Pet Owners told the FDA to STOP!

Pet owners stepped up in a BIG way, sending the FDA a strong message. Stop allowing waste to be dumped into pet foods, label products as feed or food.

In October of 2016, we (Association for Truth in Pet Food – representing pet owners) sent the formal document to FDA requesting the Agency to stop allowing pet food to violate federal law and to properly label pet products as food or feed. In April of 2019 (2 1/2 years later), the FDA responded with a definite “No“. In July of 2019, we asked the FDA to reconsider by filing a Petition for Reconsideration. And 788 pet owners have added their comments to the reconsideration, sending FDA a very strong message.

Below are just a few of the comments posted on the government website regarding our Petition for Reconsideration:

From Anonymous: I strongly feel that dog and cat food should NOT be allowed to be made from diseased, dying, dead, or decaying animals. I do not want to feed trash to my beloved fur covered companions. And that is what 4d meats are in pet food. Trash, garbage, rubbish that is being sold to make pet food so pet food companies can get rich by selling garbage instead of putting quality meats in their pet foods. Our pets deserve quality food as much as we do. As a consumer I want to know by reading the pet food label whether I am buying a pet food or a pet feed. Please do the right thing and stop allowing 4d animals to be used in making pet food and please require clear transparent labeling on pet food packaging that specifies whether its a food or a feed so consumers can make an informed decision on what they are feeding their pets.

From Linda: To protect the well-being of our pets, it is urgent that the FDA stop allowing pet food ingredients to be sourced from diseased animals or animals that have died otherwise than by slaughter. These are contaminated ingredients!

Many pet owners pointed out to FDA how ridiculous it is that we have to ask them to enforce law:

From Ryann: This is deeply concerning that we even have to be begging for this to be reconsidered. It should all just be human grade. I fully support the petition for reconsideration.

From Julie: I fully support the Petition for Reconsideration. OF COURSE PETS SHOULD NOT BE EATING FOOD THAT CLEARLY GOES AGAINST ESTABLISHED BEST PRACTICE. It is astonishing that we need to tell you this. Good heavens.

From Diane: I totally support all aspects of this Petition for Reconsideration. If I would not eat it, neither will my dogs. The fact that your regulations allow and has allowed for such a practice for years is totally beyond my comprehension.

From Sue: The FDA must start listening and DOING their job!! They are supposed to be protecting our pets and us. It’s absolutely mind blowing that they are taking this serious issue so lightly. Yes it will cost money to regulate and maintain proper guidelines but it has to be done to protect the innocence that are eating this crap that we as consumers are trusting that is safe to feed out pets!

From Rhonda: I can’t believe this is an issue. Our pets are family and should be fed human grade food. Not food with everything under the sun in it. Dead animal parts, dyes, ect. Take the trash food off the market…please help.

From Carolyn: This is ridiculous and inane… The laws are written, please enforce them!

From Anonymous: This is unbelievable. We entrust our federal agencies to protect us (and our pets). If the downed animal is not fit for human consumption, then it is not fit for dog/cat food either!  

From Charles: I strongly support this petition. It should not be an agency option to ignore the law. Enforce the law; do your job as defined by congress, not by industry.  

From Crystal: I’m appalled at your response, “we do not believe that the use of diseased animals or animals that died otherwise than by slaughter to animal food (or do you mean ‘feed’ and made yet another uneducated decision) poses a safety concern”. My understanding is that diseased animals or animals that died by means other than slaughter is officially a violation of federal law in human or animal food. I’m asking you to simply do your job correctly. How many more pets must die due to Pentobarbital (the euthanasia drug) in pet food? How many more pets must die from cancer? Over half of every dog over the age of 10 will get cancer is what the current statistics are showing. It’s simple common sense; we should be able to know exactly what is in the food we choose to feed our pets. Pet foods should be clearly marked as either ‘food’ or ‘feed’, depending on the ingredients. The American public is no longer uneducated about these things and want to know not only what is in our food, but our pet’s food as well. Do not make us question the reason why you would be opposed to transparency to the ingredients in pet food or why you went to the pet food makers before deciding against this request. I don’t know why you should not be held accountable to enforce the law. I fully support the Petition for Reconsideration and as an American citizen who is trusting the motives of the FDA in various areas less and less, I expect you to do your job and do it correctly without bias.

From Jeanne: PROVE to us you are not corrupt>>> Do your job to protect our animals and people>>

Veterinarian Dr. Jean Hofve gave FDA an earful, including scientific evidence that waste pet food ingredients allowed by FDA are dangerous to pets:

From Dr. Jean Hofve: As a veterinarian with 25 years of experience, and as an industry advisor to the Association of American Feed Control Officials (AAFCO), I strongly support reconsideration of the petition from the Association for Truth In Pet Food.

The Federal Food, Drug and Cosmetic Act defines an adulterated food (in part) as: A food shall be deemed to be adulterated if it is, in whole or in part, the product of a diseased animal or of an animal which has died otherwise than by slaughter.”

