The Other Human Grade Pet Foods

Just because a pet food is not labeled as Human Grade, doesn’t mean it isn’t.

Pet food regulations are not easy to locate (they are not public information as human food laws are), and even if you can find the laws – they are often confusing to read and understand. Not the best combination for pet owners hoping to understand what they are feeding their pet.

Speaking of confusing…is AAFCO’s double standard for the term “ready-to-eat”.

The legal definition of Human Grade pet food:

“Human Grade: Every ingredient and the resulting product are stored, handled, processed, and transported in a manner that is consistent and compliant with regulations for current good manufacturing practices (cGMPs) for human edible foods as specified in 21 CFR (Code of Federal Regulations) Part 117.”

But…the AAFCO Standard for Human Grade pet food includes another requirement that excludes some styles of pet food. See item ‘b’ in the quote below.

“In order to substantiate that a ‘human grade’ pet food claim is truthful and not misleading on products manufactured in an FDA Human Food Facility subject to 21 CFR Part 117, the firm must maintain and make available upon request, documentation sufficient to show that:

a. All individual ingredients supplied to the manufacturer that are further utilized in the manufacture of human grade pet food, are fit for human consumption.
b. Every ingredient and the resulting product are stored, handled, processed, and transported in a manner that is consistent and compliant with 21 CFR part 117 and the final product is considered ready-to-eat;
c. The manufacturing facility is licensed to produce human food by all appropriate/required authorities”

The problem…AAFCO applies the ‘ready-to-eat’ term to a raw pet food as if a human was going to eat it. But ONLY with raw pet food.

In human food, it is a violation of law for retailers to sell raw meat products without Safe Handling labeling such as “Some food products may contain bacteria that could cause illness if the product is mishandled or cooked improperly. For your protection, follow these safe handling instructions.” And it is a violation of law for human food manufacturers to sell a ready-to-eat food that is not properly cooked.

As example, raw chicken sold in your grocery store is required to be labeled with Safe Handling requirements. And cooked chicken sold in your grocery store is required to be cooked to 165F minimum temperature. 

IF AAFCO properly applied human food laws to raw human grade pet food, the ONLY requirement would be the Safe Handling instructions on the label. 

Instead, AAFCO decided to pick out the portion of law they wanted to be applied to these products – the cooking part. AAFCO applied the human food standard of ready-to-eat for humans to one style of pet food. 

Now consider what AAFCO considers ready-to-eat for pets.

AAFCO and all regulatory authorities allow diseased animals and animals that have died other than by slaughter to be processed into pet food through “enforcement discretion” (with no disclosure on the pet food label). Diseased animals and animals that have died other than by slaughter are a direct violation of the Federal Food, Drug and Cosmetic Act in ANY food (human or pet food) – thus the need for enforcement discretion.

Statement from FDA CVM Director Dr. Steven Solomon: “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.”

As absurd as it is…processed diseased animal material is considered by AAFCO and regulatory as “ready-to-eat” because pets are the intended species.

But a raw pet food, as example a raw pet food that is manufactured in a licensed USDA facility, under direct supervision of USDA (exactly the same as human food) is not allowed to make the Human Grade label claim because the product is held to ready-to-eat standards for humans consuming the product, not pets.

Double Standard. With one style of pet food ready-to-eat applies to humans, with all other styles of pet food ready-to-eat applies only to pets.

We sent AAFCO the following message:

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In AAFCO’s Standard for Human Grade pet food, you include the requirement “the final product is considered ready-to-eat”. However, AAFCO is applying the ‘ready-to-eat’ requirement of a pet food as if a human would be eating the product, not taking into account the intended species. 

We are requesting that AAFCO consider that raw pet food is indeed ‘ready-to-eat’ for the intended species. It is bias for the AAFCO Standard to apply the ready-to-eat requirement of a pet food as if a human would be consuming the product. 

Who is the AAFCO’s ready-to-eat for? Pets or people?

We both know there are significant differences to quality of ingredients used in all styles of pet food, that pet owners are provided NO label disclosure to. Everything from “diseased animals and animals that have died otherwise than by slaughter” to USDA inspected and passed are allowed by regulatory into pet food – again, with no label disclosure for consumers. 

Does AAFCO consider cooked diseased animals in pet food ‘ready-to-eat’? You do. Your legal definitions of many ingredients hold no requirement to inspected and passed meats. In these instances AAFCO and regulatory authorities apply the ready-to-eat term to pets consuming the products, not people. 

So how can AAFCO apply the ready-to-eat requirement of raw pet foods – that meet every single requirement of Human Grade – to humans consuming the products (human food ready-to-eat)?

Pet owners want label information to quality of ingredients, quality of manufacturing standards for ALL styles of pet food. AAFCO needs to decide, who are pet food products ready-to-eat for? Either allow all pet food styles that meet the legal definition of Human Grade to be labeled as Human Grade, OR require all styles of pet food to meet ‘ready-to-eat’ requirements of a human (no more condemned material in pet food).

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Raw pet foods are absolutely ready–to-eat. Ready-to-eat for the “intended use as animal food”. Not ready-to-eat human food.

Raw pet foods consisting of 100% human edible ingredients and manufactured per human food safety standards SHOULD be allowed to disclose on their labels human grade quality. Pet food consumers deserve this label information.

Should we receive a response from AAFCO, it will be shared.

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

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