action.

    Lead us forward…we all stand poised to topple this pseudo-scientific regime that does so much harm every single day. They poison our pets, not figuratively but literally, day in and day out and pass themselves off as nutritional experts, ending up on industry leading panels and committees.

    Can you imagine if the committee had been made up of Susan, Mollie, a rep from Answers Pet Food, Honest Kitchen, Rad Cat, maybe Dr, Karen Becker, and some friends of TAPF? Now THERE wold be consumer and animal advocates!

  11. CSollersa says:

    Another example of big business running the country.

  12. lynn says:

    all the more reason to keep research of balance homemade diets for our fur kids. i will never stop making my fur babies food ever.BUT! we have to watch what we buy in human grade too!!! i am thinking of buying chicken to raise but no way could i kill them for food but i do give my fur kids eggs in home made food so the eggs i would be sure of home the chickens are fed. i do get rabbit meat for them a friend raisedd them and i do not kill but it is good meat for the fur kids in treats as well as food once a week. also a friend rases chicken for meat i buy from her. so i do know what they get in the way of their meat and summer veggies NO gmo seed ever. and go to earthfare for the veggies in the winter months.this is very upsetting but has been for a very long time onlt to get worse . we need to feed our fur babies real food and put these dog food companies out of business and for cat’s too. you can grow veggies and your own fish too even from the basement in the winter months. kibble trees do not grow and therfore are bad dry food is so bad no matter what they say.fresh food for man and animal is best.we can’t live on potato chips that is how i feel about pet food .

  13. Yvonne McGehee says:

    I wonder whether the previous 1985/1986 NRC guides were actually based entirely in human grade ingredients. Or if they were necessarily very good ingredients. Cornstarch, cellulose etc are not great dog food ingredients even if human grade; though I suppose if exclusively human grade ingredients were used for all the research the past NRC guides were based on, that would be better, but less representative than, the actual marginal ingredients used by Big Pet Food. But, how do you have human grade by-product meal for example? Or, did the past research not use things like by-product meal? “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.”

    “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.” Clearly it does mean that the recent guide will be based on the ingredients big pet food finds easy and cheap to use and not exclusively on purified human grade ingredients. But I don’t know that it means that all the ingredients of all past research for the past NRC guides were purified human grade ingredients.

  14. Victoria says:

    Thank you and Mollie very much for this investigative report.

    I bought the expensive report in 2007 and was sure I now was in posession of the best book on animal nutrition ever published.

    Fortunately I already had been feeding raw for years, so it didn´t influence my pets´ health in any way.

    What a fraud this is once again. And shame on those “scientists” who sell themthelves to the pet industry!

    Good health for your pets

    Victoria with momentarily 4 pets, all fed raw for at least 10 years and all in good health

  15. Tammy Scott says:

    The same corruption in pet food is also effecting human food – It makes absolutely no sense to quit feeding your dog commercial food containing genetically modified corn only to feed him a raw chicken that was fed the same genetically modified corn – geez some things in life really are that obvious. Why don;t we address the real issue = governmental corruption.

  16. Susan,

    Wonderful work. But while we can all sit around and say tsk tsk and how dreadful – what can we do about it? Shouldn’t we be focused on getting things changed rather than just uncovering their dirty little secrets? When, as a consumer fraud attorney I wanted to get attention on a particular issue – I took it to the media. Also – California has a fairly powerful law under Business and Professions Code 17200 that speaks to these very issues – and then there is the Federal Trade Commission who has the granddaddy of laws under Section 5 that prohibits any kind of misleading advertising or promulgation of misleading information. We need to find some powerful and influential supporters/advocates who are willing and able to move these issues into the public spotlight. Only the court of public opinion gets things done quickly. This is not a criticism of yours and Molly’s efforts – simply an effort to get everyone focused on solving the problem rather than just reporting it. With your excellent work Susan I see great opportunities to make changes in our lifetime.

  17. Victoria says:


    aside from the fact that you can buy biologically produced meat, fruit and vegetables for your pets, it is still a big difference to me if I feed my carnivores highly processed junk food with practically no protein in it, but instead poisoned with dozens of additives.

    Of course food for human purposes can be trashful, but I wouldn´t want to live on canfood like many pets are condemned to all their lives.

    All of my pets are oldies: My oldest pet,cat Carlos, is more than nineteen years old and my shepherd dog Laika will be twelve next year. I don´t think they´d become that old if they had been fed commercial food.

    Good health to all

  18. Sharon says:

    This is awful. I can only hope my large breed puppy reaches 2 years of age before this “law” goes into effect since the AAFCO calcium “guideline” is way too high. I spent weeks pouring over research on the relationship between bone disease and puppy food. Independent analysis of a study on large breed puppies calls for nearly half of the AAFCO minimum (and God help you when you have to feed more than one cup per meal – you better start a fund now to pay your orthopedic vet later).

    It looks like I’ll be researching how to prepare a balanced raw food diet a lot sooner than I expected that limits calcium content.

    It’s a real shame we can’t get behind these regulators – if only they’d do the right thing. I hope none of them share their homes with pets of any sort.

  19. Jon87 says:

    Excellent research. Thank you Susan and Mollie for your great work.
    These regulators definitely don’t have any kind of contact with pets, they couldn’t do the things that they do if they had a pet in their life.

  20. Mona says:

    Love the article.. Please refer me to a website or place where I can get recipes for homemade dog food..

    Thanks so much.. Mona

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