Pet Food Supply - Unfit for Human Consumption?

A recent article brings into question the source of products allowed in the production of commercial pet foods. The use of food products is governed by the provisions of the Federal Food, Drug, and Cosmetic Act (FFDCA), and the regulations issued under its authority. These regulations are published in the Code of Federal Regulations (CFR). The FFDCA defines food as "articles used for food or drink for man or other animals..." Therefore, any article that is intended to be used as an animal feed ingredient, to become part of an ingredient or feed, or added to an animal's drinking water is considered a "food" and thus, is subject to regulation. FDA's Center for Food Safety and Applied Nutrition (CFSAN) is responsible for the regulation of human food products. The Center for Veterinary Medicine (CVM) is responsible for the regulation of animal food (feed) products.

There are 3 questions addressed in the article posted on The truth about pet food.com:

#1: Do you believe pet food should abide by federal law?

It does. There are federal laws that govern the labeling of animal food, and states are involved in the process. For instance, FDA cooperates with the Association of American Feed Control Officials (AAFCO) and the States for the implementation of uniform policies for regulating the use of animal feed products. This includes the establishment of uniform feed ingredient definitions and proper labeling to assure the safe use of feeds. The ingredient definitions are important because animal feeds and feed ingredients must be correctly and truthfully labeled when they enter commerce. Although FDA has the responsibility for regulating the use of animal feed products, the ultimate responsibility for the production of safe and effective animal feed products lies with the manufacturers and distributors of the products.
The Food Safety Modernization Act (FSMA), the most sweeping reform of our food safety laws in more than 70 years, was signed into law by President Obama on January 4, 2011. FSMA aims to ensure the U.S. food supply is safe by shifting the focus from responding to contamination of the food supply to preventing it. The law applies to human food as well as to food for animals, including pets. 

chickens
 

#2: Is material from diseased animals or animals which have died otherwise than by slaughter fit for my pet’s consumption?

It doesn't sound like that would be ideal, until you get into the details of how this material is processed. For many years end products from rendering have been used to feed animals. The rendering industry utilizes packinghouse offal, meat processing waste, restaurant waste and animal tissues from other sources including animals that have died "otherwise than by slaughter".

There are two types of processes in use by the rendering industry to prepare this material. They are dry rendering, used by the largest portion of the industry, and wet rendering. Both rendering processes were designed to ensure that the resultant animal feed ingredients pose no threat of disease transmission to animals which are fed the material or to the health of humans consuming their edible products (meat, milk, and eggs). Prior to the appearance of BSE (bovine spongiform encephalopathy or 'mad cow' disease), CVM had no evidence of human or animal disease associated with the feeding of properly rendered and handled animal feed ingredients despite the use of tissues from diseased animals or animals that have died otherwise than by slaughter. In addition, the Center for Veterinary Medicine does not believe that Congress intended the Act to preclude application of different standards to human and animal foods under Section 402. Although this information was initially published in 1998, it is considered current as of 3/2/2015
Other things to consider include the phrase 'unfit for human consumption'. This statement could mean a number of things.  Cattle inspected and not passed for human consumption means cattle that did not pass antemortem inspection by the appropriate regulatory authority. This term includes non-ambulatory disabled cattle. Non-ambulatory disabled cattle are cattle that cannot rise from a recumbent position or that cannot walk, including, but not limited to, those with broken appendages, severed tendons or ligaments, nerve paralysis, fractured vertebral column, or metabolic conditions. It could also mean animals that have lesions or other physical finding that fail them in antemortem inspections. It dose not mean that every animal that is found unfit for human consumption becomes a supply for animal consumption. 

Further, when evaluating whether a rejected human food or a by-product with a food safety concern is suitable for use as animal food, federal guidance at a minimum recommend management to consider:
(1) whether any human food safety concern is an animal food safety concern;
(2) the type of animal food the food will be used for, or the animal species to which it will be fed;
(3) the level of the food safety concern, considering the animal species to which it will be fed; and
(4) FDA's guidance on the diversion of contaminated or adulterated food for use as animal food. The management should use this and any other relevant information to make a determination whether the food is safe to use as an animal food prior to marketing or distributing the food for use as animal food. http://bit.ly/2vqHI1b 

Under the FSMA rule, animal food processors are required to identify potential hazards in their operations and implement preventive controls. For example, processing plants would need to identify and establish cooking temperatures that would reduce or eliminate the risk of bacterial or fungal contamination of feed. Importers of pet or livestock feeds or feed ingredients would be held responsible for identifying foreign manufacturer quality control processes and verifying that these processes meet U.S. standards, creating a level playing field between imported and domestic food. While the FSMA covers both human and animal food, there are different sets of proposed rules governing animal and human food production. Under the new law, food-safety rules can’t be “wildly different between human and animal feeds.” The two sets of rules are “very similar with some exceptions.”

sheep

#3: Is rendered pet food ingredients sourced from animals which have died otherwise than by slaughter a safe, quality ingredient?

As stated above, prior to the appearance of BSE, CVM had no evidence of human or animal disease associated with the feeding of properly rendered and handled animal feed ingredients despite the use of tissues from diseased animals or animals that have died otherwise than by slaughter.

 

 

Unfortunately, there will always be unscrupulous individuals attempting to divert inappropriate sources into food supplies in an effort to control manufacturing costs. The current FDA regulations are fairly robust in attempting to prevent products from entering pet food sources that may be dangerous to an animal's health. Possibly, some of the wording in the regulations could be improved, as it seems the phrases 'unfit for human consumption and 'other than by slaughter' could have a wide range of definitions for the lay person unfamiliar with the protocols in place. A host of incorrect assumptions could lead to increasing public misconceptions. Articles such as the one referenced give great current insight to public perception of the origins of the manufacture of pet foods, and challenge veterinarians to become educated in an effort to exact change when necessary. Consumers also have a role, as the economic battle for the consumer dollar is heard by the pet food manufacturers. The bottom line is that higher quality products and increasing regulations will cost more, as those higher manufacturing costs are passed on to the consumer. If the upside is healthier pets, then we as consumers can determine if the cost is valid and acceptable.  Education and correction of misinformation will affect changes in federal regulations and implementation of new manufacturing processes, all for the benefit of our patients.  

supply chain