COMMERCIAL DOG FOOD FACTS AND LABELING PRACTICES
Are you as confused by dog food labels as we are? When it comes to dog food, labeling is one of the most perplexing and potentially misleading elements of the business. If a manufacture can list “chicken meal”, “beef meal”, “lamb meal”, etc as an ingredient and not also inform the consumer that this description can include indigestible by-products such as bone, hoof, hide, hair, blood then the labeling system is broken. It becomes very difficult for a pet parent to know what their dog is really eating when the accepted descriptions for pet food ingredients are so convoluted. Here are some interesting dog food industry facts as well as answers to some frequently asked questions about the dog food business.
What is the AAFCO? (Association of American Feed Control Officials).
AAFCO is not a government agency and includes the involvement of people related to the pet food manufacturing industry. The AAFCO and its involvement in the pet food industry may be one of the best examples of “self regulation” in the entire country. There is literally no entity charged with policing the production of pet food in the United States. The AAFCO is an organization more or less governed by the large, commercial animal and pet food manufacturers, and their appointees. When non-government organizations such as this are allowed to preside over themselves the focus is generally related to profits rather than quality.
Is it true that pet food labels can use descriptions of ingredients that could mislead or confuse the public?
We believe so but you can decide for yourself. Here are just two examples of labeling guidelines from the Association of American Feed Control Officials (AAFCO).
a) According to AAFCO labeling guidelines, if the name of the food includes the phrase “with (ingredient)”, eg (“with beef”), the named ingredient must not be less than 3% of the total weight. So in other words, a dog food manufacturer could have a label that says “Aunt Susie’s Wholesome Stew with Lamb” and as long as (by weight) the lamb is 3% of the ingredients they are following the rules! Really? 3%?
b) If the name includes the word “flavor” or “flavored”, no specific percentage is required at all, but a product must contain “an amount sufficient to be able to be detected”. This guideline leaves the door wide open. After all, what is the definition of “detected”. It seems pretty clear that a dog food manufacture could market a product called “Aunt Susie’s Wholesome Stew with Lamb Flavor” and put just 1% lamb flavor in the meal. To make things worse, there is no rule that says the lamb flavoring can’t be artificial!
What is “Guaranteed Analysis”?
This is the most basic, rudimentary breakdown of the contents of a pet food, listed on the package. It lists items such as “crude protein”, “crude moisture”, “crude fat” and “ash”. For all practical purposes this “analysis” is meaningless because under AAFCO guidelines the crude protein could be anything from chicken feathers to meat from a diseased animal (both are acceptable under AAFCO guidelines and both are allowed in the production of dog food). There is no “law” or “rule” requiring a manufacture to put the “Guaranteed Analysis” breakdown on the package but it is a recommendation of the AAFCO and since most consumers assume that AAFCO has their dogs best health in mind, most manufacturers include the standard AAFCO statement on their packaging.
This excerpt from Dr. Pitcairn DVM, PHD, in his book Natural Health for Dogs & Cats makes an excellent point - “...meat and bone meal is generally comprised of ground bone, gristle, and tendons, and is the cheapest and least nutritious of the by-product meals. The same is true of lamb meal, poultry or chicken meal, or fish meal”.
In the absence of a more detailed analysis a pet parent will have no idea what they are feeding their dog. For a dog food manufacturer, adhering to the guidelines of AAFCO is easy, but frankly, meaningless. You could put almost anything in dog food and meet these very loose requirements. The question is not whether a dog food meets the crude requirements of the AAFCO guidelines, the question is, how far beyond those guidelines does the manufacture go to ensure quality.
Below are some ingredient regulations from the Association of American Feed Control Officials. This information has been taken directly from the 2010 Official Publication Association of American Feed Control Officials Incorporated as well as the AAFCO Pet Food and Specialty Pet Food Labeling Guide. Where indicated by quotation marks the text has been copied from the literature verbatim. Just to be clear, these are ingredients that are allowed to be put into dog food.
“Chapter Six Feed Terms and Ingredient Definitions”. Page 387 “74.1 Dried Poultry Waste-- (DPW) means a processed animal waste product composed primarily of feces from commercial poultry, which has been thermally dehydrated to a moister content not in excess of 15%.”.
Page 387 “74.3 Dried Poultry Litter-- (DPL) means a processed animal waste product composed of a processed combination of feces from commercial poultry together with the litter that was present in the floor production of poultry, which has been artificially dehydrated to a moisture content not in excess of 15%. It shall contain not less than 18.0% crude protein, and not more than 25.0% crude fiber, 20.0% ash, and 4% feathers.”
