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The new argument on Menadione Sodium Bisulfite Complex

Somebody who regulates pet food did the right thing; prohibited is prohibited.

Somebody who regulates pet food did the right thing; prohibited is prohibited.

Menadione Sodium Bisulfite is a commonly used pet food supplement – a synthetic source of vitamin K. This supplement has been used for years in cat and dog foods…as it turns out…illegally.

The supplement Menadione Sodium Bisulfite is ONLY approved for use in poultry feed. Menadione Sodium Bisulfite has NEVER been proven safe for use in cat foods or dog foods. No supplement supplier has ever bothered to provide regulatory authorities scientific evidence to the safety of this supplement for pets, no pet food manufacturer that uses this supplement has ever bothered to provide regulatory authorities scientific evidence to the safety of this supplement in cat and dog foods. For years (and years) regulatory authorities have just looked the other way, allowing this supplement to be used in pet food when it had never been proven safe for cats and dogs.

That is, until recently. One state Feed Official (I don’t know which state that is or who the Feed Official is) has taken a close look at the AAFCO regulations and is enforcing them (instead of looking the other way). Per a post from Dr. David Dzanis in PetFoodIndustry.comRecently, though, at least one state feed control official has taken action against any pet product containing MSBC (menadione sodium bisulfite complex). This is because the listing of MSBC in the AAFCO Official Publication makes reference to poultry only. As the state interprets its animal feed regulations, any other use is strictly prohibited.”

This particular Feed Official is absolutely right. From the AAFCO rule book:

The AAFCO Official Publication states Menadione sodium bisulfite is ONLY approved for use in feed for poultry. It’s been there all along – for any pet food regulatory authority to see, for any pet food manufacturer to see. Until recently, everyone just ignored the rules.

Concerned about the safety of this ingredient, in 2011 TruthaboutPetFood.com emailed the Chair of the AAFCO Pet Food Committee. This was her response regarding Menadione sodium bisulfite:

“Menadione sodium bisulfite complex is the only acceptable source of Vitamin K in pet foods.  At this time, no other sources of Vitamin K are allowed in pet food including natural Vitamin K and K1 (phylloquinone).  If you have additional questions regarding vitamins, please contact Ali Kashani, who is AAFCO’s Vitamin Investigator.
I hope this answers your question,

Regards,

Liz Higgins
Chair, AAFCO PFC”

And in 2011, we did ask Mr. Ali Kashani AAFCO’s Vitamin Investigator as the Pet Food Committee Chair advised. This was his response:

“Good morning Susan,

In order for ingredients to be considered safe and effective for their intended use, data need to be submitted and reviewed, unless one of other conditions like generally recognized safe (GRAS) and or prior history of safety use have been determined.  Menadione or Menadione sodium bisulfite complex has a GRAS status for use in poultry feed at 2 to 4 g per ton of feed (Federal Register 55:50777, December 10, 1990).  States and FDA have given low regulatory priority for use of the above vitamin as source of vitamin K in other species’ feeds including pet food.

I believe Liz’s reference was to pure sources of vitamin K.  If you have ingredients that contain natural sources of vitamin K in their composition, as long as the methods of analyses are legitimate and can be verified, I believe the manufacturer can list it in the guaranteed analysis section of the label, as long as they meet other requirements (units of the vitamin, etc.).

I hope the above explanation adequately addresses your questions.  Please let me know if I can provide any additional explanation.  Best Regards!  Ali”

So…for years regulatory authorities have been fully aware that menadione sodium bisulfite was NOT approved for use in cat foods or dog foods and AAFCO even encouraged manufacturers to use an ingredient that was NOT approved for use in pet food. Up till now, all agreed to just look the other way (“low regulatory priority“). No one questioned the safety of this ingredient for cats and dogs, no one cared.

Until now.

Personal opinion: I want to thank the individual(s) that finally enforced law. What you did couldn’t have been easy, standing up against all other authorities that considered this issue “low regulatory priority“. Standing up against the many pet food manufacturers that have been illegally using this supplement couldn’t be easy either. You did the right thing. Thank you.

I hope this one State stands their ground on this pet food supplement. I hope all the other State Feed Officials realize that rules are rules. The common practice of ‘low regulatory priority’ (in other words selective enforcement) is detrimental to pet food safety and detrimental to consumer trust of pet foods and regulatory authorities.

I encourage pet owners to write their State’s Feed Officials and ask them to stop selective enforcement of law. Law must be enforced – as it is written, not as the pet food industry wants it to be interpreted. To find your State Feed Official, Click Here and click on your state.

