It isn’t publicly mentioned often (by government), but found within the Federal Register…FDA openly admits the agency allows pet food/animal feed to violate federal law.
While unknowing consumers believe they are buying ‘food’ for their pet, behind public view is a massive illegal food waste disposal system allowed by a little discussed privilege of government – selective enforcement. Wikipedia defines selective enforcement as: “In law, selective enforcement occurs when government officials such as police officers, prosecutors, or regulators exercise enforcement discretion, which is the power to choose whether or how to punish a person who has violated the law.”
Most consumers assume the Food and Drug Administration (FDA) is enforcing law, assume the pet food they purchase is a legal, safe product. The reality is many – probably most – pet foods contain one more more ingredients that violate federal law.
For most pet food consumers, this is very difficult to accept. It couldn’t be true. The FDA – our government – wouldn’t knowingly allow illegal pet food products to sell on store shelves.
The doubt is understandable, mainly because the illegal system of pet food/animal feed isn’t often admitted to. Ten years ago – in 2008 – the FDA made some significant admissions in the Federal Register (U.S. government publication). Back in 2008, the FDA strengthened regulations to prevent the spread of Mad Cow Disease publishing “Substances Prohibited From Use in Animal Food or Feed; Final Rule”. Bovine spongiform encephalopathy (BSE) or commonly known as Mad Cow Disease is fatal to cattle and humans consuming the meat from sick animals. Cats can be sickened by a version of Mad Cow (Feline spongiform encephalopathy) – to date it is believed dogs cannot contract the disease.
The short version of the 2008 rule FDA implemented to prevent the spread of Mad Cow Disease is the agency required specified risk materials (brain and spinal column) be removed from diseased and/or dead non-slaughtered animals before they would be allowed to be processed into any animal feed ingredient. The rest of the diseased animal, and the rest of a dead decomposing animal that died other than slaughter – even though both are a violation of law – would be allowed into any animal feed ingredient.
Quoting the Federal Register document:
This rule, however, should not be construed to mean that it is legal to use any portion of an animal that is adulterated under the Federal Food, Drug, and Cosmetic Act (the act) in animal food or feed.
FDA notes that, for cattle not inspected and passed that are diseased or that died otherwise than by slaughter, the entire carcass of such animals is adulterated under section 402(a)(5) of the act.
FDA has traditionally exercised enforcement discretion with regard to the use of such animals in animal feed. For example, see Compliance Policy Guide 675.400. FDA intends to continue exercising such discretion for the use in animal feed of: (1) The remaining material from cattle that are diseased or that die otherwise than by slaughter when the brain and spinal cord are effectively removed or effectively excluded from animal feed use and (2) the entire carcass from cattle that are diseased or that die otherwise than by slaughter if such cattle are shown to be less than 30 months of age.
The FDA openly admits these types of animal feed/pet feed ingredients are illegal – remain illegal. But the agency makes it clear they are CHOOSING not to enforce law. The agency is CHOOSING to allow pets to consume diseased animal material, CHOOSING to allow pets to consume decomposing, dead, non-slaughtered animal material. The agency is CHOOSING to allow the pet feed industry to profit from the sale of illegal ingredients. And significantly – illegal ingredients are allowed by FDA with no disclosure on the pet food label. No warning to any consumer.
Who in their right mind would allow this?
It’s not just pets that are consuming diseased and decomposing dead non-slaughtered animal material – livestock animals are fed the same material in processed livestock feed. As insane as it is, the FDA allows cattle to consume rendered diseased cattle material, chickens to consume rendered diseased chicken material, and pets to consume any diseased or decomposing dead animal. Why would the agency allow this? It’s waste disposal.
Again, from the Federal Register document:
Some comments stated that rendering is the best disposal option and that burial, composting, and incineration are undesirable alternatives. One comment said that if SRMs and deadstock are diverted from animal feed use, FDA will no longer have control over this material. Another comment pointed out that it takes 14 months to properly compost a 1500-pound (lb) cow. (Response) FDA believes this final rule appropriately controls materials to be rendered for animal feed. FDA intends to work with relevant local, State, and other Federal agencies concerning disposal issues.
