Inexcusable Pet Food Ingredient Definitions

What was first assumed as an AAFCO oversight, now appears to be nothing close to oversight. A pet food ingredient – sourced from a horrific animal practice – is allowed and hidden from consumers due to regulations from AAFCO. Please note – this post is not for the faint of heart, it contains some haunting information.

At least a year ago, I brought to the attention of the American Association of Feed Control Officials (AAFCO) that pet food meat ingredient definitions are not consistent; some include the requirement of a slaughtered animal – others do not. The example ‘meat’ such as beef is required within the legal definition to be sourced from a slaughtered animal. But ‘chicken’ is NOT required to be sourced from a slaughtered animal. I was told by AAFCO the organization would update these ingredient definitions. However a year later, not one ingredient definition has changed, and I’ve got a good guess why.

Thanks to a tip, I put two and two together. There is a very suspicious reason as to why the pet food ingredient ‘chicken’ is not required to be sourced from a slaughtered animal. That reason is the common practice of culling baby male chickens and spent layer hens by a macerator. The birds are ground alive (they are not slaughtered). As explained to me, the end product is sold to pet food as ‘chicken’ and/or ‘chicken meal’.

Public record of this horrific practice was easily found. Discovery.com explained the practice known as chick culling. “Sometimes you see something that makes your jaw drop and stuns you into silence, which is quickly followed by outrage. Everyone who eats eggs should know about this and watch this video (also below). It’s not bloody or gory, but shows a bunch of very adorable fuzzy chicks dropping into a machine that the narrator explains grinds them up alive.” This post states that an estimated “200 million male chicks per year” are ground alive.

The Animal Welfare Foundation of Canada has published a report on “The Disposal of Spent Laying Hens”. This document outlines the accepted methods of slaughter for spent laying hens, but explains “The disposal of spent laying hens raises issues that do not neatly fit into the list of accepted means of slaughter.” One of the methods this document states is used to kill spent birds is “Macerator“. Quoting: “A macerator for use on-farm has been developed by Oleet Processors in Regina, Saskatchewan. Their unit ‘vacuums’ birds down a 20 foot long tube, to a grinder that kills the birds upon impact with its blades. While the system shows potential, some questions remain to be answered regarding its humaneness.”

Putting two and two together, I now believe AAFCO intentionally excluded the requirement of slaughter from the pet food ingredients chicken and chicken meal (poultry and poultry meal). If the requirement of sourced from a slaughtered animal was added to the legal definition of chicken/poultry – pet foods would legally not be allowed to use non-slaughtered poultry (ground alive).

[one_half]Pet Food Ingredient[/one_half][one_half_last]Legal Requirement[/one_half_last]

[one_half]Chicken/Poultry[/one_half][one_half_last]NOT Required to be sourced from a slaughtered animal[/one_half_last]

[one_half]Chicken Meal/Poultry Meal[/one_half][one_half_last]NOT Required to be sourced from a slaughtered animal[/one_half_last]

[one_half]Chicken By-Product Meal/Poultry By-Product Meal[/one_half][one_half_last]Required to be sourced from a slaughtered animal[/one_half_last]

Unlike the ingredient chicken or chicken meal, chicken by-product meal definition is required to be sourced from slaughtered animals. By-products are leftover pieces of chicken not typically consumed in human food. The ONLY source for these pieces is from slaughter facilities. So – regulations require ‘sourced from slaughtered animals’ in the legal definition of the ingredient chicken by-product meal.

How very convenient that ingredient definitions are so skillfully crafted.

The following letter was sent to AAFCO (AAFCO President and the co-directors of the Pet Food Committee)…

Over the last several days thanks to inside information provided to me, I believe I’ve put two and two together as to why AAFCO ingredient definitions are what I once believed to be inconsistent. If you recall, I brought to AAFCO’s attention more than a year ago that meat ingredients were inconsistent with their requirement of being sourced from a slaughtered animal. Some ingredient definitions required ‘slaughter’, others did not.

Information provided to me was regarding the source of chicken/poultry in pet food. I learned that culled chicks and culled spent laying hens are ground alive (macerator) – and this end product is sold to pet food as ingredients ‘chicken’ and ‘chicken meal’. Fitting perfectly into this horrific practice, is AAFCO ingredient definitions. Both the ingredients ‘Poultry’  and ‘Poultry Meal’ do not hold the requirement of being sourced from a slaughtered animal. The very same ingredients I brought to your attention more than a year ago for their inconsistent definitions, happen to provide industry a regulatory open door to sell ground alive birds as common pet food ingredients – without disclosing the true source of chicken to the consumer.

