No kidding, they do. Are you ok with that?
On April 30, 2019, the FDA issued a public notice that on the surface appeared to be good news for pet owners. “In a continued commitment to the agency’s modernized risk-based approach to the regulation of animal food…the U.S. Food and Drug Administration today withdrew three outdated Compliance Policy Guides (CPGs) pertaining to the use of certain animal-derived materials in animal food.”
Sounds promising, doesn’t it? It’s not. In fact, there is NOTHING “modernized” about it. It’s the same old FDA song and dance. FDA will continue to allow pet food to violate federal law, continue to allow pet food to contain diseased and non-slaughtered animal material and the agency REFUSES to alert pet owners to which pet foods contain this illegal waste.
Why did FDA issue this notice?
The short answer is that FDA no longer wants pet owners to see – on the FDA website – what they actually allow in pet food. By withdrawing the compliance policies, pet owners can no longer see the cold, harsh reality of what FDA allows in pet food right on the FDA website. Below is screen shot images of the withdrawn policies highlighting the FDA policy:
The agency removed those policies ONLY for their benefit, not for the benefit of pets. The above pages are now poof!, gone. Click Here to see the current page of CPG 690.300 and Click Here to see the current page of CPG 675.400.
The policies are gone, but those waste ingredients in pet food are NOT. They are still just as openly allowed in pet food as they were previously, but now FDA is allowing them behind their secret curtain of “enforcement discretion“.
Evidence.
In October of 2016, our pet owner association (AssociationforTruthinPetFood.com) filed a Citizen Petition with FDA. A Citizen Petition is the required procedure to follow when asking the FDA to change their current enforcement procedure.
In short, we asked the agency to stop allowing diseased animal material and material from animals that have died otherwise than by slaughter (or illegal animal material) into pet food.
We also asked FDA, to properly label pet products as Dog Food and Cat Food if the products met the requirements of food, or label pet products as Dog Feed and Cat Feed if they did not meet the legal requirements of food.
Two and a half years later (4/30/2019), the FDA said: “No” to everything.
To read our Citizen Petition, addendum and FDA’s response Click Here.
Regarding our request asking the FDA to stop allowing diseased animal material and material from animals that have died otherwise than by slaughter into pet food, the FDA said:
“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 and we intend to continue to exercise enforcement discretion where appropriate.”
In other words, the FDA believes it is perfectly safe for your pet to consume condemned inedible diseased chicken or beef from a decomposing carcass of a cow that died in the field 5 days before it was rendered.
In no uncertain terms, this FDA response classifies cats and dogs as obligate scavengers.
Per Wikipedia.org: “Scavengers are animals that consume dead organisms that have died from causes other than predation. Obligate scavenging is rare among vertebrates (excluding the pets consuming diseased and dead waste pet food day in and day out), due to the difficulty of finding enough carrion without expending too much energy. Scavenging may provide a direct and indirect method for transmitting disease between animals. Scavengers of infected carcasses may become hosts for certain pathogens and consequently vectors of disease themselves.”
Do you consider your pet a scavenger?
Regarding our request asking FDA to properly label pet products as Cat Food/Dog Food or Cat Feed/Dog Feed to alert pet owners to the possibility of waste ingredients included – the FDA stated:
“You provided no evidence that human consumers believe that all pet food is equivalent to human food or that it would help consumers to know specifically how pet food differs from human food.”
So, not only is FDA classifying cats and dogs as obligate scavengers, the agency also doesn’t believe it is necessary for pet owners to be warned or alerted that pet food DOES contain carrion (the decaying flesh of dead animals).
Is this acceptable to you?
Is it acceptable to you that FDA declares pets to be scavengers? Is it acceptable to you that cooked rotting animal flesh pet foods are sold in every grocery across the U.S. – one aisle over from your food? Are you concerned of what diseases could be spread by these scavenger pet foods? (By the way, you should be concerned – click here.)
Diseased animal material in ANY food (human food or animal food) is a direct violation of federal law. Decomposing animal tissue in ANY food (human food or animal food) is a direct violation of federal law. With no doubt, this material IS dangerous, is illegal for a valid reason.
Tell the FDA exactly how you feel. Don’t put it off, don’t wait. Tell the FDA pets are not obligate scavengers.
Call FDA at 240-402-7002 or Email FDA at AskCVM@fda.hhs.gov.
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
Become a member of our pet food consumer Association. Association for Truth in Pet Food is a a stakeholder organization representing the voice of pet food consumers at AAFCO and with FDA. Your membership helps representatives attend meetings and voice consumer concerns with regulatory authorities. Click Here to learn more.