In the AAFCO Model Bill, it states that a product is adulterated “If it is, in whole or in part, the product of a diseased animal or an animal which has died otherwise than by slaughter which is unsafe within the meaning of Section 402(a)(1) or (2) of the [FFDCA] (p 112).

There are several important reasons why products considered adulterated under the FFDCA are, in fact, dangerous to dogs and cats.

1. Live bacteria. Despite rendering, live coliforms have been cultured from rendered meat meal. [Strombeck DJ. 2010. Home-prepared diets for dogs and cats. 2010. Wiley-Blackwell.]

2. Bacterial Endotoxins. While canning and rendering kill bacteria, they do not eliminate the endotoxins that some organisms produce. These contaminants can survive processing and cause sickness and disease. Dead bacteria release large amounts of endotoxin. Unlike bacteria, endotoxins are not altered by processing. Even a small amount of endotoxin present in the finished product can make pets sick.

3. Bacterial Spores. Certain types of bacteria, including common food-borne strains like Clostridia and Bacillus, produce spores as part of their reproductive process. These spores are extremely resistant to pasteurization, boiling, freezing, acid, and high heat. They can survive the processing that pet food undergoes. [Andersson et al. Intl J Food Microbiol,1995 Dec;28(2):145-55, Franke-Whittle IH et al. Crit Rev Microbiol, 2013; 39(2): 139151. Professor James Cullor of UC Davis [personal communication 1999] suggested that many cases of “garbage gut” (vomiting or diarrhea of unknown cause) in dogs were likely caused by Bacillus cereus, which he cultured from the surface of >50 dry dog foods.

4. Antibiotic Resistant Organisms. Food animals can become hosts to antibiotic-resistant bacteria through either contaminated feed or administration of subtherapeutic antibiotics. While most bacteria are killed during pet food processing, fragments of bacteria or bacterial DNA can pass the resistant trait to resident organisms in a pets digestive tract. These can be transmitted to humans and other animals through fecal contamination of the environment. [Davis 2003] One study found multi-drug resistant Enterococci and methicillin-resistant Staphylococcus aureus from dog fecal samples collected from city streets and sidewalks. The presence of the resistant bacteria in an urban environment may represent a serious public health hazard. [Cinquepalmi et al. Intl J Envir Res Pub Health, 2013 Jan; 10(1): 7284.]

It has been known for many years that overuse of antibiotics in livestock are a factor in multi-drug resistance and human illness. Recycling animal waste into animal feed has been practiced for > 40 years as a means of cutting feed costs [AAFCO] advises that processed animal waste should not contain pathogenic microorganisms, pesticide residues, or drug residues that could harm animals or eventually be detected in animal-based food products intended for human consumption. Nonetheless, these guidelines are not adequately enforced at the federal or state level. [Sapkota 2007]

Moreover, there are kidney-toxic antibiotics used in livestock that are extremely restricted, with long withdrawal times before slaughter for human food; but if livestock die with high levels of drugs in their systems, they are condemned for human consumption but are still rendered and used in pet food, resulting in dangerous contamination that can harm pets.

5. Mycotoxins. When mycotoxins are present in feed consumed by livestock, they can contaminate meat and milk from those animals. This is significant because even if a manufacturer tests grain products for mycotoxins, it may completely miss significant levels in animal-source ingredients. Very little if any destruction occurs under normal heat-processing conditions and temperatures. Aflatoxin, for example, is highly carcinogenic and can cause disease even at low levels of exposure. [Milievi DR et al. Toxins, 2010;2: 572-592, Buss et al. Carcinogenesis, 1990; 11(12):2133-2135.]

6. Pharmaceutical drugs. Because sick or dead animals are frequently processed for pet foods, the drugs that were used to treat or euthanize them may still be present in pet food. Pentobarbital has recently been found in many pet foods by FDA itself, indicating that this is an ongoing problem; one that is entirely due to the use in pet food of animals that died otherwise than by slaughter.

Many pet owners explained to FDA the challenges we face due to their allowance of illegal pet foods:

From Anonymous: Quote of FDA – We do not believe that the use of diseased animals or animals that died otherwise than by slaughter to make animal food poses a safety concern as long as hazards are controlled.

Scenario – You take your family to a barbecue hosted by neighbors new to your subdivision. A delicious meal is served, including various kinds of meat. The grilled meat is especially delicious, with tantalizing favors due to previous marinating. Your children especially love the meats. Oddly, upon returning home all family members experience digestive issues which you attribute to the rich marinades.

A few days later, when you travel down a country road, you spot your new neighbor picking up road kill. Seeing you, he quickly shuts his trunk but you get a good look at various mangled meats stored there. Putting two and two together, you are overcome with nausea. What bothers you most is that you had taken your family, your children to that deadly barbecue. The need for rich marinades becomes clear. So you head to the police station to report the crime.

