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Pet Food Regulations

Paying Double for Pet Food

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

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).”

“The LIP national payment rate for eligible livestock owners is based on 75 percent of the average fair market value of the livestock. An eligible loss condition includes any of the following that occur in the calendar year for which benefits are requested:
  • 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
Association for Truth in Pet Food


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10 Comments

10 Comments

  1. Chris

    October 11, 2018 at 12:46 pm

    What is “provided they are not otherwise in violation of the law”?

    including those using animals which have died otherwise than by slaughter, provided they are not otherwise in violation of the law.

    • Susan Thixton

      October 11, 2018 at 12:53 pm

      That means if the ingredient violates any other law (one that they enforce). As example FDA enforces a zero tolerance for live Salmonella bacteria. but the agency could care less about dead Salmonella bacteria which produce endotoxins that are more dangerous to the pet than live Salmonella bacteria. FDA practices “selective enforcement” which means they pick and choose which laws they enforce.

  2. Faith Jones

    October 11, 2018 at 2:55 pm

    Thank you, Susan for your continual research and information! Your unrelentless work has to make a difference! To just get FDA to do their job!

  3. Sharon

    October 11, 2018 at 6:48 pm

    So terribly sad!

  4. Anne

    October 11, 2018 at 7:14 pm

    Making the FDA accountable for doing its job in protecting the public and our animals would be a long and arduous battle.
    However – we are not powerless and we need to use our power where it will count. Stop buying dog and cat food. This will hit the manufacturers where it will be noticed — in their profits – until they become accountable for what they put in their food. Stop the chain of blame! The FDA doesn’t do its job, the meat suppliers sell tainted meat, and the pet food manufacturers don’t care about our companion’s health.
    Making your own food takes a little more time, but is better for our animals in the long run. I’ve been making my animal’s food for over 35 years and the payoff is in better health, longer lives, and fewer vet bills.

    • Opie Catt

      October 12, 2018 at 6:19 pm

      M-A-N-Y animal care-givers are elderly, handicapped or both — physically unable to COOK for themselves or their companion animals….how can they “stop buying petfood”???

      • Anne

        October 12, 2018 at 10:57 pm

        Hi Opie Catt. I am 77 and have physical issues also. There are quality food (not feed) grade pet foods available and I believe Susan has a list of manufacturers who have pledged to be transparent in their ingredients. Check out Find Healthy Pet Foods under Special Pages, Anne

  5. Robin

    October 13, 2018 at 12:37 pm

    Go super women Susan Thixton!!!!

  6. D

    October 15, 2018 at 3:41 am

    It’s good you posted this, but I hope people don’t come away from this thinking the USDA are heroes. The USDA has a ton of their own problems, mostly due to under-funding. The main thing is corruption due to their being “captured” by business they are supposed to regulate. I mean, the companies the USDA are supposed to be regulating *pay* for the USDA. Anyone can do the math on that. Plus, just for fun you can do a search for ” USDA regulatory capture applesauce mold school lunch ” for a story from years back that sticks in my mind.
    .
    Then there are the “privatized inspections.” Food and Water Watch did a recent article on some disgusting problems and how supervisors are pressuring workers not to stop the processing line no matter what here:
    http://www.foodandwaterwatch.org/news/usda-inspectors-pressured-keep-line-speeds-under-privatized-inspection-system
    .
    Definitely check out whistle-blowers here: http://www.foodwhistleblower.org/
    .
    There’s been problems with line speeds for eons but the USDA won’t change them. Mother Jones did a long article on Hormel processing a long time back. Didn’t mention the USDA directly but the line speed problems. The phrase that sticks in my mind is “pig-brain machine” making some kind of blood mist, which caused neuro problems for workers. The most recent story on foodwhistleblower.org is about the food privatization and the “dangerous and disgusting high-speed pork slaughter inspection system (NSIS).” It’s related, so the MJ article is a good backup to see what that means for workers.
    .
    Also, so much of our food goes uninspected because there aren’t enough inspectors. Which absurdly reminds me of the joke, “Such awful food. . . And such small portions!” It’s especially concerning when considering foods from other countries and that so much ‘meat’ is sent for processing to other countries and then sent back here.
    .
    There’s just not much good to be said about our regulatory agencies 🙁
    .
    .
    D

  7. D

    October 15, 2018 at 3:45 am

    We are disabled, too. The pet food list Susan has available on this site was helpful to us, even though there are very few companies selling cat food. If you have dogs there are a lot more choices.
    .
    I hope you can find something. For us, we were glad to find companies that delivered food and had already portioned frozen raw food.
    .
    D

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