“Dehydrated Garbage” and Other (absurd) Legal Feed Ingredients

The truth of animal feed ingredients IS stranger than fiction.

Through a non-legal agreement with FDA, the Association of American Feed Control Officials (AAFCO) defines all pet food/animal feed ingredients. Every single ingredient used in a pet food/treat or animal feed is VERY different than it’s counterpart in human food, many don’t have a counterpart in human food. Because this agreement denies public access to these ingredient definitions (AAFCO charging $120.00 per year), the public doesn’t get to see the absurd legally defined ingredients approved to be fed to animals – approved by FDA and State Department of Agriculture members of AAFCO.

In the year 2000 – the AAFCO book of pet food/animal feed ingredient definitions included the ingredient:

“Dehydrated Garbage”

In 2000 – “Dehydrated Garbage” was allowed to be included in any feed. Because the ingredient definition was/is copyright protected by AAFCO – allowed to be copyright protected by FDA agreement – the full definition of “Dehydrated Garbage” cannot be shared. Our interpretation of the ingredient definition is: dried animal and/or vegetable waste.

In the current AAFCO book (2019), the same ingredient has been renamed. Today, Dehydrated Garbage is termed “Food Processing Waste“. And AAFCO has added two more food waste ingredients: “Restaurant Food Waste” and “Recovered Retail Food“. These pet food/animal feed ingredient names are descriptive of their definitions – they are recycled garbage sourced from just about anywhere.

What the poop?

2019 AAFCO and FDA pet food/animal feed ingredient definitions include an entire category of Animal Waste Products. This group includes the legal definition of various…processed…animal poop definitions, such as:

• “Dried Poultry Waste”
• “Dried Poultry Litter”
• “Dried Ruminant Waste”
• “Dried Swine Waste”
• “Undried Processed Animal Waste Products”
• “Processed Animal Waste Derivative”

To be clear, all of the above ingredients ARE animal poop – and all have been approved by FDA as “food” for animals.

Dust

Under the AAFCO category of ingredients of Screenings, is the legally defined pet food/animal feed definition “Chaff and/or Dust“. Chaff – per Wikipedia – is “the dry, scaly protective casings of the seeds of cereal grain“. Dust – per the AAFCO definition is…well, anything swept up from the floor including dirt and sand.

Plastic

Within the AAFCO category of ingredients Special Purpose Products, we find the legal definition of “Polyethylene Roughage Replacement“. Polyethylene is “the most popular plastic in the world. This is the polymer that makes grocery bags, shampoo bottles, children’s toys, and even bullet proof vests.” A ‘roughage’ is fiber (in this case a plastic being used as fiber in an animals diet).

Breakfast Cereal, Doughnuts and Candy

FDA has approved the pet food/animal feed ingredient definitions of “Cereal Food Fines“, “Dried Bakery Product“, and “Sugar Foods By-Product“. These definitions are recycled breakfast cereals, recycled or expired/moldy breads or cakes or doughnuts, and recycled candy.

Hair and Feathers

And FDA has even approved the pet food/animal feed ingredients of “Hydrolyzed Hair” and “Hydrolyzed Poultry Feathers“. These ingredients are – cooked hair and feathers.

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It is doubtful that any pet food will include “Restaurant Food Waste” or “Sugar Foods By-Product” – but they could because they are legally defined ingredients of animal feed. The exception would be any Human Grade pet food (with the words “Human Grade” printed on the label). NONE of these ingredients would be allowed in the door of a plant manufacturing a human grade pet food (which is required to meet the same standards as human food – no recycled poop allowed).

These ingredients ARE being fed to livestock animals that become human food and pet food, with the exception of livestock that meet the certification standards of humanely raised.

Besides these blatantly horrendous feed ingredients, there are thousands more – more that are allowed into pet food that violate food law. And again, those ingredient definitions – significant for pet owners to read and understand – are NOT public information.

Our consumer association (AssociationforTruthinPetFood.com) began (officially) discussion with FDA about consumers being denied public access to pet food/animal feed ingredient definitions since January 2019. The agreement between FDA and AAFCO that allows AAFCO to control these definitions (and sell them for profit) was set to expire at the end of October 2019. We began communication with FDA 10 months in advance as this is such a significant issue for pet owners, we didn’t want the agreement to be renewed without consumer input. After weeks of broken promises to speak with us, FDA renewed the agreement with AAFCO without giving consumer representatives a voice in the renewal – without altering the agreement to make all pet food/animal feed ingredient definitions public information.

It’s significant to share a portion of FDA’s September 20, 2019 response to us – this particular quote regarding the Agency’s belief of what food is (bold added for emphasis):

The Federal Food, Drug, and Cosmetic Act (the Act), section 201(f), defines the term “food” to mean “(1) articles used for food or drink for man or other animals, (2) chewing gum, and (3) articles used for components of any such article.” 21 U.S.C. § 321(f). Any feed ingredient found in the AAFCO Official Publication that meets this definition is considered “food” under the Act.

In other words – the FDA chooses to believe that the Federal Food Drug and Cosmetic Act condones the use of recycled garbage, poop, plastic, and hair in “food”. This is completely FALSE. In fact, federal law clearly and concisely classifies this waste as an adulterant of food – and illegal. Perhaps this is exactly why FDA works so hard to keep pet food/animal feed ingredient definitions out of public view; if more people knew adulterated pet foods/animal feeds are sold every day in the U.S., they wouldn’t be able to get away with their crimes.

We continue our discussion with FDA on this issue (even though our requests are falling on deaf ears).

Personal Opinion: All involved in the approval of these ingredients and the many waste ingredients allowed in pet food should be served the waste for dinner…every night…for years.

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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