Who decides what ingredients are used in pet food? You aren’t going to like the answer.
One of you great pet owners sent me the question ‘who decided that peas, chickpeas, and lentils were good for dogs in pet food?’ Great question.
The answer: Industry.
The legal requirements of pet food is: no ingredient can be used in any pet food until the ingredient is defined by AAFCO (Association of American Feed Control Officials). The legally required process is:
- proposed ingredient is submitted to AAFCO Ingredient Definitions Committee typically through a trade association;
- proposed ingredient definition is discussed at an AAFCO meeting – sometimes multiple times at multiple meetings – attendees are welcome to comment pros or cons on the ingredient;
- after all discussion, ingredient definition is approved or denied;
- approved ingredient is added to the AAFCO Official Publication (book of regulations and definitions) most often as “tentative” (allowed to be used in pet food as tentative);
- at follow-up meetings ingredient definition will be approved as official.
Notice in the above, there is no legal requirement for scientific evidence to prove ingredient safety. In fact, often regulatory authorities simply ignore risk.
Example: In August of 2014 the feed ingredient “Zinc Hydroxychloride” was submitted to AAFCO for approval. The ingredient was approved even though 3 veterinarians spoke out against it (Dr. Jean Hofve, Dr. Cathy Alinovi, Dr. Oscar Chavez). Below is a screen shot copy of a segment of the minutes of this meeting approving this ingredient:
Three veterinarians expressed concern and FDA couldn’t respond to the effects of heat on the ingredient…but it still was approved as a feed ingredient. (On a side note, AAFCO has stopped including audience comment in their minutes of meetings. Unless you are at the meetings – which cost $550.00 each to attend – no one knows opposing discussion on any ingredient.)
Back to this pet owner’s question – ‘who decided that peas, chickpeas, and lentils were good for dogs in pet food?’ The answer for these ingredients is solely industry.
Years before the ingredient was legal to use in pet food – manufacturers used the ingredient without caution. In fact, the entire “Grain-Free” pet food segment was built on illegal use of the ingredients pea protein, pea fiber, and pea starch.
The legal definitions of pea fiber, pea protein, and pea flour were “Proposed in 2015” and “Adopted in 2016“. This means that legally – no pea fiber, pea protein or pea flour ingredient should have been used in ANY pet food until 2016. But that’s not what happened. Thanks to the WayBack Machine…
In 2008, Purina ProPlan used the ingredient “pea fiber” in a pet food, eight years before it was legal to use in pet food.
In 2013 – Merrick Pet Food announced in a press release their first Grain Free dog food that included the non-defined, illegal to use ingredient “pea protein“.
In 2012, Blue Buffalo marketed “Grain-Free” dog foods using the ingredients pea starch and pea fiber.
In 2013, Blue Buffalo Longevity Cat Food included the illegal ingredient “pea protein“.
In 2013, Orijen Adult Dog Food included the illegal ingredient “pea fiber“.
In 2013, Hill’s Science Diet offered a grain free pet food that included the illegal ingredient “pea protein concentrate“
In 2015, Nutro Natural Choice Dog Food included the illegal ingredient “pea protein“.
This is only a small example of the manufacturers that used these ingredients LONG before the ingredients were legal to use. In other words – ‘they’ (industry) did whatever they wanted to (and still do). No regulatory authority (FDA and/or each State’s Department of Agriculture) stopped pet food manufacturers from using illegal ingredients.
This issue could be regulated better if pet owners had public access to pet food ingredient definitions. If there was public access, any pet owner could look up all ingredients listed on a pet food label and report to authorities any illegal use. But…pet owners don’t have public access to pet food ingredient definitions. AAFCO owns them and charges $120 a year to read.
If you see any ingredient on your pet’s food label that you don’t recognize or want to know the definition of – contact your State Department of Agriculture representative and ask them to provide you with the legal definition. Click Here for a map of US pet food regulatory authorities – click on your state.
My thanks to this pet owner for a great question!
