From Alabama to Wyoming, every U.S. State allows illegal pet foods and treats to be sold to unknowing consumers. Each and every State Department of Agriculture could step in and enforce Federal laws with pet food, but they don’t. No one does. It is time for this to stop. Which U.S. State will be the first to do the right thing to protect their pets?
Federal Food Safety laws are very specific, no food for humans or animals can contain a diseased animal or an animal that has died other than by slaughter. Thank goodness for these laws; no one would want to eat lasagna made with ground meat from a sick animal or a hamburger from an animal that has been euthanized (side order of lethal drug please). It would be unhealthy and certainly dangerous.
But…every U.S. State allows diseased animals and euthanized animals to be ground up and cooked into pet foods and treats. Don’t our pets deserve the same protection from dangerous and unhealthy ground meat from sick animals and ground meat from animals that have been euthanized? Fifty State Department of Agriculture offices don’t think so.
Federal Law clearly includes the protection of pet food. The Federal Food, Drug, and Cosmetic Act defines food as: Section 201 (f) “1 The term “food” means (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.” http://www.fda.gov/RegulatoryInformation/Legislation/FederalFoodDrugandCosmeticActFDCAct/FDCActChaptersIandIIShortTitleandDefinitions/ucm086297.htm
Adulterated Food, which would be prohibited (illegal) is defined as (quoting only parts of the law that would address pet food): Section 402 “A food shall be deemed to be adulterated (a) (3) if it consists in whole or in part of any filthy, putrid, or decomposed substance, or if it is otherwise unfit for food; (5) if it is, in whole or in part, the product of a diseased animal or of an animal which has died otherwise than by slaughter;”. http://www.fda.gov/RegulatoryInformation/Legislation/FederalFoodDrugandCosmeticActFDCAct/FDCActChapterIVFood/ucm107527.htm
In layman terms, if a pet food contains an ingredient made from a diseased animal or an animal that has died other than by slaughter (road kill, euthanized animal) it would be considered adulterated and in turn would be illegal for sale in the U.S.
For those that are thinking ‘No Way…I don’t believe this…There is No Way a diseased animal or road kill could end up in pet food…EEEUUUUU’…
In 2002, the FDA published a report titled ‘Risk of Pentobarbital in Dog Food’. A two year study by the FDA discovered the lethal drug Pentobarbital in dog foods purchased from grocery stores and retail outlets. Pentobarbital is the drug used to euthanize (kill) a dog, cat, horse, and/or cow; in many cases the animal is seriously ill. http://www.fda.gov/AboutFDA/CentersOffices/CVM/CVMFOIAElectronicReadingRoom/ucm129131.htm
FDA testing found the drug in Nutro, Ol’ Roy, Ken-L-Ration, Kibbles ‘n Bits, Purina Pro Plan dog food among others. http://www.fda.gov/AboutFDA/CentersOffices/CVM/CVMFOIAElectronicReadingRoom/ucm129135.htm
Cat foods were never tested.
How could a lethal drug end up in dog food? The FDA determined that euthanized animals, killed with pentobarbital, were ‘rendered’ (cooked) and become the common pet food and treat ingredients “Meat and Bone Meal”, “Beef and Bone Meal”, “Animal Fat”, and “Animal Digest”. (I hope you are running to the pantry at this point to read your pets food and treats ingredients! – you really don’t want to feed your beloved cat or dog a sick euthanized animal do you?) http://www.fda.gov/AboutFDA/CentersOffices/CVM/CVMFOIAElectronicReadingRoom/ucm129134.htm
In 2004, the 108th Congress of the United States was provided (via the Congressional Research Services) a report titled “Animal Rendering: Economics and Policy”. http://www.nationalaglawcenter.org/assets/crs/RS21771.pdf
This report provided Congress with insight to a little known industry; Animal Rendering. “Renderers convert dead animals and animal parts that otherwise would require disposal into a variety of materials, including …proteins such as meat and bone meal. These materials in turn are exported or sold to domestic manufacturers of a wide range of industrial and consumer goods such as livestock feed and pet food,…”.
“Renderers annually convert 47 billion pounds or more of raw animal materials… Sources for these materials include meat slaughtering and processing plants; dead animals from farms, ranches, feedlots, marketing barns, animal shelters, and other facilities; and fats, grease, and other food waste from restaurants and stores.”
(Please take note the inclusion of ‘animal shelters’ in the above quote. Per this Federal document researched for and provided to the 108th Congress of the United States, euthanized dogs and cats removed from animal shelters across the U.S. are rendered and are included in the pet food/treat ingredient ‘meat and bone meal’. Dogs and cats eating euthanized dogs and cats.)