I now believe that what I gave AAFCO the benefit of the doubt for as being inconsistent ingredient definitions – just a simple error – was not an error after all. I wonder why AAFCO  wasn’t upfront with me more than a year ago? Back then, the simple AAFCO response could have been ‘The meat ingredients that do not include the requirement of slaughter can include culled birds or animals that have died other than by slaughter’. However by your response that these ingredient definitions will be corrected, and then not corrected – it causes me to question who AAFCO is protecting?

I have an on-going concern that AAFCO is too tightly connected with industry. At my first AAFCO meeting, the open discussion was what to name an ingredient that consisted of expired grocery foods – the example discussed was expired Hot Pockets. The AAFCO member publicly stated “we have to name it something the consumer will buy”. It is understood as to why industry would want to keep secrets from consumers – Ground Alive Chicken Pet Food wouldn’t sell well. It is not understood as to why AAFCO would assist industry in hiding these secrets. Ingredient definitions should be clear and provide consumers with full disclosure to the source of that ingredient (sourced from slaughtered animals or ground alive animals or expired Hot Pockets).

Pet food consumers deserve to know what they are feeding their pet. If the chicken is sourced from culled day old baby chicks or spent laying hens ground alive, consumers deserve to know. I ask that AAFCO stop aiding industry in hiding the secrets of pet food/animal feed. I ask that AAFCO develop regulations that require the truth to be told to consumers on pet food labels. I don’t expect or am I asking AAFCO to put themselves into a position of judgment (such as: is this a humanely sourced ingredient?, is this ingredient ethical?). I am asking AAFCO to require ingredient sourcing disclosure to the public (slaughtered animals or ground alive animals). Allow the public the opportunity to judge for themselves what source of chicken pet food they provide to their pet.

Susan Thixton
Representing Pet Food Consumer Members of Association for Truth in Pet Food

And because FDA recently announced they will begin to take over the role of animal food/feed ingredient definitions (from AAFCO), the following letter was sent to FDA…

It has been brought to our attention that it is common practice within the pet food industry to utilize ingredients sourced from culled baby chicks and spent laying hens by means of a macerator; the animals are ground alive. The end product is sold to pet food as ‘chicken’ or ‘chicken meal’ without disclosure to the consumer.

Currently the AAFCO established definition of poultry/chicken does not require the ingredient to be sourced from a slaughtered animal. This is in direct contrast to the AAFCO established definition of other meat ingredients – which do include within the ingredient definition the requirement of sourced from a slaughtered animal. We can only assume this omission of the requirement of ‘sourced from a slaughtered animal’ to be regulatory permission to utilize culled birds ground alive sold as the pet food ingredient ‘chicken’.

As FDA just announced “a strategy to establish ingredient definitions and standards for animal food in order to increase transparency”, ATPF asks FDA to include the transparency of source of ingredients (sourced from slaughtered animals or culled animals ground alive) within ingredient definitions. Pet food consumers deserve to know this information when making their pet food purchases.

ATPF also asks FDA for the ingredient definition transparency to include the quality of each ingredient; which ingredients are true food ingredients meeting all requirements of food law and which ingredients are considered feed (not meeting the requirements of food law).

We hope the FDA is sincere in their statement wishing to increase transparency within the pet food/animal feed industry. Consumers have waited a long time for transparency, it will be a welcome change.

Susan Thixton
Representing Pet Food Consumer Members of Association for Truth in Pet Food

For me, it has always been such a struggle to consider the slaughter of an animal. I have read far too many documents on the process, the memory of those words has caused me lots of lost sleep. While the slaughter of an animal is horrific to consider, the macerator process of grinding an animal alive is something completely unacceptable. Add with this, the pet food industry hiding this dirty little secret – keeping this truth from consumers on pet food labels – unacceptable has moved to a whole new level.

Call your pet food manufacturer and ask for their assurance that all meat is sourced from a USDA inspected and approved slaughtered animal. Will any pet food admit to sourcing ground alive chicken? It is doubtful. Which is all the more reason that we must have regulations that require this disclosure to consumers.

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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