Wishing you and your pet(s) the best,
Susan Thixton
Pet Food Safety Advocate
Author Buyer Beware, Co-Author Dinner PAWsible
TruthaboutPetFood.com
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Charlene Schreiber
January 7, 2019 at 4:54 pm
I feed basically a home prepared raw diet to my dogs, but, need to use dry dog food on occasions. To keep the dogs GI systems accustomed to processed food, I feed the dry stuff a coupe times a week.
Every time I find a food I think is OK, just ok, I learn something disturbing about that food. I thought Orijin was the best I could do, but now have heard it is no longer made in Canada, no longer using top grade ingredients and was using pea fiber prior to the legalization date to do so!
What is a person to do!!??
guest
January 7, 2019 at 7:33 pm
This is the alternative I use when I cannot feed raw.
When you need to feed dry food, I buy the onlynaturalpet .com dehydrated raw or dehydrated wholesome homemade cooked stew and when traveling I bring this dry to the hotel, In the morning, mix with water and add a little salmon oil or codliver oil to make it more appetizing. If I don’t have oil, I get a little real butter at the hotel, and mix in a little real butter, or some breakfast eggs, sausage, bacon, from the hotel breakfast, and my dog loves it and no issues with digestion and firm poop.
Normally I feed real frozen ground raw, no hpp, no pressurization, no radiation, no pasteurization, with some frozen raw green beans or mixed veggies, a raw organic egg, and kelp tablets for iodine.
If I cannot get raw for some reason, then I buy the freshpet .com in the pet fridge at costco, target, some grocery stores and add an organic raw egg, sometimes I add additional frozen green beans or mixed veggies.
The dehydrated is dry so works great when you need to bring dry food with you.
Pet ~Owner~
January 9, 2019 at 5:15 am
Not a criticism at all, in fact kudos for your ultimate confidence! Wow, with “real frozen *ground* raw” (it sure better be human grade) and then handled quickly and carefully. The problem is cross contamination. Same for those eggs! Yes, I know, dogs can handle Salmonella (just not people). And I assume it’s ground for the purpose of bone meal inclusion.
Also (in reading up on supplementation) it seems like the commercial raw PFs aren’t as fully supplemented as they would have you believe, such as the current running discussion on “complete & balanced” would suggest. Am not sure of the value of green “beans” (except as a little filler). But Habib/Becker use a broccoli, red pepper in there ultimate raw food recipe. Your dog (it would seem) already has an iron stomach, and maybe from being on raw food, has kept his natural digestive process fortunately healthy. But for an average dog, I’d sure caution against butter (yikes, mine came across some inadvertently which sent him in with a pancreatitis attack, and yes he was fed a lot of raw food). But sausage & bacon (highly spiced, salted, artificially cured and very fatty). When using kelp as a source, then why not use one that qualifies as a full supplement (like “Pet Kelp”)?
Remember in the wild (healthy dogs, and then their lifespan wasn’t nearly as long as domesticated) were opportunistic scavengers. Thriving on “fresh” variety (not just red meat) but the fermented innards of the prey’s semi-digested choice of a “carbohydrate.” I’ve read that the dehydrated carbohydrate recipes (like THK) is convenient, apparently appealing, but still the dehydration process changes the basic cell structure of the ingredients. Can also be on the “starchy, sugary” side when favoring grain-free recipes. Prey animals may have feasted on some wild natural vegetation, but it was already partially digested (fermented). What’s important is getting the calcium/phosphorus ratio correct, as well as a adding good and proper source of oil.
Of course infrequent usage of what’s been described above can be a place in rotation. “Fresh Pet” looks appealing, is the essence of “convenient” but have heard that if it’s not maintained well in the refrigeration section (probably not by not being rotated correctly) it can pose problems. I would gage it offers the equivalent of a (cured meat type) like bologna does for humans ….meaning occasionally, but not as a continuous diet!
Katie Asling
January 8, 2019 at 4:26 pm
Use Susan’s list. For dry food when needed, I use Open Farm.
Mother of Dragons
January 7, 2019 at 5:21 pm
Is there a reason why peas and chickpeas were the subject of this particular inquiry? There are countless other ingredients that I’d be concerned with, peas and chickpeas aren’t among them.
