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Pet Food Ingredients

State Laws are Sabotaging Pet Food

Laws require transparency within the pet food industry, but not for you.

Arizona law – Section R3-2-201 – Definitions – defines a dead animal as: “an animal that died other than by slaughter in a place where inspection is performed by the Department or by the United States Department of Agriculture.” Arizona law allows: “a dead animal carcass may be rendered or made into animal food only at a licensed rendering or animal food manufacturing plant…”

Arizona law also requires meat from dead animals to be “decharacterized” or denatured; “All denaturing shall be done immediately upon condemnation of the meat or product…” Arizona suggests powdered or liquid charcoal or dyes as approved denaturant agents.

Arizona requires each shipment of condemned animal material to be labeled with (bold added):

  1. The kind of animal
  2. The follow phrases:
    i. For pet food only from dead animals,
    ii. Denatured with _______________.
  3. The correct statement of net weight, and
  4. The name and address of processor or manufacturer.”

In other words, the state of Arizona requires full disclosure of condemned animal material – who processes it and who receives it – up until the condemned animal material becomes a pet food. Pet food manufacturers (purchasing this condemned animal material) are required by state law to be informed to what they are buying – but Arizona does NOT require the same disclosure to pet owners to what they are buying.

The legally required transparency abruptly stops when the condemned animal material becomes a pet food.

Colorado state law includes “the Colorado Inedible Meat Rendering and Processing Act”. These Colorado laws define 3-D and 4-D meats as:

  • 4-D means meat and meat products derived from dead, dying, disabled, diseased or
    condemned animals
    .”
  • 3-D means meat and meat products derived from animals which were slaughtered.”

Colorado law includes requirements for “disposal plants” (that dispose of 4-D and 3-D meats) including regulations regarding conditions at plants, vehicles that transport dead animal carcasses, and more. Colorado also requires the condemned meats to be denatured and requires each shipment from disposal plants to include a label that is approved by Colorado Department of Agriculture.

Colorado laws for packaged products that contain 3-D and/or 4-D meat…

As used herein, “prepared and packaged products” means inedible meat products which have been prepared by drying, heat processing, smoking, jerking, pressing, forming, stuffing in casing or similar end-processing and packaged. The packages and containers shall display a statement in capital letters, “FOR DOGS,” “FOR CATS,” “FOR PETS,” “DOG TREATS,” “CAT TREATS,” “PET TREATS,” or similar statement denoting that the product is for other than human food…”

But these laws ONLY require pet products made with 3-D and/or 4-D material to be labeled as ‘For Dogs’ or “For Cats’ – no required disclosure to the consumer the products contain dangerous 3-D or 4-D animal material.

The state of Colorado knows exactly who receives every shipment of 3-D and 4-D meats (because they approve the label) – but pet owners do not.

The state of Indiana has Agriculture laws titled “Disposal of Dead Animals”. Indiana requires any person (or business) that transports non-slaughtered dead animals to properly label shipping containers. “The container must be clearly marked or stamped with the legend ‘Unfit for Human Consumption’. The meat may be hauled to the plant of a manufacturer of pet food or to the place of feeding to animals at places approved by the state veterinarian.”

Just like other states, Indiana also requires condemned animal material to be denatured – their law stating: “(a) Nonedible meat may be sold when properly decharacterized for shipment to a plant producing pet food or to a person for use in feeding mink and other animals as allowed by the state veterinarian.”

The state of Indiana knows exactly which pet food manufacturers receive condemned animal material because every shipment is “approved by the state veterinarian”. But Indiana law does NOT require disclosure of condemned animal material to pet owners. Those on the ‘inside’ know – but pet owners do not.

The state of Michigan has a multitude of laws specific to the disposal of dead animals. Michigan state law defines “dead animals” as: “means restaurant grease and the bodies, any part of the bodies, or any material produced from the bodies of animals that have been slaughtered or have died from any other cause and are not
intended for human food. Dead animals do not include a finished product that has been processed by an approved method
.”

Michigan law defines an “animal food manufacturing plant” as: “an establishment at which animal or pet food is produced through the slaughtering, boning, grinding, cooking, canning, or freezing of dead animals.”