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The 2019 List
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Cannoliamo
May 1, 2019 at 2:42 pm
FDA is now relying on regulatory obfuscation to hide the truth from pet owners about their unwillingness to serve as a regulatory authority to protect our pets. I find that very sad and disappointing, but I know (as they do) there’s not much anybody can do about their complacency and indifference to the nutritional necessities and contamination safeguards for these pets to enjoy a healthy life. They are demonstrating the same ambivalence that has caused so many past acute and chronic illnesses (and deaths) among our pets in direct opposition to their charter. This is indeed an agency without a conscience and without accountability for their administrative negligence.
Lonnie
May 2, 2019 at 3:10 pm
well said my friend!
~Pet Owner~
May 2, 2019 at 3:55 pm
This factual article like many others (see my links below) are not only posted to empower PF consumers to make better choices. BUT to make pet owners angry! Not shut them down in defeat (“… there’s not much anybody can do about their complacency and indifference to the nutritional necessities ….”). As an author spending hundreds of hours motivating the public, wouldn’t the above attitude make a person feel they have just wasted a lot of time?
(“This is indeed an agency without a conscience and without accountability for their administrative negligence.”) No. The complacency and indifference lies with PF consumers who fail to make their voices known. Exactly what “regulatory authority” counts on! How many readers confirm they’ve called or emailed. How many will reject their Vet’s incorrect nutritional advice.
While social media is an irreplaceable tool for information exchange, those who “check-out” from “reality checks” can barely be counted on anymore for EVEN a few strategic keystrokes where they count. Meaning, how hard is to generate an avalanche of disgust and criticism aimed at where it belongs. The Agencies, the AVMA, and the Media. Be sure to mention (by the way) that you no longer buy trashy PF!
T Allen
May 1, 2019 at 2:53 pm
There are no words…. This needs to be on the nightly news!
Sharon Bilotta-Testa
May 2, 2019 at 5:02 am
FDA is controlled by the greedy deceptive corruptive government! Put NO faith in either THEY JUSY DONT CARE ABOUT PEOPLE OR ALL GOD’S creatures!!!
nikki121
May 2, 2019 at 6:50 pm
It never will because they make sure the media moguls would never let out any REAL meaningful news.
Dr. Laurie Coger
May 1, 2019 at 3:15 pm
WTF? Obligate scavengers? Do you want to feed your dog according to his biology, or as an obligate scavenger will be my new question for every dog owner!
~Pet Owner~
May 1, 2019 at 5:11 pm
So let’s clear out a couple of cobwebs first! Do Veterinarian Colleges fail to provide legitimate animal nutrition courses (yes). Are VC’s obligated by corporate brand name grant money (yes). Are Vets under pressure to pay back student loans (yes). Are donations made for small animal medical research (yes). Hopefully rebuttals to the following comment have now been avoided.
Over on this thread https://truthaboutpetfood.com/is-it-any-wonder-pet-owners-are-suspicious/ I spent a very considerable amount of time responding to a Reader’s comments who said: “I am so sad to read stories of how people are still going to their ‘trusted’ vet (who have been) determined to be uncommon, who have any common sense, or actual genuine care for our beloved dogs and cats.” “…(who’re) are suffering so badly because of greed.” “… it’s up to us to speak up everywhere we can.” “I do blame pet food manufacturers, but also vets, who are also part of corporate America, and tied in financially with the food and pills they prescribe in sales.” And I was pretty bummed by her callous response. Until I thought through it.
After reading today’s article, it’s clear PF advocates (us) increase the stakes in the name of PF advocacy! As recommended action, it’s fine for as many as possible letters and phone calls to trickle into our Representatives’ offices. But now we have to put pressure on our Vets, especially the AVMA to support this effort. Afterall what’s the point of treating illnesses that can be prevented by avoiding garbage filled PF. And this article makes that point CRYSTAL clear.
But first Vets require education, and at least orientation, to what we’re talking about, meaning by giving them access to a stream of articles that (in total) point to the PFI’s deceptive practices and the FDA’s collusion with the interests of big business & agriculture instead of benefitting the consumer. We are NEVER – ever – going to change their behavior UNTIL the financial impact (of a growing number of well-informed pet owners) is collectivized and highly incentivized!! But they will never feel that impact unless (and until) they are informed!
