FDA Double Standards

It’s FDA double standards.  Raw pet food is held to one standard while any kibble or canned pet food is allowed free reign.

Back in 2004, the FDA was developing guidance regulations for manufacturers of raw pet food.  Of course this guidance was more concerned with the safety of humans handling the food than the pets consuming it, but…within this draft guidance the FDA states several things they don’t typically mention when they speak about pet food.  1) Within this Guidance, the FDA urges raw pet food manufacturers to use USDA inspected and approved meats.  2) The FDA admits 4D meat (meat sourced from dead animals, dying animals, diseased animals or downer animals) is nutritionally deficient.  And 3) in this document the FDA clearly admits that 4D meats in a pet food would be “unlawful”.

From the FDA document “Manufacture and Labeling of Raw Meat Foods for Companion and Captive Noncompanion Carnivores and Omnivores”…

Let’s work backwards…starting with FDA statement of federal law first (page 8)…bold added…

“It is unlawful to introduce in to interstate commerce any food, including food for pets and for other animals, which is adulterated (Section 301(a) of the FFDCA). Among the circumstances in which a food will be deemed adulterated are when: (a) it contains any poisonous or deleterious substance that may render it injurious to health, unless the quantity does not ordinarily render the food injurious to health; (b) it has been prepared, packed, or held under unsanitary conditions whereby it may have become contaminated with filth, or whereby it may have been rendered injurious to health; and (c) it is, in whole or in part, the product of a diseased animal or of an animal that has died otherwise than by slaughter (Section 402(a) of the FFDCA).”

So there it is.  FDA admitting that it is unlawful for a pet food to include any part of a diseased animal or any part of an animal that has died other than slaughter.

But, below is FDA talking out of the other side of its mouth…(bold added)

“Foods for carnivorous and omnivorous animals containing raw meat, or other raw animal tissues, have been on the market for many years for use by zoos, mink farms, dog racing facilities, and other professional establishments. Some of these products may have included meat and other tissues from mammals or poultry that have died other than from slaughter or have otherwise been unfit for human consumption.”

“Previously it was presumed that raw meat or raw animal tissues were primarily purchased and used by zoos, mink farms, dog racing facilities, or other professional establishments, and that these entities were aware of the potential risks of using such products, from both a food safety and nutritional deficiency perspective, and could take measures to mitigate those risks.”

Nutritional deficiencies aside (for the moment), the FDA decided they wanted raw pet food manufacturers to be legal.  Which is good.  The FDA’s Raw Pet Food Guidance document suggests “Manufacturers who produce raw meat diets should use USDA/Food Safety and Inspection Service (FSIS)-inspected meat that has been passed for human consumption.”

Sigh of relief right?  Not so fast.  While the FDA encourages raw pet food manufacturers to use USDA inspected and approved meats, on the flip side the FDA opens the door to any type of illegal meat in all other pet food manufacturing.

FDA Compliance Policy CPG Sec. 675.400 states “No regulatory action will be considered for animal feed ingredients resulting from the ordinary rendering process of industry, including those using animals which have died otherwise than by slaughter, provided they are not otherwise in violation of the law.”

FDA Compliance Policy CPG Sec. 690.300 states “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.”

Why does the FDA do this?  Why does the FDA attempt to hold raw pet food manufacturers to a human grade meat requirement while Big Pet Food’s kibble and canned foods are allowed to use just about any waste meat they want?  I’ve tried asking FDA these questions for years.  The only response I’ve gotten (well, close to a response) is that FDA does not feel diseased animals or animals that have died other than by slaughter are a risk.  No kidding, that’s what they said.  They didn’t specify if that ‘no-risk’ was to the humans handling the pet food or the pet consuming it.  And by the way, the consumer is never told if the meat in their kibble or canned pet food is sourced from a dead cow that laid in the sun for three days or is sourced from a USDA inspected and approved slaughtered animal.

And let’s not forget about the nutritional deficiency.  FDA readily admitted that meats sourced from non-slaughtered animals are at risk of being nutritionally deficient.  But somehow that nutritional deficiency is forgotten about with kibble or canned pet foods that use meat sourced from non-slaughtered animals.

All pet foods should contain legal ingredients.  The FDA has no right to pick and choose which federal laws they enforce and which types of pet foods can include illegal ingredients.  The FDA provides pet food manufacturers the ability to lie to consumers and freely allows some pet foods to be illegal and nutritionally deficient.  It’s wrong.

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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