The state of Michigan requires any business that transports dead animals to be licensed, charging a rendering plant “$375.00” annually and charging an animal food manufacturing plant “$200.00” annually. So – even though the state of Michigan knows exactly who processes condemned animal material (due to required licensing), Michigan state laws DO NOT require disclosure to consumers which pet foods are made with condemned animal material.

Nebraska law specifically states “material derived from seriously distressed animals or animals dead or dying other than by slaughter” to becapable of being processed into pet animal food”. Nebraska law requires each container of “inedible meat and carcass parts” be shipped with a form that includes number of containers, date and hour of shipment and pounds shipped. Nebraska also requires documentation of the “name of plant receiving inedible meat and carcass parts.”

The state of Nebraska knows exactly which pet food manufacturers receive condemned animal material, but pet owners do not. Nebraska law requires detailed transparency up until these ingredients become a pet food or treat and reach the consumer.

Even though we did not research laws in every state, we assume most states (if not all) have similar laws.

Why do state laws require such transparency and documentation to how and where condemned, diseased, 3-D and or 4-D animals are disposed of?

Because of the risk to human health. Strict laws are in place because authorities cannot allow this material to be processed into human food.

If diseased, condemned, 3-D or 4-D animal material is a serious risk for humans to consume, why is this material suddenly acceptable when included in a pet food?

Why do state laws stop short of requiring disclosure to pet owners?

We can only assume it’s because no one would purchase pet products that contain condemned, diseased, 3-D or 4-D animal material. States and industry’s only apparent concern is disposal of this animal waste, not properly informing the consumer to what they are purchasing.

This has to stop.

Pet food consumers deserve full transparency as to what they are purchasing in their pet’s food and treats. If state governments are approving the disposal of condemned animal material into pet food and requiring transparency to which pet food companies purchases this material, then state governments need to initiate state laws continuing that transparency down to pet food consumers. We must ask our state for these pet food transparency laws.

What you can do…

Contact your state government representatives via email or calling their local office. Tell them you’ve been made aware of state laws that allow dead animals, condemned animal material, 3-D and or 4-D animal material to be processed by rendering ultimately becoming pet food ingredients or allowed to be sold directly to pet food manufacturers. Tell them you are requesting full transparency to be required – by legislation – on pet food labels of products that contain any part of a diseased animal, condemned animal, 3-D or 4-D animal. Tell your state representative you deserve to be informed (on the pet food label) if the product contains inedible animal material.

Personal opinion: these laws were not easily found. No state regulatory authority has ever shared this information with me previously (even after more than a decade of speaking with state and federal pet food authorities). In researching another issue, I happened upon the laws of one state – and had to dig into government websites to find the other laws. These are laws regulators don’t want us to know about. It’s so wrong, so deceitful, it is difficult to put into words.

Your dog or cat is NOT a waste disposal system for your state’s hideous waste. Yes – diseased, condemned, 3-D and 4-D animal material must be properly disposed of. BUT – it should not be our pet’s responsibility to be the secret waste disposal system. We all need to demand to know exactly what we are buying – to know exactly what is in our pet’s food. Please contact your state representatives.

Wishing you and your pet the best –

Susan Thixton
Pet Food Safety Advocate
TruthaboutPetFood.com
Association for Truth in Pet Food


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2 Comments

2 Comments

  1. Sally

    September 1, 2022 at 2:02 pm

    Please explain the point or purpose of denaturing. What if you live in an agricultural red state, where filing complaints about animal welfare is laughed at, scoffed, or blatantly and repeatedly ignored. No state employee is ever accountable, and no one cares. I live in the hellhole backwater of Idaho.

    • Susan Thixton

      September 1, 2022 at 2:14 pm

      Condemned material is required by federal law to be denatured to clearly mark the material as inedible – an effort to prevent the material from entering the human food chain.
      My only suggestion is for you to keep asking your State officials for transparency. Believe me, I’ve been laughed at and scoffed for years – but I keep asking regardless to how I’m treated.

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