“Poultry operations and pet food manufacturers accounted for 66% of the domestic MBM (meat and bone meal) market of nearly 5.7 billion pounds in 2000…”
So now you know how diseased animals and worse end up in pet food, the next question is why?
Federal law says it is illegal for a diseased animal or euthanized animal to become any food ingredient, but the FDA says they are not going to enforce the Federal law…
FDA POLICY:
“Pet food consisting of material from diseased animals or animals which have died otherwise than by slaughter, which is in violation of 402(a)(5) will not ordinarily be actionable, if it is not otherwise in violation of the law. It will be considered fit for animal consumption.”
http://www.fda.gov/ICECI/ComplianceManuals/CompliancePolicyGuidanceManual/ucm074710.htm
Let’s recap…the Federal Food, Drug, and Cosmetic Act clearly includes pet food under its protection, and clearly states a food would be considered adulterated and thus illegal if it contains a diseased animal or an animal that has died other than by slaughter (the tip of the illegal pet food ingredient iceberg). According to a Congressional Report, diseased animals and euthanized animals including euthanized dogs and cats, are ground and cooked (rendered) and become the common pet food ingredient ‘meat and bone meal’. FDA testing determined that the common pet food ingredients ‘Meat and Bone Meal’, ‘Beef and Bone Meal’, ‘Animal Fat’, and ‘Animal Digest’ are scientifically linked to the discovery of Pentobarbital (lethal drug) in dog food. Despite Federal laws prohibiting such food ingredients, the FDA says they will not enforce Federal laws relating to these illegal ingredients in pet foods and treats. (By the way, the FDA does not have authority over Federal law; they do NOT have the legal power to override a Federal law. They simply choose not to enforce laws relating to the safety of pet food and treats.)
Even though the FDA chooses not to enforce Federal laws relating to the safety of pet foods and treats, any U.S. State could choose to enforce the laws within their borders; sadly, no one does. From Alabama to Wyoming, not one U.S. State bothers to do the right thing to protect the pets of its citizens. Not one U.S. State bothers to enforce Federal law. Not one.
A pet food industry insider recently shared with me details of State Department of Agriculture officers routinely pulling pet foods and treats from store shelves because of improper labeling or other slights of regulations. Each State is different, some are stricter than others. As example, Florida Department of Agriculture has the reputation of being tough; yet the agent in charge of pet food told me “You are right, they (pet food ingredients meat and bone meal, beef and bone meal, animal fat and animal digest) are prohibited by law”, and then he added “But, we’re going to follow FDA advice”.
A Maryland Independent Pet Store Owner recently was visited by the Agriculture Inspector; this inspector pulled numerous products from the pet food store; several because of improper labeling, one because the company had not registered with the State. Despite being on top of their game in one perspective, Maryland still allows the sale of illegal pet foods and treats to be sold one aisle over from YOUR food in the grocery and major retail outlets.
It is long past time; illegal pet foods and treats should be promptly removed from store shelves. Federal Pet Food Safety laws should be promptly enforced. No company should profit from the sale of illegal pet foods and treats; No pet should consume a food or treat containing an illegal ingredient.
The Federal laws are in place, who will be the first State to have the courage and integrity to abide by Federal law?
Call, email, and or write your State Department of Agriculture. Tell them you feel Federal laws should be enforced relating to pet food and pet treat safety. Tell them all pet foods that contain the ingredients meat and bone meal, beef and bone meal, animal fat and/or animal digest should be removed from store shelves immediately. Insist your State abide by Federal law. Insist the pet foods and treats be removed from store shelves until the manufacturer proves they are not in violation of Federal law.
It is the law; Federal law. It should be enforced.
Until it is, closely read the ingredients of your pets food and treats. If the food or treat contains ‘Meat and Bone Meal’, ‘Beef and Bone Meal’, ‘Animal Fat’, or ‘Animal Digest’, the product is probably in violation of Federal law; do not feed it to your pet. Return any unused products to the store and tell the clerk this food/treat is in violation of Federal law and request a full refund. Do not support pet food/treat manufacturers that disregard Federal Food Safety laws; do not purchase their products.
Wishing you and your pet(s) the best,
Susan Thixton
Pet Food Safety Advocate
Author, Buyer Beware
Co-Author Dinner PAWsible
TruthaboutPetFood.com
PetsumerReport.com
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