Would you pick up a decomposing animal from the side of the road and feed it to your pet? I think not. Yet that’s what pet owners are innocently part of. FDA is our watchdog, if you will, to protect our pets. Please put the safety of our pets before all other enticements, including lobbyists offers and big name pet food companies questionable claims. Using common sense, one realizes that diseased and other damaged meats are not safe therefore not a viable option to include in pet foods. We pet owners will continue to fight for safe practices, for transparency concerning pet food ingredients and finally for appropriate and uncompromised FDA rulings which protect our pets.

From Judy L: Our pets are dying at younger ages and the use of diseased or euthanized animals as food for our pets is disgusting and should not be allowed to continue. Also, as a consumer I would like to see clear labeling as to ingredients whether they are considered to be food or feed. It does make a difference!

From Laura: Pets are part of the family, we love them same as our kids. We invest money to keep our family member healthy and what we feed them is a huge part of their overall health. We can have regular check ups, get enough exercise, brush their teeth and keep them well groomed. We have control over our pets health and we take it very seriously. One thing we don’t have control over is being properly informed. We do not have a clear understanding of what is in a food and the quality of ingredients. It is a failure to us the consumer. I ask that you side with our family, for the sake of their health! Now is not the time to side with big Corporate money.

From Mary: I lost my cat because of a direct result from eating a certain brand her whole life and I know that some of the ingredients as I’m sure the FDA also knows they cause cancer, diabetes, food allergies just to mention a few. So Yes I believe in what we’re asking from the FDA! I know the FDA needs to modify current pet food ingredient definitions and require all animal protein ingredients to be sourced from slaughtered animals.

I’m asking like so many other animal lovers for the FDA to require pet products to be labeled as food for example Cat Food and Dog Food only if they meet the legal requirements of food. Please label all other products as feed such as Cat Feed, Dog Feed providing pet owners with transparency and honestly labeled products.

From Brenda: I have two dogs whom I’ve rescued from shelters. They have both transformed from fear and anxiety to love and affection. Today after 7 and 8 years (I got them a year from one another), and they work as therapy dogs for Mercy Hospice in the Soul program as well as reading dogs for elementary school children. As you can see, these dogs are not just animals, they are an active and integral members of the community. This is why the food I provide them is critical to their healthy longevity. I’m concerned that dog food companies have no regulatory rules to stick with as in human food. As important as my dogs are in the work they do, they deserve the very best in nourishment for their longevity and continuing their important work.

As a pet mom, I have the right to know whether my dogs food is made of real food or animal “feed” which is not real food. Please help protect our furry family and community members. We need to speak for those who are unable to speak for themselves.

I would like the FDA to require pet products to be labeled as food (Cat Food, Dog Food) ONLY if they meet the legal requirements of food. I am asking for all other products to be labeled as feed (Cat Feed, Dog Feed) providing pet owners with transparency and honestly labeled products.

From Ann: As a dog breeder, the health of my dogs is of utmost importance. It disgusts me that drug riddled rotting carcasses can be put in dog “feed”. I want to feed my dogs food, not “feed”. I am asking FDA to STOP allowing pet food ingredients to be sourced from diseased animals or animals that have died otherwise than by slaughter (such as euthanized animals or animals that died in the field).

From Abram: As a citizen who is a pet guardian who try’s to purchase clean & nutritional food for my pets health and wellbeing I request that standards be changed to make all ingredients food quality NOT feed grade. This with oversight to guarantee that my purchases are edible, nutritious and safe for the wellbeing of my feline companions. Please note that these are my companions for up to 20 years and I do not want greed and corporate profit to kill them. The advertisements sway buyers to purchase “healthy” food and yet on more occasions I note that there are recalls only after significant numbers of pets are dead. Please, let’s try and correct this situation for the future.

From Wanda: I want to know what I am feeding the little ones that depend on me!

In comment after comment, pet owners told the FDA to “Stop” allowing illegal waste into pet food. “Stop” allowing pet food to lie to consumers.

But there was one opposing comment:

From Anonymous: I do NOT believe that FDA is working in an improper manner. I would NOT ask FDA to stop allowing pet food ingredients to be sourced from diseased animals or animals that have died otherwise than by slaughter.

I would NEVER ask FDA to modify current pet food ingredient definitions requiring all animal protein ingredients to be sourced from slaughtered animals.

It would be ridiculous and stupid to require pet products to be labeled as food (Cat Food, Dog Food) if they meet the legal requirements of food and to ask for all other products to be labeled as feed (Cat Feed, Dog Feed). Anyone who would ask for this has NO concept of agriculture or food production.  

Based on the “What’s Trending” section on the Regulations.gov homepage, the comments from pet owners received on our Petition for Reconsideration are the 3rd highest number of comments received on any current issue; 788 in favor, 1 opposed. Three cheers for us!

We made a strong statement to FDA. Only time will tell if FDA will finally listen to us; we continue to wait for their decision. My sincere thank you to all that have shared with FDA your comments on illegal pet foods and the pet food/feed transparency issues (with exception of the one comment opposing).

The FDA is still accepting comments on this issue (it is unknown how long comments will be accepted). If you would like to add your message to FDA, Click Here to read background information and help on how to post a comment.

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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