Wishing you and your pet(s) the best,

Susan Thixton
Pet Food Safety Advocate
TruthaboutPetFood.com
Association for Truth in Pet Food


Become a member of our pet food consumer Association. Association for Truth in Pet Food is a a stakeholder organization representing the voice of pet food consumers at AAFCO and with FDA. Your membership helps representatives attend meetings and voice consumer concerns with regulatory authorities. Click Here to learn more.

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18 Comments

18 Comments

  1. Chris Javier

    April 21, 2020 at 2:13 pm

    Yes, a big thank you to whoever it was that stood up for what was right, and what was in the safety of all.

  2. Krista

    April 21, 2020 at 2:16 pm

    Thanks Susan for once again sharing some great info with all of us. Yes, kudos to that one Feed Official who did the right thing in speaking up against illegal use of ingredients in our pets’ food. It’s so refreshing that there are people ready and willing to do the right thing. Let’s hope this is the first of many!

    Appreciate everything you do!

  3. Debbie

    April 21, 2020 at 2:31 pm

    Ali uses the words ” I BELIEVE the manufacturer can list it in the guaranteed analysis section”…. is horrible. She doesn’t even know herself. What’s wrong with these people?!!

    • T Allen

      April 22, 2020 at 10:04 am

      That’s what happens in a corrupt organization. People are more worried about keeping their jobs then doing a good job and keeping the boss happy (the “boss” that is a political appointee and who at best is clueless and at worst is under orders to tear apart the organization!). Besides which, after decades of operation by people like this, no one knows how to do their jobs properly. They just follow the motto, “Do it the way it’s always been done”. 🙁

  4. Dianne & Pets

    April 21, 2020 at 4:16 pm

    What steps can be taken to help this person keep their job

  5. Brian

    April 21, 2020 at 9:50 pm

    Can you give us some text to copy and paste? Few of us write as well as you do, and more people would send emails to their officials if they had a few paragraphs already written and ready to send. Thank you Susan.

    • Susan Thixton

      April 22, 2020 at 11:02 am

      Hi Brian –
      How’s this:
      I was recently made aware of another selective enforcement concern in pet food. While your agency might have a different perspective, I look at selective enforcement as a way for regulatory authorities to allow pet food manufacturers to violate law. Why have laws if they are not enforced? I am a concerned pet owner asking your agency to enforce pet food laws as they are written, everyday – every pet food. Please stop allowing illegal ingredients in pet food. Enforce the law.

      • Brian

        April 22, 2020 at 12:04 pm

        Email sent! Thanks!

        • Susan Thixton

          April 22, 2020 at 12:21 pm

          Thank you!

  6. Brian

    April 22, 2020 at 10:58 am

    Hi Susan, Please give us a few paragraphs to copy and paste. Most people won’t write a letter but will copy/paste an email to our elected officials. This will help flood our politicians’ inboxes to try to get them to take action.

    • Susan Thixton

      April 22, 2020 at 11:09 am

      For an elected official:
      I was recently made aware of more selective enforcement concerns in pet food. FDA and State Department of Agriculture have allowed for years ingredients in pet foods that were never proven safe for pet food. These ingredients violate federal and state laws – yet not one regulatory authority takes any action. They call it “selective enforcement”. I call it illegal pet food. Why are laws written if our regulators are allowed to ignore them? In April of 2019, in response to a Citizen Petition, the FDA stated “we do not believe that the use of diseased animals or animals that died otherwise than by slaughter to make animal food poses a safety concern and we intend to continue to exercise enforcement discretion where appropriate”. Pet food ingredients sourced from diseased animals or non-slaughtered animals is a direct violation of the Federal Food Drug and Cosmetic Act. Why is FDA allowed to “believe” these ingredients are safe when law defines them as “adulterated”? Please investigate the many concerning selective enforcement practices of FDA’s Center for Veterinary Medicine.

      • Brian

        April 22, 2020 at 12:18 pm

        Email sent to both of my US Senators!

  7. Carol Hughes

    September 30, 2020 at 4:09 pm

    I don’t know what is meant by “enforced” in this article. The can of Hill’s prescription Kidney Care, k/d Pate with chicken I am holding in my hand, purchased this week, lists Menadione Sodium Bisulfite Complex as an ingredient. Perhaps what was meant by “enforced” was “brought to the attention of” someone. 2020-09-30

