The AAFCO working group that has developed a legal definition for human grade pet food met again yesterday. There is good news, and bad news (especially for raw pet food manufacturers and raw pet food consumers).
AAFCO working groups volunteer to define an ingredient or term or update an existing regulation. Members of State Department of Agriculture and FDA participate on these working groups, as well as representatives of industry and consumers. The working groups meet via webinars as often as is needed to accomplish the task at hand. Yesterday the working group defining human grade pet foods met again to tweak the definition of human grade.
The good news is that during this meeting we tweaked the definition of human grade pet food a little more, providing a clear explanation in the definition that a pet food must meet numerous requirements in order to make the (human grade) claim. Briefly, those requirements are:
Every ingredient and the finished product must be ‘human edible’ and must be processed, stored, and transported per regulations of human food.
- The pet food must be processed in a licensed human food facility.
- Human grade claims will not be allowed for individual ingredients.
- Human grade claims will not be allowed on brochures, websites, etc. unless all of the requirements of the claim are met.
Consumer advocates felt the definition is good (with the exception explained below). With the addition in the definition to limit website claims of human grade to only pet foods that meet the full definition of the law – hopefully consumers will not be mislead by marketing claims on various pet food websites.
The definition will be voted on (by only AAFCO members – FDA and State Department of Agriculture) in a few weeks.
The big problem with the definition is raw pet foods. Raw pet foods will not meet the requirements of the definition – all because the two regulatory agencies that govern food don’t work together.
The first issue for raw pet foods and consumers is ‘human edible’. Raw meat is not considered ‘human edible’. Basically this is because raw meat sold for human consumption comes with cooking instructions. The regulatory mindset is all raw meat will be cooked.
As example, a raw pet food that is made with 100% human grade meat, with 100% human grade supplements, processed, stored and handled all according to human food regulations cannot be termed as ‘human grade’ because the legal definition (and the mindset of regulatory authorities) is raw meat is not ‘human edible’.
The next issue has to do with food jurisdiction. The FDA’s jurisdiction in food is all ‘ready-to-eat’ foods. The USDA’s jurisdiction in food is raw meat.
In an attempt to explain this very messy regulatory problem…A cooked pet food manufacturing facility is considered a ‘ready-to-eat’ product, thus it falls under FDA’s jurisdiction. A raw pet food is ‘ready-to-eat’ per those pets that consume it, but to regulators it remains raw meat thus it falls under the jurisdiction of USDA. The final product is pet food – so it’s regulated by FDA…BUT…it’s raw meat, not ready-to-eat under current regulatory mindset, so raw meat pet foods sort of lies in-between FDA’s and USDA’s jurisdiction. The finished product – a pet food – is FDA’s jurisdiction. But the manufacturing facility – a raw meat facility – is USDA’s jurisdiction. And neither authority – FDA and USDA – are willing to work together specifically for raw meat pet foods.
The laws that govern human food manufacturing – which a human grade pet food must abide by – are all for ready-to-eat products. Raw meat doesn’t even get a mention in human food manufacturing laws because humans don’t (typically) consume raw meat. This leaves a big hole in the human grade pet food definition that raw pet foods fall through.
To further muddy the water, USDA does have a pet food certification program, but it is not in cooperation with FDA or with AAFCO. It is their own certification program whose requirements are not the same as a human grade pet food requirements.
The Human Grade Pet Food definition is founded on what FDA has historically required of a pet food (to make the claim of human grade); FDA stated they have been verifying the human grade claim in pet food for about 10 years. In these past 10 years, FDA also stated no raw pet food ever applied to be verified as human grade. (A dehydrated raw pet food is ‘processed’ – it can and one has been verified as a human grade ‘ready-to-eat’ product. Not a actual raw meat pet food).
The reason no raw pet food has asked to be verified as human grade could be because many raw pet foods are manufactured in USDA human food meat processing facilities. It could be they assume they meet the requirement because they are manufactured in a human food (meat) facility. But…
Again, because pet food is not USDA’s jurisdiction – often at a USDA human meat processing facilities – the USDA inspectors ‘go to lunch’ when the meat is processed for pet food. Human meat products are processed under constant USDA supervision. But…because pet food falls under FDA jurisdiction, USDA doesn’t often spend their resources (pay their inspectors) to inspect the processing of raw meat pet food. Even though raw meat pet food is/can be manufactured in the same facility as human meat, very often the inspector leaves his supervisory position during the pet food processing. This leaves the raw pet food consumer without a guarantee the pet food is indeed human grade. Note: some raw pets foods are manufactured under USDA supervision – ask your pet food manufacturer for verification of this.
It’s one big regulatory nightmare. Sort of regulatory turf wars. Two government agencies – both supported by consumer tax dollars, but they do not work together. Each has their own turf, each adamantly defends their turf and unfortunately adamantly refuses to cross over the line to the others turf. They refuse to talk about any common ground.
The loser in this is raw meat pet food consumers. Consumers deserve to know – with certainty – if their pet food of choice is human grade or is feed grade. Consumer advocates will continue to address this issue with regulatory authorities, however what is needed is for raw pet food manufacturers to take this issue on with authorities. We hope they do rally together and address the issue with FDA, USDA and State Department of Agriculture/AAFCO. I will be attending the Global Pet Food Expo (trade event for pet food manufacturers) in a couple of weeks and will share this need to all raw pet food manufacturers. Fingers crossed.
Wishing you and your pet(s) the best,
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