What better way than for the clients of Veterinarians to state that they will no longer patronize those who are pushing substandard OTC products – without being informed of worthy alternatives. And to avoid Veterinarian Hospitals connected with corporate PF supply stores, unless they include worthy PF alternatives too. THOSE are the real kinds of letters & calls that need to happen! For the purpose of explaining why the mentality of the (assumed) “average” PF consumer is changing!
YOU are that person!
For all the Readers who consider this yet another futile effort (on a par with one in thousands of issues already landing on your Representatives’ desks) ask yourself how long was smoking considered a carcinogen before your PCP ever had a conversation with you about stopping. (And no doubt while probably lighting up a cigarette on a break). It’s been proven obesity is linked to heart disease (and cancer). Now it’s clear that exercise & diet are the proper alternatives. The point being that conversation (motivation/reasoning) is the catalyst for action.
(One) I recommended that a database email list be used to send out regular TAPF Newsletters to Vets nationwide. Because education is a building process which is the only way conversations can begin. The TAPF has a decade of archived information and that information has been carefully researched. Will some Vets consider it “spam” (no doubt). Will it catch the attention of others (maybe). Will it provide the reasons why clients object to the sale of undeserving products (perhaps). But it will also demonstrate the growing awareness of informed pet owners – thanks to the internet – which Vets (and eventually the AVMA) might as well accept as revelation here to stay.
(Two) To counter the intimidation of professionals, here are a few powerful TAPF articles:
1) https://truthaboutpetfood.com/top-5-only-in-pet-food/
2) https://truthaboutpetfood.com/is-meat-from-diseased-and-non-slaughtered-animals-in-pet-food-safe/
3) https://truthaboutpetfood.com/a-pet-food-betrayal-like-none-other/
4) https://truthaboutpetfood.com/an-unbelievable-conflict-of-interest/
When your Vet refuses to validate your concerns, then it’s time to move on in order to find the one who will! Strength ONLY happens from numbers!
Tamara Terry
May 2, 2019 at 7:11 am
Great info! I’ve talked to at least 6 vets about how much time they get trained in veterinary school about pet food nutrition. They have told me FOUR hours and that four hours is taught by Hills, Science Diet, etc. This is how vets make the majority of their money…selling crappy prescription pet food and over vaccinating. I’d love to send our vet all this info…but we just got a new vet in December 2017 and we have independently rescued feral cats for over 14 years. We spend at least $500/month on premium wet and dry (not supposed to feed cats dry food) grain-free cat foods…and some months we even buy http://www.nomnomnow.com because I don’t have time to cook raw food. But, despite feeding them good food we still get kitties with dental disease and have to get their teeth extracted (many of them lived in the wild before), CRF, hyperthyroid, etc. Because of the Truth About Pet Food website (which I found back in 2007 but haven’t kept up on everything), my stomach turns when I see some man in the grocery store all dressed up in an expensive Italian suit buying Gravy Train and Alpo for his dog. I want to say something….I just shake my head in disbelief…that someone feeds their animals that crap. Hmm… should send our vet some of these articles….but my bf said I might piss her off and then we would have to find another vet. 🙁
Terrie
May 1, 2019 at 6:53 pm
This kind of makes me giggle…because commercial pet food proponents, including many veterinarians are constantly harping that home cooked diets are potentially unbalanced and unhealthy for your dog, and raw diets are potentially laden with pathogens and unhealthy for you and your dog. How does that jive with ‘pets are scavengers” I wonder…
Jenn Hahn
May 2, 2019 at 9:59 am
The f.d.a should stand for FICTIONAL DATA AGENCY
BC
May 3, 2019 at 7:00 pm
You will find this interesting about our jackbooted thugs at the FDA
https://pacificlegal.org/1860unconstitutionalrules/
Maxine Schmidt
May 3, 2019 at 10:11 pm
Surely not happy with the job they’re doing.
Kay
June 28, 2019 at 10:01 pm
Well they are actually correct about the scavenger thing, the domestic dog IS a scavenger despite how much people like to throw the “pack” word around. That being said I don’t think it is at all appropriate to say they should be eating the filthy remains of rotting animals simply because the factories have low standards. That’s just straight up bullshit. Yet again, dog industry standards are garbage.
(If you’re interested in the scavenger vs. pack animal thing it’s a fascinating read and explains a lot of behavioral loopholes that occur in pack theory. Dogs: A New Understanding of Canine Origin, Behavior, and Evolution
Book by Lorna Coppinger and Raymond Coppinger does a ridiculously thorough job of exploring it, but google is fine for the tldr folks.)