  8. Lynn

    September 11, 2021 at 8:03 am

    Found your article this week – my cat has had repeated bladder issues and chicken seems to really upset his system i.e. urinary issues – he ended up blocked. I’ve changed his diet now to something at least label wise is free of it – it’s a process – but I find he still avoids poultry i.e. chicken seems the worst perhaps because chickens are fed the problem ingredient and then it’s also added to the cat food as well, I think so.
    He doesn’t seemed thrilled with duck either but turkey as of yet as long as it’s just occasional seems ok but then he doesn’t really eat the food just licks the juice/gravy off of it – thinking all poultry must go. Seems like they scrub so much information especially now. Per an FDA article dated April 2021 they still use a variation of menadione – Menadione dimethylpyrimidinol bisulfite and menadione nicotinamide bisulfite are vitamin K active substances that are regulated as food additives for use in animal feed. Federal regulation 21 CFR 573.620 lays out how menadione dimethylpyrimidinol bisulfite must be used in feed. Menadione dimethylpyrimidinol bisulfite is a nutritional supplement for the prevention of vitamin K deficiency in chicken and turkey feeds at a level not to exceed 2 g per ton of complete feed, and in the feed of growing and finishing swine at a level not to exceed 10 g per ton of complete feed. Pretty sure these may be no better overall and foods being sold still contain the complex ingredient, they have not been pulled from the shelves – let the buyer beware. Factory food not good for us or pets. Pet food industry is huge, so money and politics like everything else. Not sure they’re interested too much in what is or isn’t in pet food, they are more focused on global experiments.

  9. Steve Lunetta

    March 24, 2023 at 11:39 am

    I always find it interesting that people see the word “synthetic” and automatically think “toxic”. Many of the things around you as well as the things you eat are “synthetic” and you are not keeling over dead. But I digress.

    Here is what you need to know about Vit K. Animals do not produce Vit K. They must consume it in their diet (ah,yes, before I get jumped on, microbes in the animal gut convert K1 and K3 into bioavailable K2). What this means is that PET FOOD MUST CONTAIN VIT K.

    Menadione (K3)(and its various salt forms) provides that supplementation. Has it been banned in human foods? Yup. Because we learned back in the 1960’s is that high doses create all kinds of problems in humans. BUT, remember that we humans are an omnivorous bunch. We eat many things and can get the Vit K we need from our diet. Not so with pets. That is why AAFCO exists (the industry regulator for pet foods) which sets nutritional standards for pets like yours.

    Is Menadione toxic? At incredibly high levels, yes. But, at normal feeding levels seen in pet foods (which are exponentially lower than the toxic levels), there is negligible risk. Think I’m lying? Read the 2021/3 AAFCO Official Publication pp 336-342 and you can read all of the toxicology studies that were performed. Sorry about the year confusion. In 2023, it may be on a different page but hunt around for it, its there.

    The MAIN RISK IN VIT K IS DEFICIENCY, NOT EXCESS INGESTION. If you want to kill your pet, deprive it of Vit K. For most pets, this means using a food that contains Menadione.

    Oh- and the vets, scientists, and techs at AAFCO say one more thing;
    “Menadione Sodium Bisulfite Complex may be used as a safe and
    suitable source of Vitamin K” (ibid)

    Look, if you choose to believe alarmist websites, that’s up to you. But, common sense, science, and animal health care experts say otherwise.

    Am I an industry wonk? Yup, and proud of it. I’ve been in the industry many years. If you want more information, please email me at slunetta63@yahoo.com.

    • Susan Thixton

      March 24, 2023 at 12:40 pm

      So…if you are as you claim “an industry wonk” – then do you confirm that AAFCO has NOT approved menadione sodium bisulfite for cat foods and dog foods? Is someone being an “alarmist” notifying pet owners an ingredient is only approved for poultry feed not cat and dog food?

  10. Charles Sabo

    March 29, 2023 at 9:12 pm

    My daughter’s cat suffered kidney failure two weeks ago, which seemed sudden, but she may have had her problems earlier than what seemed extreme at the end. I have researched cat food ingredients and found that her entire life she was eating cat food (Purina, Iams, and Meow Mix) which all used Menadione Sodium Bisulfite as their Vitamin k supplement. From what has been disclosed here online, this horrible K3 substitute causes organ failure in cats and dogs. Shopping for cat foods that do not use this is difficult, as maybe 80% of the cat food market has this deadly ingredient. People need to protest and boycott the brands and mixes that use this very deadly chemical.

    • Steve Lunetta

      March 30, 2023 at 1:22 pm

      Charles- so sorry for your loss. I am still getting over the loss of Mango, our orange tabby who sat in my lap every night for 9 years.

      Unfortunately, I can’t agree with your conclusion. I’ll bet you’ll find many similar ingredients between those 3 companies. Do you have any references for your assertion on the toxicity of this menadione salt? Because, as stated above, AAFCO did a review of all the data available and concluded that it is safe for use in pet food.

      Again, Vit K deficiency is far more dangerous to your pet than excessive amounts. That is the simple truth.

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