The FDA estimated that ONLY brain and spinal cord from diseased or dead non-slaughtered cattle (material FDA was not permitting in animal feed) is “approximately 670 million pounds” a year. We can safely times that amount by 20 (a very conservative estimate of brain and spinal cord to be 1/20th of the weight of the entire animal carcass) to estimate what IS allowed into pet feed/animal feed. Which means more than 13 billion pounds of illegal cattle material is processed each year into pet feed/animal feed.
And that 13 billion pounds is just cattle material. We can estimate an equal 13 billion pounds of illegal poultry material and another 13 billion pounds of illegal pig material is also allowed to be processed into pet feed/animal feed for a grand illegal total of 40 billion pounds a year.
Why? Because any other disposal method is costly to industry and could pose a risk to human health (contamination of water and land from billions of pounds of decomposing dead animals).
It’s allowed – law is ignored – because the FDA feels the best place to dispose of 40 billion pounds of diseased, decomposing, dead, non-slaughtered animals is pet feed/animal feed. As insane as it is – the FDA holds the authority to do this through selective enforcement.
But…the question remains if the agency actually has the authority to operate in such an opposite direction of law – and if the agency has the authority to selectively enforce law with no warning on pet food labels alerting consumers to the violation of law risk.
In October 2016, we (Association for Truth in Pet Food) officially requested the FDA to stop allowing these illegal ingredients into pet food. And in July 2017, we submitted an addendum to our request asking the agency to require pet products to be clearly labeled as “pet feed” or “pet food” depending if ingredients used in the products are illegal (feed) or legal (food). To read our official requests published on the government website – visit: https://www.regulations.gov/docket?D=FDA-2016-P-3578. (First item is our original request, second item is our addendum.) Or click Here and Here to view the documents in a separate window.
To date – 19 months after we submitted the request – FDA has not responded.
And…
Any pet food that does not meet the full requirement of human grade pet food (100% ingredients and supplements human edible, manufactured in a licensed human food facility) – could contain ingredients sourced from a diseased or decomposing, non-slaughtered, dead animal. No particular style of pet food is guaranteed safer than another from these types of ingredients. However – just how FDA takes enforcement discretion allowing these ingredients into pet feeds, the agency takes an opposite enforcement discretion with raw pet food.
Within the FDA Guidance document titled “Manufacture and Labeling of Raw Meat Pet Foods” the FDA tells industry that raw pet foods “should” be sourced from human edible meats…
All meat- and poultry-derived ingredients should be United States Department of Agriculture (USDA)/Food Safety and Inspection Service (FSIS)-inspected and passed for human consumption.
In other words, FDA openly allows all other styles of pet feed (kibble, canned, dehydrated, and so on) to utilize illegal ingredients sourced from diseased/non-slaughtered animals with NO disclosure to the consumer – BUT tells raw pet food all meats should be sourced from human grade/human edible sources. Completely opposite standards.
Until we receive a response from FDA on our request, consumers are left to trust their pet food manufacturer (excluding human grade pet foods). Ask your pet food manufacturer: “Are meats/meat meals sourced from USDA inspected and passed animals?” If they cannot guarantee you they are – you are taking a risk of feeding your pet diseased and/or decomposing, dead, non-slaughtered animal material.
With human grade pet foods, consumers can trust the claim stated on a pet food label – trust that 100% of this pet food is human edible (NOT sourced from diseased or non-slaughtered animals). Consumers cannot trust the claim on a pet food website; regulatory authorities do not scrutinize pet food websites for honest/accurate claims. With raw pet foods, the human grade claim cannot be made. Ask raw pet food manufacturers if the product was manufactured “under constant USDA inspection”.
And if you are furious at the thought of the weight of 1,300 Brooklyn Bridges worth of illegal waste allowed to be dumped into pet feed/animal feed (though labeled as ‘food’) each year – tell the FDA how you feel.
You can email the Center for Veterinary Medicine (division of FDA that oversees pet food/animal feed) at: AskCVM@fda.hhs.gov. You can call the agency at: 240-402-7002.
Tell them to stop allowing diseased and non-slaughtered animals into pet food, animal feed. At the VERY least, pet food labels should be clearly marked if the product contains diseased or non-slaughtered animal material (clearly marked as “feed” or “food”). Tell them you support Docket ID: FDA-2016-P-3578 (our request to the agency to label products as feed or food and to stop the use of illegal ingredients in pet foods).
