Feed Food Brochure - Truth About Pet Food

PET FEEDThis document is provided to pet food consumers as a resource to better understand pet food regulations,and the lack of enforcement of those regulations. Provided by Susan Thixton, pet food consumer advocate;TruthaboutPetFood.com and AssociationforTruthinPetFood.com.

All pet foods and treats fall into two different classifications:Feed Grade Pet FoodsHuman Grade Pet Foods Feed grade pet foods are not required to abideby U.S. Federal food safety laws. In fact, theFDA allows feed grade pet foods to violate U.S.Federal law. Human grade pet foods are “food” - required toabide by all U.S. Federal food safety laws.In April of 2019, the FDA stated:“We do not believe that the use of diseasedanimals or animals that died otherwise thanby slaughter to make animal food poses asafety concern and we intend to continue toexercise enforcement discretion.” Manufactured by the same safety standards ashuman food. Ingredients and supplements are NOT requiredto be human edible. Labeled with the term “Human Grade” alertingpet owners all food safety requirements havebeen met. NOT required to be manufactured by foodsafety standards. Formulated for pet consumption only, not heldto U.S. food safety law. NOT labeled with any term or disclosure toalert pet owners to feed grade quality and/orpotential use of illegal inferior ingredients orinferior manufacturing conditions. All ingredients and supplements are humanedible. Formulated for pet consumption, but are heldto the exact same food safety laws as humanfood. Raw pet foods are not allowed to be labeled asHuman Grade. Raw pet foods meet the legalrequirements of the claim IF they aremanufactured under USDA inspection (emailthe manufacturer for verification). All styles of pet food can be feed grade; dry,can, raw, dehydrated, etc.Provided by Susan Thixton, pet food consumer advocate; TruthaboutPetFood.com and AssociationforTruthinPetFood.com.

All pet foods and treats fall into two different classifications:The legal definitions (fromAssociation of American Feed ControlOfficials - AAFCO) of theseclassifications are:“Feed Grade: Material that hasbeen determined to be safe,functional and suitable for itsintended use in animal food, ishandled and labeled appropriately,and conforms to the Federal Food,Drug and Cosmetic Act unlessotherwise expressly permitted by the1appropriate state or federal agency(Suitable for use in animal feed).”“Human Grade: Every ingredientand the resulting product are stored,handled, processed, and transportedin a manner that is consistent andcompliant with regulations forcurrent good manufacturing practices(cGMPs) for human edible foods asspecified in 21 CFR (Code of FederalRegulations) Part 117.” 1means that all ingredients andsupplements are required to be thesame quality you’d purchase in agrocery for your human family, theyare human edible quality. Humangrade pet foods are alsorequired to bemanufactured by thesame food safetystandards that humanfood is manufactured by.The diets are formulatedfor cats and dogs, buteach ingredient qualityand manufacturingstandards are the exactsame as for human food.Feed grade pet foodsdiffer from human gradepet foods in that theycould be manufactured with humanedible quality ingredients and perhuman food safety standards, but theFDA does not require them to be.When you read the definition of feedgrade carefully, it states that feedOn the surface these twoclassifications of pet food orgrade pet foods or ingredients abideingredients don’t seem that different. by law – unless they don’t; “conformsBut with further information, you’ll to the Federal Food, Drug andCosmetic Act unless otherwisesee they can be as different asdaylight and dark.expressly permitted by theappropriate state or federal agency.”Human grade pet foods are simple to In other words, feed grade petfoods/ingredients abide by federalexplain, they are food. When a petfood label includes the wordslaw, UNLESS they are permitted to“Human Grade” (ignore websiteviolate law by state or federal petfood authorities. What is “expresslyclaims, more on this to follow), thispermitted” by state and federal petfood authorities in feed grade petfoods/ingredients is shocking.In April 2019 the FDA stated:2In October 2016, the pet foodconsumer group Association for Truthin Pet Food filed a formal requestwith FDA asking the Agency toprohibit their allowed use of diseasedanimals and non-slaughtered animalsinto pet food. The FDA responded2 ½ years later with the abovestatement, refusing to prohibit thesedangerous and illegal ingredients intopet food. FDA continues to “exerciseenforcement discretion”, allowing petfoods to include illegal ingredients.Provided by Susan Thixton, pet food consumer advocate; TruthaboutPetFood.com and AssociationforTruthinPetFood.com.

