Is it Feed or Food?

We believe we are buying food…pet food.  But is it made from feed grade ingredients?  There IS a significant difference between feed and food – even acknowledged by FDA.  What’s feed and what’s food – and why pet food consumers need to know the difference.

It is interesting that with almost every other species of animal – besides dogs and cats – their food is referred to as ‘feed’.  Horse feed, cattle feed, poultry feed.  But with our pets it is referred to as food – cat food, dog food.  Food is what humans eat, so perhaps the intent was – from the very beginning – to cause the consumer to think pet food is similar to human food – nothing like a cattle feed or poultry feed.  We want to provide our pets a safer, more quality ‘food’…right?  Here begins the problem for the consumer.

Pet food was a secondary product to animal feed.  AAFCO (American Association of Feed Control Officials) – the organization that currently develops pet food/animal feed ingredient definitions, regulations, labeling requirements – began in the early 1900’s with regulations guiding only livestock feed.  A few small mentions of pet food requirements happened in early years, but it wasn’t until the late 1950’s that AAFCO established the Pet Food Committee – whose purpose was to establish regulations over the pet food industry.

Regulators considered pet food a specialty product of animal feed.  Nothing different than adding another species feed (cattle, poultry, dog, cat).  From it’s very beginning pet food has been clumped together with animal feed. Clumped together such as…

• The very same regulations that govern cattle feed or poultry feed – govern cat and dog food (with minor exceptions such as nutritional requirements).
• The very same ‘feed’ ingredients that are used in cattle feed or poultry feed, are used in pet foods (with the exception of a few ingredients specific to dog or cat food only).
• There are little to no quality standards for feed ingredients – so in turn, there are little to no quality standards for pet food ingredients.
• Even down to safe manufacturing practices and transportation of ingredients or finished product are the same for animal feed and pet food.

So regulatory speaking, pet food was/is considered ‘feed’ for cats and dogs.  But here is where numerous concerns begin.

Livestock feed – such as for cattle or poultry – does not have the same feeding purpose as pet food.  (Most) Livestock feed is designed to rapidly fatten-up the animal and is only concerned with short term health; only keeping the animal healthy until slaughter. Pet food – to the contrary – is used (in hopes) to sustain a pet for many years. Besides the nutritional requirements, there are very few differences in the regulations, the ingredients, the quality standards of ingredients (lack thereof), and the manufacturing practices to the feed that livestock animals consume and the majority of the food that is sold for our pets.

Another significant concern to the differences between feed and food, unlike livestock feed, pet food is brought into the home, often handled by numerous members of the family. As pointed out by FDA administration at a recent public meeting, cattle feed or poultry feed is often dumped right onto the ground to feed the animal – this is expected in the ‘feed’ industry. To the contrary, pet food is often mixed or even served right on the kitchen counter potentially exposing an entire family to risks of feed ingredients.  And again, pet food – despite it being as much of a human food item as could be (without us actually eating it) – is held to the very same manufacturing and safety regulations as ‘feed’ – which is expected to be ‘served’ on the ground with little human exposure (besides the farmer).

Perhaps this is why we see so many Salmonella recalls in kibble?  Feed quality ingredients used in pet foods being brought into the home – which, by design – feed quality ingredients are not expected to be brought into the home.  A point (well made) by Dr. John Tegzes, Veterinary Toxicologist in response to a recent FDA video on the safe handling of pet food.

First – here’s the FDA video titled “Pet Food and Treats in Your Home”

Now, here is Dr. John Tegzes response to the FDA video…

It boils down to regulatory bodies (in the U.S.) look at feed as what animals eat (including pets) and food as what humans eat.  And the two are as different as daylight and dark with regards to safety, quality, and standards.  The numerous FDA Compliance Policies that allow diseased animals or pesticide laden foods to become animal feed ingredients – all reference ‘feed’ – “suitable for use in animal feed.”  These same Compliance Policies are not allowed for ‘food’.

Examples of the differences between feed and food…

FDA’s Compliance Policy “CPG Sec. 675.100 Diversion of Contaminated Food for Animal Use” states “FDA does not object to the diversion to animal feed of human food adulterated with rodent, roach, or bird excreta.” 

Compliance Policy “CPG Sec. 675.200 Diversion of Adulterated Food to Acceptable Animal Feed Use” states “The *Center* will consider the requests for diversion of food considered adulterated for human use in all situations where the diverted food will be acceptable for its intended animal food use. Such situations may include:
a. Pesticide contamination in excess of the permitted tolerance or action level.
b. Pesticide contamination where the pesticide involved is unapproved for use on a food or feed commodity.
c. Contamination by industrial chemicals.
d. Contamination by natural toxicants.
e. Contamination by filth.
f. Microbiological contamination.
g. Over tolerance or unpermitted drug residues.

One more, Compliance Policy “CPG Sec. 690.300 Canned Pet Food” 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.”

Feed can include “material from diseased animals” or “contamination by filth” or “contamination by industrial chemicals”.  Food can not.

Now here is the worst part…some pet food manufacturers do use food ingredients and others use feed grade ingredients – but they all look the same (or similar) on the shelf.  Pet food companies can imply they are using ‘food grade’ ingredients on the labels while actually using feed grade ingredients inside the bag or can.  And the consumer is none the wiser.  Pretty pictures of fresh chicken (even grilled chicken) and fresh vegetables on the outside of the bag or can could instead actually be diseased chicken and pesticide contaminated vegetables inside the bag or can; a completely misleading representation of the pet food.  And there is no one that oversees this aspect of pet food to make certain the consumer is protected.  Because authorities considers pet food ‘animal feed’.

If you are wanting to provide your pet ‘food’ instead of ‘feed’ – you can purchase human food (which is USDA inspected and approved for human consumption) and make your own pet food.  If you are buying a commercial food, you need a very clear guarantee from the manufacturer all ingredients (meats and vegetables) are USDA inspected and approved.  ‘Approved’ is key – don’t accept anything less; USDA inspected and approved for human consumption ingredients (which is NOT feed grade).  The companies that have provided us their Pledge to Quality and Origin have fully disclosed what quality/grade ingredients they are using.

Pet Food Consumers deserve to know what they are buying.  No animal deserves to eat drug laden or pesticide contaminated or rendered diseased animals.  And it especially should not be sold to us implying it is made from fresh healthy ingredients.  But until regulations force manufacturers to disclose the true quality of ingredients (food or feed grade) and regulations are enforced – we must continue to be our own private detective.  Keep asking questions.

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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