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
Become a member of our pet food consumer Association. Association for Truth in Pet Food is a a stakeholder organization representing the voice of pet food consumers at AAFCO and with FDA. Your membership helps representatives attend meetings and voice consumer concerns with regulatory authorities. Click Here to learn more.
What’s in Your Pet’s Food?
Is your dog or cat eating risk ingredients? Chinese imports? Petsumer Report tells the ‘rest of the story’ on over 5,000 cat foods, dog foods, and pet treats. 30 Day Satisfaction Guarantee. Click Here to preview Petsumer Report. www.PetsumerReport.com
The 2018 List
Susan’s List of trusted pet foods. Click Here to learn more.
Have you read Buyer Beware? Click Here
Cooking pet food made easy, Dinner PAWsible
Find Healthy Pet Foods in Your Area Click Here
Michelle
June 3, 2018 at 5:43 pm
And people wonder why their pets are dying from all forms of cancer…
paponypal
June 3, 2018 at 6:38 pm
Thanks Susan I’ll write as usual as I’m sure all your followers will do. But I feel unless we win a trillion dollar lottery to buy off the watchdogs, they’ll remain cold & callous, deaf & blind. But I continue to hope in my heart someday WE THE PEOPLE WILL BE HEARD.
Stephanie N.
June 4, 2018 at 2:27 pm
Completely agree, paponypal.
Kathryn Smith
June 3, 2018 at 6:43 pm
I still contend that INCINERATION of ALL this ‘product’ in a “waste energy’ facility to provide electricity would be the best solution … Yes, initial implementation would be expensive, but in the long run would benefit animal feed industry and the public.
Cannoliamo
June 3, 2018 at 7:26 pm
It’s my nature to by cynical, but it sounds like all those lawyers for the tobacco companies have gotten jobs in the pet food industry.
Angie
June 4, 2018 at 10:32 am
The best way to know how food is affecting your pets health is to have a complete blood panel drawn yearly and have regular exams. My senior dog just had his senior profile completed and he is in perfect health and he eats Natural Balance LID canned and Natural Balance LID treats.
Stephanie N.
June 8, 2018 at 1:54 pm
Angie,
It really stinks you’ve been attacked by other members of this site after posting.
And, I agree with you completely that the best way to ensure our pets are healthy is to have complete blood chemistry panels and other pertinent tests performed along with check-ups on a regular basis.
Jess
June 4, 2018 at 2:44 pm
The best way to feed your pet is homemade diets. You can prepare 2 weeks worth of food and freeze it in advance .You can know and control everything that goes into their food with an organic, healthy diet. BalanceIT.com has recipes and the necessary supplements. If your pet has health issues like kidney disease, you need a prescription from your vet for special supplements. For healthy pets, no prescription is necesary. My cat lived to 19 years old with a healthy homemade diet. I switched when I found out she had kidney disease and realized the horrible things and risks associated with all commercial cat food (including many organic brands being recalled). The cost of homemade even ends up being less expensive. My cat never threw up from homemade food, didn’t have a smelly litter box, and it kept her healthy for many years. My primary vet wasn’t knowledgeable of homemade diets (I found out about it through a specialty vet), but my primary vet would comment how young my cat looked and said “whatever you are doing, keep it up”. I’ll always use a homemade diet for my furbabies. ♥️
Angie
June 4, 2018 at 3:42 pm
Not everybody can afford to do that. My dog has food allergies and has to eat duck. Duck is VERY expensive and he is doing great on his canned food. And cats need protein and moisture. Cats shouldnt be fed dry kibble ever. A good quality canned cat food is fine. The key is taking your animals for yearly checkups and getting those blood tests done.
A
June 4, 2018 at 4:23 pm
I’m sorry Angie but you must be new to this website or work for Natural Balance. No, not everyone can afford to feed raw or organic home cooked meals. But I suspect your dog is genetically blessed and that’s why he is healthy – it is most likely IN SPITE of his food, not because of it. I wasn’t going to comment but if you sound very self confident but seem not to know much about proper nutrition for companion animals. If you do some more research or read more of Susan’s website you would know that she does not recommend kibble and NB is not one of her trusted brands that she has extensively researched. Unfortunately you can’t just trust what a company puts on their website. Some people eat all organic and exercise and die from cancer at a young age. Other people smoke and eat crap and live to be 90. So it’s not all about food sometimes. But NB is not an ideal or biologically appropriate diet.
