The Dividing Line Between Food and Feed

Food can be recalled for lack of inspection. Why haven’t we seen a pet food recalled for lack of inspection?

On October 17, 2020 the USDA (United States Department of Agriculture) issued a recall for two foods (human foods) because they were not manufactured under inspection. “Taher, Inc., a Plymouth, Minn. firm, is recalling approximately 22,096 pounds of meat products that were produced without the benefit of federal inspection, the U.S. Department of Agriculture’s Food Safety and Inspection Service (FSIS) announced today.“

The USDA requires that all foods with 2% or more meat to be produced under inspection. A USDA representative must be present when the food is manufactured. In the above case, 4 bags of “Fresh Seasons Tator Tot Hot Dish” and 4 bags of “Fresh Seasons Sloppy Joe” were manufactured without a USDA Food Safety representative present (were not manufactured under inspection) and the food was forced to recall.

Why haven’t we seen a recall like this in pet food?

The USDA and the FDA have separate jurisdictions. With the exception of (most) pet food, the USDA has jurisdiction over all foods that contain 2% or more meat. The FDA has jurisdiction over all foods that contain less than 2% meat.

Pet foods – for some unknown reason – are part of FDA jurisdiction even though they contain more than 2% meat. Thus, (most) pet foods are not held to the USDA requirement to be manufactured under inspection like any other food product (that contains more than 2% meat).

[It is assumed that pet foods were grandfathered in under FDA jurisdiction after animal feeds. Animal feeds such as livestock feeds, that contain no to minimal meat, began under FDA regulation. Pet foods followed animal feed and we can assume they automatically fell under FDA jurisdiction as another animal ‘food’.]

The exception is Human Grade pet foods (pet foods with the words Human Grade on the label – ignore the marketing claims). Only pet foods that meet the full requirement of Human Grade are produced under USDA inspection. They are treated no differently than any food with more than 2% meat.

Human grade pet foods are still regulated by FDA, but they as well are regulated and inspected by USDA during the manufacturing process. USDA inspection gives pet owners a guarantee all ingredients are human edible (including supplements) and the pet food was manufactured per human food safety standards.

There is another exception, but this exception is not so easily identified. Raw pet foods are not allowed to make the Human Grade claim on their label – but some are manufactured under USDA inspection and meet every legal requirement of the Human Grade claim. Pet owners can ask their raw pet food manufacturer if they are manufactured under inspection.

The dividing line – in this case – between Human Grade pet foods (and some raw pet foods) is inspection during manufacturing. A USDA representative at the manufacturing facility whose responsibility is to assure the consumer all food safety laws are abided by.

The FDA inspects pet food plants AFTER a problem occurs (such as reports of sick or dying pets), but not during manufacturing as is required of food (with more than 2% meat). The USDA inspection during manufacturing is preventative, the FDA approach of inspecting after a problem is reported is only reactive.

Inspection is a little thought of thing that happens everyday with our own foods, but it is a significant big step in pet food. Inspection separates food from feed.

Wishing you and your pet(s) the best,

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

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