Michael M
August 23, 2019 at 6:45 pm
There are so many items being covered here and each worthy of its own discussion.
I’ll simply toss my peanuts into the gallery here –
Dogs are unique among domesticated animals because of the role they played early on with humans. They are not wolves nor should be treated as wolves. There is confusion with the use of the term scavenger and if we use the supposed working definition that was example in this writing, then humans too are scavengers. Don’t let the term’s connotation redirect attention away from the fact we are talking about healthy foods for dogs. Dogs are, unlike wolves, able to digest plant starches. This is a game changer meaning they can get not only caloric advantage with certain plant based food but also may be an alternative source (than prey) for various nutrients if not more.
Since dogs do not pack like wolves (and humans play a direct role in that subspecies life), domesticated dogs are fully dependent on humans for food intake. This may be part of the reason that when forced back into the wild, they consume all sorts of items and generate what may appear as scavengers. Dogs are not obligate carnivores like wolves because dogs can and do make use of other sources of food than animals. They remain in the realm of facultative carnivores. Dogs can live for long long periods of time without meat unlike a cat or wolf which are both obligate carnivores.
To add to all the confusion of terms and real world measures, dogs are the most diverse in the canine family and as a whole, one of the most diverse in the mammal family due to human intervention to an extent the animal ranges from a couple of lbs to over 200 lbs. This range of diversity brings all sorts of different physiological needs and abilities as related to environment and food source as well as ability to make use of food sources. Perhaps a great investigation into the practices of how dogs are bred would shed greater information on the universal food requirements verse real world differences among the varieties (breeds).
To the author and others who concern themselves with the welfare of dogs, this is a very very difficult area to make changes. Sometimes I* think it would be wiser to find legitimate altruistic vets and science folks to stand by a new “seal” that states the value and contents of the food being sold. In short if the dog food item has the seal, it validates that the food went through certain tests, the sources of the food has been verified and any other measure that would have REAL value as far as measure of food ‘goodness’ for our dogs. The idea is that people should be able to look for that seal on dog food and know it is a valid starting point to finding the right food for their dog. It takes out the variables portion that is often a negative.
Ron Pies
August 24, 2019 at 3:01 pm
Welcome to a federal government, run by the inmates of the prison. Every single agency is administered by industry people who are out to protect their industry, not the consumer. Check it out and see who is in charge of the FDA. Don’t expect a any changes until the administration changes, It isnt about Republicans or Democrats. Until this administration kidnapped government, all previous administrations pretty much put responsible qualified people in charge.
Gregg Ordes
September 4, 2019 at 10:39 pm
Back in 1988 I ran across info while researching nutrition for my dog. In California thier was an Attorney General that sued a large dog food company because they used dead, diseased and dilapidated horsemeat in their dog food with the results being healthy dogs dying from all sorts of ailments related to poor dietary intake. Heartbroken owners found that their dogs food was putrid and was awarded a phyrric victory and the company was forced to upgrade and allow inspection…..this book was written by that AG in the late 60s I believe but the companys name was withheld as an agreement of the settlement.
Ally
April 29, 2020 at 7:01 pm
Hi, so I don’t necessarily think there was any intentional negativity being thrown their way in this, but I do want to add in a little bit of information here regarding the article photo and the information about scavengers: vultures, who are pictured at the top, do not spread disease, they prevent it. They have really strong stomach acids (a turkey vulture’s is just slightly above a pH of 0), and they are essentially immune to a variety of different pathogenic bacteria that cause diseases like anthrax, botulism, rabies, cholera, etc.. Other scavengers, such as jackals, coyotes, raccoons, etc. are vulnerable to these pathogens and capable of infecting local populations, but a vulture’s stomach acid basically neutralizes the bacteria; therefore, they basically act as a “dead-end” for disease. As the only terrestial vertebrates in existence today that are obligate scavengers, they play a pretty important role in keeping the environment healthy and clean. They are also incredibly smart, playful, social, and curious birds, and they are considered among the most intelligent raptors, if not the most. Unfortunately, vultures are currently the most threatened group of birds in the world (16 of the 23 species are red-listed by the IUCN), and there’s a lot of misinformation about them that prevents people from understanding how essential they are to our ecosystem.
This comment is pretty random, and I apologize for that; I just felt like sharing some of this information in case there are any misunderstandings regarding vultures (and scavengers in general, but mainly vultures). I agree that something should be done about the pet food, especially since cats and dogs are vulnerable to the diseases found in carrion. I hope that changes will be made soon.