Are Ingredient Definitions Allowing Loopholes to Quality?

In working on the consumer language definitions of pet food ingredients, I discovered a huge concern.  I found official pet food ingredient definitions that do not provide the consumer with any security to quality.  Here are those concerns and action that our Association for Truth in Pet Food has taken to protect pet food consumers.

The first concern any pet food consumer has is the safety of the pet food one chooses to trust and feed to their pet.  Alongside the safety concerns of the pet food as a whole is the quality of the individual ingredients used in that pet food.  As it turns out, pet food consumers have a lot more to worry about than we thought.  Incomplete pet food ingredient definitions allow inferior quality ingredients to be part of a pet food without consumer knowledge.

The Association of American Feed Control Officials (AAFCO) is the organization responsible for developing existing pet food ingredient definitions; specifically the Ingredient Definitions Committee within AAFCO.  These ingredient definitions become law within U.S. states and subsequently guide pet food manufacturing.  Needless to say, pet food consumers depend on these pet food ingredient definitions to properly define what can or can not be included in their pet food choice.

To explain the concern of incomplete ingredient definitions…

Meat is defined in the AAFCO Official Publication as “flesh” sourced from slaughtered mammals and is listed on pet food labels with the descriptive term such as Turkey, Lamb, Venison, Beef.

Chicken is officially defined a combination of flesh and skin and could include bone.

The HUGE concern…meat – per AAFCO definition – must be sourced from slaughtered animals; providing pet food consumers with some quality security.  Chicken on the other hand does NOT include this requirement in the definition.  In other words, per the official definition of chicken (all poultry), the ingredient can be sourced from 4D (dead, dying, diseased, disabled) animals rejected for use in human food – including euthanized poultry.

One would assume that meat meal would be almost the exact same definition as meat, with the exception that the meat is rendered (cooked prior to pet food manufacturing).  But that is not the case with AAFCO ingredient definitions.  The definition of meat includes no bone and again is defined to be sourced from slaughtered animals.  The definition of meat meal includes bone and has NO requirement it must be sourced from slaughtered animals.  Again, per official pet food ingredient definitions, a meat meal such as lamb meal or beef meal can be sourced from 4D (dead, dying, diseased, disabled) animals rejected for use in human food – including euthanized animals.

Chicken Meal or Poultry Meal as well does NOT have the requirement it must be sourced from slaughtered animals.

Now, here’s the crazy part (ok, here’s more crazy)…

Meat meal (such as lamb meal) which is a rendered (cooked prior to pet food manufacturing) does NOT have the requirement to be sourced from slaughtered animals.  But Meat By-Products (such as lamb by-products) which is a non-rendered ingredient does.

Ok, so if a pet food consumer would want to understand the methods used by regulatory authorities, we could assume that rendered (cooked) ingredients would be those that can be sourced from 4D – rejected for use in human food animals.  Meat and Meat By-Products – not rendered – sourced from slaughtered animals.  Meat Meal and Meat and Bone Meal – rendered – no requirement to be sourced from slaughtered animals.  But…that’s not the case.

Chicken – not rendered – no requirement to be sourced from slaughtered animals.  Chicken by-products – not rendered – DOES have the requirement to be sourced from slaughtered animals.

So, so wrong.

To re-cap…

Meat – definition requires souring from slaughtered animals;
Meat Meal – definition does NOT require sourcing from slaughtered animals;
Meat By-Products – definition requires sourcing from slaughtered animals;
Meat and Bone Meal – definition does NOT require sourcing from slaughtered animals.

Chicken – definition does NOT require sourcing from slaughtered animals;
Chicken Meal – definition does NOT require sourcing from slaughtered animals;
Chicken By-Products – definition requires sourcing from slaughtered animals;
Chicken By-Product Meal – definition requires sourcing from slaughtered animals.

The following letter has been sent to AAFCO President Tim Darden and Ingredient Definitions Chair Richard Ten Eyck…

Richard Ten Eyck
AAFCO Ingredient Definitions Committee Chair

and

Tim Darden
AAFCO President

The Association for Truth in Pet Food, a consumer stakeholder association, is writing you to alert you to concerns of incomplete pet food ingredient definitions.  We hope AAFCO takes swift action to correct these pet food safety issues.

Consumers depend on the quality and safety of the pet food they purchase.  Pet food ingredient definitions can help define that quality and subsequently the safety of the pet food.  We have found some significant inconsistencies within common pet food ingredient definitions that could lead to quality issues for the consumer.

The pet food ingredient ‘Meat’ has included within the definition it must be sourced from slaughtered animals.  However the ingredient ‘Meat Meal’ does not have this same requirement (sourced from slaughtered animals) within the definition.  ‘Meat by-products’ definition has the requirement sourcing must be from slaughtered animals, but ‘Animal by-products’ and ‘Meat and bone meal’ has no requirement (sourced from slaughtered animals) within the definition.  

Though ‘Meat’ includes the sourced from slaughtered animals requirement, ‘Chicken’ a similar meat ingredient does not.  ‘Chicken Meal’ as well does not have the requirement (sourced from slaughtered animals) within the definition.  However, ‘Chicken by-products’ and ‘Chicken by-product meal’ does include the requirement within the definition.

In the 2013 Official Publication we found…
Meat – definition requires souring from slaughtered animals;
Meat Meal – definition does NOT require sourcing from slaughtered animals;
Meat By-Products – definition requires sourcing from slaughtered animals;
Meat and Bone Meal – definition does NOT require sourcing from slaughtered animals.

Chicken – definition does NOT require sourcing from slaughtered animals;
Chicken Meal – definition does NOT require sourcing from slaughtered animals;
Chicken By-Products – definition requires sourcing from slaughtered animals;
Chicken By-Product Meal – definition requires sourcing from slaughtered animals.

Federal law – specifically the Food, Drug, and Cosmetic Act (the Act) – defines food (Section 201 f) as “articles used for food or drink for man or other animals”.   The Act defines adulterated food (Section 402) as (a, 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.”  

Federal law is very clear, pet food is protected under the Act and pet food would be considered adulterated if it contained any part of a animal which has died other than by slaughter.  

The Association for Truth in Pet Food asks AAFCO to tighten up pet food ingredient definitions to be compliant with federal law.  Each pet food ingredient definition (animal sourced ingredients) should include the requirement to be sourced ONLY from slaughtered animals.  

Further, our association asks AAFCO to include within ingredient definitions the option for quality or grade of animal sourced ingredients.  Such as ‘If it bears a USDA Inspected and Approved or Grade descriptive, it must correspond thereto.’  Pet food consumers want and deserve to know the quality and/or grade of ingredients within the pet foods they purchase.

Association for Truth in Pet Food is more than willing to work with AAFCO and provide additional input if needed.  

Association for Truth in Pet Food
Susan Thixton
Mollie Morrissette  

Until pet food regulations specifically require meat (all animal sourced ingredients) ingredients to be sourced from USDA inspected and approved slaughtered animals, consumers only option is to call the manufacturer and ask…

Are your meat and/or meat meal ingredients sourced from USDA inspected and approved slaughtered animals?

Note:  Pet food manufacturers that have provided us their Pledge have already given us this information – and certified the information to be true with signature of CEO or President of the company.

Wishing you and your pet(s) the best,

Susan Thixton
TruthaboutPetFood.com
Association for Truth in Pet Food
Pet Food Safety Advocate
Author Buyer Beware, Co-Author Dinner PAWsible

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