Paying Double for Pet Food

Because USDA enforces law and the FDA doesn’t, consumers pay double for illegal pet food ingredients.

First: this article is in NO way opposing US farmers or the federal support they receive. This article is strictly opposing the fact that pet food consumers are far too often short changed in their efforts to find safe, healthy pet food.

The USDA provides livestock farmers a sort-of insurance policy in case of “excess of normal” animal deaths. This (sort-of) insurance policy is called the Livestock Indemnity Program. Quoting a pamphlet explaining the program: “The 2014 Farm Bill authorized the Livestock Indemnity Program (LIP) to provide benefits to eligible livestock owners or contract growers for livestock deaths in excess of normal mortality caused by eligible loss conditions, including eligible adverse weather, eligible disease and eligible attacks (attacks by animals reintroduced into the wild by the federal government or protected by federal law, including wolves and avian predators).”

• Eligible adverse weather event;
• Eligible disease; and
• Eligible attack.”

An example of a “eligible adverse weather event” was Hurricane Florence that hit North Carolina so badly in September 2018. The catastrophic flooding from Hurricane Florence resulted in the death of at least “5,500 pigs and 3.4 million chickens” according to the North Carolina Department of Agriculture and Consumer Services – published in the Charlotte Observer newspaper September 18, 2018. The animals drowned.

The farmers that lost the “5,500 pigs and 3.4 million chickens” will be reimbursed for the animal deaths through the USDA Livestock Indemnity Program (LIP). Per the USDA LIP reimbursement fees, we can estimate that livestock farmers in North Carolina received from USDA:

• $9,146,000.00 reimbursement for 3.4 million chicken deaths*
• $527,340.00 reimbursement for 5,500 pigs deaths*
  

*Reimbursement totals are estimates based on the average “2018 Payment Price Per Head” in the USDA Livestock Indemnity Program Fact Sheet.

And now for the kick to the gut to pet owners…

The USDA and the FDA are two VERY different federal agencies. They differ on what they regulate and in many instances (including this one) they differ in HOW they regulate. The USDA Livestock Indemnity Program reimburses livestock farmers because USDA considers drowned livestock as a complete financial loss to the farmer. The USDA considers any animal that has ‘died otherwise than by slaughter’ (such as drowned animals) to be adulterated and not allowed in any food – human or animal. Making very clear their position on drowned livestock (animals that did not go through the USDA inspection process), Food Safety Inspection Service (FSIS) Directive 12,7001.1 clearly states the agency’s stance on meat that did not pass inspection (such as drowned livestock): “Product produced or prepared without inspection coverage is not eligible for donation into human food channels or for sale into pet food or other animal feed channels.”

But the FDA has a different stance. The FDA believes that “animals which have died otherwise than by slaughter” – even though their use in any food would violate federal law – are perfectly acceptable to use in animal feed/pet food. FDA Compliance Policy 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.” The thousands of drowned livestock in North Carolina are a perfect example of “animals which have died otherwise than by slaughter”. The FDA – unlike the USDA – believes decomposing animal material and much other waste ingredients are acceptable for animals to consume.

It boils down to this…USDA strictly enforces law while the FDA openly allows law to be violated. But there is one more issue: US tax payers are who fund the USDA Livestock Indemnity Program. Our tax dollars are spent to reimburse farmers – because drowned livestock are NOT food. The USDA program that we pay for, was NOT developed to provide cheap waste pet food ingredients. It was developed only to help farmers when weather destroys their livelihood. In essence, pet owners are paying DOUBLE. Once from their tax dollars to fund the USDA Livestock Indemnity Program, and twice when they purchase a pet food that contains the rendered drowned animals (which by the way they are NOT informed contains rendered drowned animals).

US taxpayers should NOT be paying for pet food to violate law. Pet owners desperately seek healthy pet foods, but how can they find that not knowing which pet food contains rendered drowned livestock? The FDA must be stopped.

Wishing you and your pet(s) the best,

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