Page 375 “60.72 Almond Hulls with Almond Shells-- Almond hulls with almond shells must not contain more than 29 percent crude fiber, 9 percent ash and 13 percent moisture. They shall be processed in accordance with good manufacturing practices and be reasonably free of foreign material.”
Page 380 “63.5 Hemicellulose Extract is a by-product of the manufacture of pressed wood. It is the concentrated soluble material obtained from the treatment of wood at elevated temperature and pressure without use of acids, alkalis, or salts”.
Acceptable ingredients under AAFCO guidelines describing “meat meal” include “hair, hide, blood, manure, stomach & contents therein...”, provided these items are not “added” items. The problem is, when a cow, pig or other animal is slaughtered, all of the parts fit for human consumption are removed and sold through the human food chain so there is little left except hide, tendons, hair, etc. So these items don’t have to be “added”, after all, they would make up the majority of the parts left behind.
Why are so many of the multi national human food companies also the major providers of pet food?
Simple, in many cases these large corporations produce pet food from the ingredients they would otherwise throw away in the production of food fit for human consumption. Think about it this way, when a cow is butchered, every possible portion that can be used for human consumption is in fact, sold for human consumption. However, there are still things like bone, blood, hair, hide, etc and these are the parts that become pet food, typically through a process called rendering. The same is true of harvesting corn, wheat, peanuts, etc. Corn has husks, peanuts have shells, etc. If you are in the candy business and find yourself throwing away tons of almond shells every year wouldn’t it be great to sell them in the form of dog food instead of hauling them away? Pet food becomes very profitable if it can be made from the items you would otherwise being throwing away. And you might be surprised at some of the “top tier” pet food brands that use these methods and ingredients. Needless to say, making decisions about what goes into dog food based on what you have left over from another use is not exactly putting the health and wellbeing of the dog first.
Some of the multi national corporations that are invested in the dog food business are:
Proctor & Gamble owns: Iams, eukanuba, Evo, Innova, others.
Nestle owns: Purina, Alpo, others.
M&M Mars owns: Pedigree, Royal Canin, others.
Colgate-Palmolive owns: Hills Science Diet, others.
Del Monte owns: Kibbles N Bits, Pup-peroni, others.
What is “rendering?
Modern slaughterhouses create a massive volume of inedible, unwanted waste that is unfit for human consumption such as hair, hoof, beak, neck, bone, blood, eyeballs, entire carcasses from diseased and disabled animals, etc. Rendering is the process of boiling these ingredients, as well as restaurant and grocery store waste and even road kill into a mixture that is then sold to manufacturers for final use in, among other things, animal feed including pet food. It should also be noted that many reliable sources believe that euthanized pet dogs and cats are also used in the production of commercial dog and cat food.
There are horrific stories about what goes into dog food, are they true? In a word, yes. Some are well documented facts. Here is just one example, taken from Dr. Martin Goldstein’s book, The Nature of Animal Healing - where he quotes excerpts from the book Food Pets Die For - introduced by Dr. Michael Fox and authored by Ann N. Martin:
“In her native Ontario, Martin discovered that rendering - at its best, the boiling of any animal substances discarded by slaughterhouses as unfit for human consumption - is an established, if little publicized industry, and that “rendered” animal substances go directly into livestock and feed. These substances may include “4 D” meat: meat from dead animals, dying animals, and diseased and disabled animals. (To that I add a fifth D for “drugged.”) These 4D carcasses may have cancerous tumors, worm infested organs, and the like - basically anything and everything goes into the pot. Worse, Martin found, rendering plants happily accept roadkill, dead zoo animals, and, most appallingly, euthanized pets from animal shelters and veterinarian clinics.
Shocked by the standards she found in Canada, Martin sent a questionnaire to the state governments of all fifty of the United States, asking, among other things, if state law allow euthanized pets to be rendered, and if rendered material is freely used for livestock and pet feed. Twenty states replied blithely that no law forbid the rendering of euthanized pets or their use in pet food. The remaining thirty states did not reply, suggesting their standards are just as lax. “Finding companion pets eating dead cats and dogs objectionable is more than just aesthetics” Martin writes. “Safety is at stake”.
I have seen the term “human grade” used by some dog food producers, what does it really mean? The best answer to this is covered by Sabine Contreras of thedogfoodproject.com.
She states:
“Frankly, there is no legal definition whatsoever for the term “human grade” when it comes to pet food, and holds no weight. If you don’t believe me, contact the FDA and the AAFCO and ask. I know it has become a major buzz word since the pet food recall disaster of 2007, and it’s widely abused to mislead consumers.”
“On the other hand, the designations “from USDA inspected facilities” and “passed USDA inspection for human consumption” do have merit. If a pet food manufacturer makes claims in regards to human grade ingredients, ask for proof that they meet these criteria before taking their word that it’s “human grade”.