A
June 4, 2018 at 9:17 pm
And I saw that you said canned not kibble so that’s my karma for leaving a comment : ) BUT I stand by my opinion of NB, even it’s canned formulas. Now I’m gonna stay out of these threads
Jess
June 4, 2018 at 4:42 pm
Again. It actually ends up being cheaper to make food than buy premade food (for pets that eat regular diet, even kidney diets). Specific allergies would be something discussed with the vet and adjusted as necessary. I don’t know the cost of duck. For anyone not feeding their pets duck and who is interested in the research and learning about homemade diets—
All my pets have ate a chicken, turkey, beef or fish diet. All have been cheaper monthly with homemade. I realized my pet developed health issues due to “quality” canned food. Hyperthyroidism, kidney disease, cancer, etc. Is caused by what’s in commercial foods. Many “quality” foods are owned by same brands that manufacture the cheap ones and none are really regulated. Quality brands still have recalls and still made my cat throw up. I took my cat to the vet regularly and did all blood tests. She still developed health issues due to commercial food from what she used to eat. There are no special kidney diet foods”over the counter”for a reason. You have to buy kidney diet meals in can or kibble from the vet, which are disguised as a quality brand but manufactured by the low quality brands. The vets get paid to push these, just like Drs do with meds, which is why there are no other options in stores. The “quality” commercial kidney diet made my cat sick. They said on it she would live one year. I switched her to homemade and her kidneys improved .She lived for 7 more years with advanced kidney disease on a homemade diet. If anyone is interested in learning more, just look up balanceit.com for recipes and info. There are probably other sites too, but this is the one I used for many years. It’s the only way I’ll feed my pets now.
Angie
June 8, 2018 at 2:09 pm
Duck costs about 8.00 a LB, very expensive. But like I said he is doing very well on his canned food, his bloodwork and exams are perfect. Why would I change something that is working so well? Same for my cats, they eat wellness, weruva and fussie cat canned are healthy as can be. I appreciate your comment and suggestions though.
Jenny Bellandi
October 22, 2018 at 11:05 am
Both my dogs had aggressive cancer and their blood labs were always perfect. I couldnt believe it. The oncologist said unfortunately it doesnt always show an issue in blood labs. I have since learned alot and feed home cooking cause raw is expensive, but its still better than kibble. I understand the duck and cost, but have you spoke to a true natural vet? Duck is just one protein and perhaps he could try another alternative alittle less pricey? Im sure you have covered all that but i wanted you to know about the blood panels not always stating the whole story. Im not saying thats happening to your babies, but it did happen with two of mine over the years.
Kimberly
June 5, 2018 at 11:55 am
I used to feed NB LID to my cats, in rotation, until I found a large piece of a blue plastic bag in it. That and the LID diets tend to have a high amount of carbs. Also, if you search on facebook for raw feeding groups in your area you might be able to share the cost with other members or learn where to get different meat proteins for a good price.
Angie
June 6, 2018 at 11:53 am
A – I find it hilarious that you think I work for natural balance just because I said my dog eats it and is healthy. Why is that a standard answer on these boards? And you can take your condescending attitude elsewhere. I know plenty about pet nutrition. Just because I don’t feed homemade does not mean my pets are not healthy. The fact remains that millions of pets live long healthy lives on commercial pet foods. Yes there are some bad foods out there. It helps to do some research. All animals are different but I know what works and what is keeping my pets happy and healthy. My cats eat canned foods made by Wellness, Weruva and Fussie cat, I suppose I also work for them? Just because a certain food is not on her “list” does not mean its not a good product. Her opinion is not the “gold standard” to me. I trust MY vet and the healthy bloodwork and other studies that have come back perfect.