U.S. federal law has no definition offeed grade (the only definition is theAAFCO definition). In fact, federallaw clearly defines pet food as“food”.The Federal Food Drug and CosmeticAct (Title 21, Chapter 9, SubchapterII, Section 321 Definitions; generally)defines a food as:“(f) The term "food" means (1)articles used for food or drink forman or other animals, (2) chewinggum, and (3) articles used forcomponents of any such article.” 3U.S. federal law also clearly definesan adulterated or illegal food, whichhappens to be word for wordopposite of what FDA allows intofeed grade pet foods.The Federal Food Drug and CosmeticAct (Title 21, Chapter 9, SubchapterIV, Section 342 Adulterated food)defines an adulterated or illegal foodas:“A food shall be deemed to beadulterated” (in part) “(5) if it is, inwhole or in part, the product of adiseased animal or of an animalwhich has died otherwise than byslaughter;” 4Per the Federal Food Drug andCosmetic Act, diseased animals andanimals that have died otherwisethan by slaughter are adulterated,illegal in ANY food. But, per theFDA’s own words and AAFCO’sdefinition of feed grade, feed gradepet foods are allowed to containillegal ingredients.report later revealed the cause of herdeath. A drug called pentobarbital, aeuthanasia agent, was found in bothAnd the worst part of this - no petthe dog’s stomach and the Evanger’sowner is warned or alerted. Pet food dog food. ‘If this sample camelabels are not required to disclose ifdirectly from a can,’ the toxicologisttheir products contain illegalwrote, ‘this is an urgent matter.’ “ 6ingredients, no pet foodmanufacturer is required to disclose The lab results were provided to FDAtheir use of illegal ingredients.and a recall of the pet food occurreda month later on February 3, 2017.From February 3, 2017 through May31, 2019 - more than 91 millionTelevision station WJLA journalistpounds of pet foods were recalledLisa Fletcher interviewed the Seattlebecause they containedpet owner and multiple consumerpentobarbital,5 a drug used toadvocates regarding the euthanasiaeuthanize animals. The fact that this drug discovered in pet food. Themuch pet food was recalled because television station tested 62 cans ofit contained ‘an animal that diedpet food across 24 brands. Theirotherwise than by slaughter’results found pentobarbital in 15(euthanized animal) should not givecans of dog food. The televisionconsumers comfort. All 91 plusstation provided their results to FDAmillion pounds of pet foods wereand a recall of multiple varieties ofrecalled because of the actions of acanned Gravy Train, Kibbles n’ Bits,pet owner and a TV station journalist Ol’ Roy and Skippy dog foods was- NOT from regulatory surveillanceissued shortly after. 7, 8of the pet food industry for illegalingredients.On New Years Eve 2016 a pet ownerin Seattle, WA fed her five dogs a canof Evanger’s Hunk of Beef dog food.Within minutes of consuming the petfood, the dogs began staggering andfalling down. The dogs were rushedto an Emergency Clinic, but one dog Talula - had eaten more of the foodthan the others. Talula died.This pet owner had a necropsyperformed on Talula. “A toxicologyProvided by Susan Thixton, pet food consumer advocate; TruthaboutPetFood.com and AssociationforTruthinPetFood.com.

and wholesale locations the recalledpet food was shipped to; efforts toassure that all recalled pet foods areremoved from store shelves. Thetrace backwards investigation is todetermine the source of theproblem. As example, in the traceIn October 2018, Dr. Stevenbackwards investigation of the GravySolomon, Director FDA Center forTrain, Kibbles ‘n Bits, Ol’ Roy andVeterinary Medicine stated in aSkippy recall, the FDA andspeech to industry (obtained through manufacturer Smuckers determinedFreedom of Information Act request) the source of the pentobarbital was a“Most of us probably think thatfat ingredient purchased from apentobarbital comes from a couple of supplier in Pennsylvania (JBS/MOPACbad actors that use a euthanizedin Souderton, PA).animal when they know they aren’treally supposed to. New evidence isWhen the source of the pet foodshowing that it may be a much more problem is determined through tracepervasive problem throughout thebackwards, a similar trace forwardanimal food supply than originallyand trace backwards investigation isthought, and we have reason totypically performed at the ingredientbelieve rendered products can be asupplier. In the case of the Gravysource for pentobarbital, if notTrain, Kibbles ‘n Bits, Ol’ Roy andcontrolled.” 9Skippy recall investigation at supplierJBS/MOPAC, authorities learned thatJBS/MOPAC also shippedpentobarbital contaminated fats toKentucky pet food manufacturerChampion Pet Foods.10that have died other than byslaughter have been documented inboth kibble and canned pet foods,and from low price ranged grocerystore type pet foods to high priceranged pet store type pet foods.Based on historical evidence andFDA’s open permission for any feedgrade pet food to utilize ingredientssourced from diseased animals oranimals that have died other than byslaughter, the answer to the question‘what type of pet foods use theseillegal ingredients’ is:Any feed grade pet food couldcontain ingredients sourced fromdiseased animals or animals thathave died other than by slaughter.Pet owners have no guarantee of thequality of ingredients with feed gradepet foods.Information provided in a 2017 FOIAUnlike previous pet food brands that requested document - the FDAinspection report of a Mars Petcarerecalled pet foods due toThere is no certain answer to thisplant in Columbus, Ohio stated:pentobarbital contaminationquestion. The only thing we have to(Evangers, Gravy Train, Kibbles ‘nbase a response on is information“Inspectional ObservationsBits, Ol’ Roy and Skippy), Championthat has come to light thus far.1. Failure to inspect, segregate,Pet Food did not recall it’s productsorotherwise handle raweven though the pentobarbitalThe typical procedure FDA followsmaterials and ingredients used incontaminated pet foods “was furtherafter a recall is to perform a tracemanufacturing under conditionsdistributed to the store/consumer11forward and trace backwardsthat will protect the animal foodlevel.”investigation with the pet foodagainst contamination andmanufacturer. Trace forwardminimize deterioration.”What we have evidence of,investigation is to document all retail ingredients sourced from animalsProvided by Susan Thixton, pet food consumer advocate; TruthaboutPetFood.com and AssociationforTruthinPetFood.com.