Susan Thixton
January 7, 2019 at 6:04 pm
Those ingredients were important to this pet owner – and for the post it was the perfect example how law is ignored by pet food manufacturer.
Lori kelly
January 8, 2019 at 2:42 pm
They were probably brought up bc they have been implicated in a fda alert about a link between certain diets and Dilated cardiomyopathy.
Barb Kaye - AKC Breeder of Merit
January 8, 2019 at 3:16 pm
I was the ‘pet owner’ (I am actually an AKC purebred breeder) about legumes in our dog food (seems all brands have these legumes in their feed). I feed a pack of dogs and began notice things like, why are they scratching so much? why are they breaking out in chronic ear infections? why are they getting scaly dry skin? Plus as a breeder, I am concerned with fertility issues. It is well known that these kind of ingredients are fertility killers, that is, they are phyto -estrogens and screw around with sex hormones and lower sperm counts in our breeding males. So that’s why I asked. Based on my own scientific observation with my own pack. These weird combination of ingredients, do have an impact of the health of my collies.
Katie Asling
January 8, 2019 at 4:28 pm
I don’t believe they were ever incorporated for any other reason than to find a filler to replace ‘grain’. Same with potato.
Grateful
January 9, 2019 at 8:01 pm
Peas also raise the protein level, replacing quality meat protein.Horrible ingredient.
Pet ~Owner~
January 9, 2019 at 5:29 am
I am the original Pet Owner (now known as Pet ~Owner~ but no worries!! LOL!). It is so important when a breeder (especially of merit) who is tasked with bettering the breed, makes a contribution to this discussion. In some circles (unfortunately) they are so maligned, no doubt become reticent about even declaring themselves. However, your point about fertility and the impact of diet on bitches and sires, is so important. Few talk about the side effects of skin and ear problems, and many breeders have always preferred a (whole) protein rich diet, and have long since supplemented with (human grade) whole food varieties (such as freeze dried!)/. It’s why (back in the day) ProPlan (wet) has been so favored; but unfortunately now it is the sourcing of the protein which is so questionable. Meaning the more those companies and have been bought and sold only for profit considerations.
Thank you for your contribution!
Joan Sutton
January 7, 2019 at 5:58 pm
What is the best can dog food for a 13 year old Yorkie with a collapsed trachea. i had her on NRG from Alberta, CA The food seemed to give her inflammation
Susan Thixton
January 7, 2019 at 6:03 pm
That question is best for a holistic veterinarian to answer.
Janet B.
January 8, 2019 at 12:52 am
Susan, how is it that AAFCO gets to charge $550 to attend their meetings and $120 a year to read the pet food ingredients definitions?
This is crazy. Government meetings are usually open and certainly don’t charge an entry fee. I understand that AAFCO isn’t really a governmental agency but an organization made up primarily of industry people, which is also crazy.
Susan Thixton
January 8, 2019 at 10:10 am
That is a really good question. I don’t know how – they just do. Owning the definitions and regulations is a violation of Freedom of Information Act rights. But…as we know, in pet food many laws are violated/ignored.
Janet R.
January 11, 2019 at 11:51 am
There are a lot of ingredients that don’t have definitions in the AFFCO manual. But I’ve been told that there is a regulation that allows for those ingredients to be used in pet food if they are a commonly found ingredient. I would imagine that “peas” are pretty common. So they were never illegal, No?
Susan Thixton
January 11, 2019 at 11:53 am
No – not peas. It’s the ingredient they have made from peas – pea protein, pea starch, pea fiber – that until defined were illegal to use.
Pet ~Owner~
January 11, 2019 at 12:46 pm
Are you thinking of the “generally recognized as safe” ingredients or GRAS? Reference:
https://www.fda.gov/Food/IngredientsPackagingLabeling/GRAS/
Pet ~Owner~
January 11, 2019 at 12:51 pm
More specific, or as GRAS as it pertains to pet food … https://www.fda.gov/animalveterinary/products/animalfoodfeeds/petfood/default.htm