Tamara
June 9, 2018 at 3:19 pm
I agree with you. We rescued lots of feral cats and we spend over $500/month on premium wet and dry cat food. I have argued with an Australian vet on line about feeding dry food. If someone has 2-3 cats and can transition them from dry to wet…then that’s great. I had this vet tell me that it wouldn’t be hard to transition 25 cats from dry to wet. Oh yeah? I told her that 12-13 eat wet food, but they share..and they eat dry food too. We have had cats not eat for a few days and they can get “hepatic lipidosis” and need a feeding tube.
I wish I could force them all to eat wet food or a raw homemade diet (if had time to make it), but it’s not feasible. We feed them 5-8 kinds of wet food and 5 kinds of dry food. Wet food like Wellness, Holistic Select, Taste of the Wild, Lotus, Fromm’s, Dave’s, etc and dry food Costco (cheapest and has grains), Nature’s Variety with raw food bits, Blue Mtn Wilderness with life source bits, American Journey grain grain free…etc. We’ve fed them Acana and Orijen dry food but they are expensive and according to this vet that argues with me…. “the worst wet food is better than the best dry food.”
My longtime bf said for me to let the Australian vet come to the US and transition the cats for us..since she thinks its easy. When I asked her how many cats she had….she said 3. Everything we think is a premium wet food has something in it that shouldn’t be in there- guar gum, carageenan (however it is spelled), etc.
We can only do the best we can. I guess I must work for all these companies above too….LOL. I even feed the feral cats in a mini-cat colony the good stuff.
Frank
June 7, 2018 at 12:26 pm
Susan, please clarify something for us: in the article, you suggest we
“…ask your pet food manufacturer: “Are meats/meat meals sourced from USDA inspected and passed animals?” …”.
This would be instead of asking
“…are the meats/meals sourced from USDA inspected facilities….” , correct? .
Previously, I have asked your suggested question to several different pet food
suppliers. Their responses were along the line of
“…All our manufacturing plants are registered with the US Department of Agriculture and the Food and Drug Administration…” or
“…We only use high quality, de boned meats sourced from USDA FSIS-inspected facilities…”.
When a provider states that manufacturing plants and suppliers that they source their meats from are USDA inspected and registered, does that guarantee that the actual meats provided by those plants are always guaranteed to be from USDA inspected and passed animals?
Susan Thixton
June 7, 2018 at 2:43 pm
Hi Frank – No. Condemned and/or diseased meats are sourced ‘from’ USDA inspected facilities. Animal material that did not pass inspection comes ‘from’ USDA inspected facilities. So a question to a manufacturer needs to be specific to the meats in the pet food – are the meats USDA inspected and passed?
With the example responses you provided – that really tells a consumer nothing. Manufacturing plants are required to be registered with FDA, but that does not require ingredients to be quality. The other example you provided – the manufacturer claimed they “only use high quality” meats – I’d suggest asking them what does “high quality” mean? For me – ‘high quality’ only means USDA inspected and passed. But that not be what they are implying by the phrase.
Hope that helps –
mako5562
June 7, 2018 at 5:45 pm
Hello Angie: Getting alittle testy here , are you. Well I have to put you in your place. Just kidding. I actually read all comments here, and Angie I do agree with you. I just switched my 3 pit bull/beagles from Iams pro active to Pure Balance Salmon variety. It was only 2 days before I noticed my 6 year old no longer was limping with arthritis like symptoms. She had this problem for like 3 years and I assumed it was permanent and chronic so I just added glucosamine chondrition pills to her daily regimen. It did help but now I no longer need to give her the glucosamine chondritin since I switched to Tru Balance(which is owned by Walmart by the way)—-a reasonably priced decent dry kibble dog food. So my guess, is Iams pro active had a toxic preservative in it(sometimes not listed in fish meal for example) or the poultry by product was some junk protein she was reacting to. If Tru Balance is banned on this website, it ain’t banned in my home. Their coats and energy level took an amazing improvement. Cheers to you Angie. Next thing you know, they will be asking you how much stock you have in Walmart. I wish I did. Cheers to all here for some great input.
Susan Thixton
June 7, 2018 at 8:54 pm
This website doesn’t “ban” any pet food. It educates pet food consumers.
Nemanja Jefic
September 20, 2018 at 3:00 pm
It’s the same way in Canada as well lots of animal by products in cat food and cats treats