Meet Jean Hofve, DVM
Dr. Jean Hofve is the former Editor-in-Chief of the Journal of the
American Holistic Veterinary Medical Association, former Companion Animal
Program Coordinator for the Animal Protection Institute and author of its most
recent Pet Food Report, and a ceaseless investigator and writer on the pet food
industry. Her wonderful articles previously appeared at the website,
However, the site appears to be down so I reproduced the articles below:
Pet Food Regulation
WHO'S IN CHARGE?
By Jean Hofve, DVM
While most pet owners are certain that "someone" is in charge of regulating
the manufacture of commercial dog food in this country, very few people know who
that mysterious official or agency might be. But somebody's gotta be making sure
that pet food doesn't contain any harmful ingredients and does contain what
animals need to survive, right? The FDA? USDA? Someone?
Unfortunately, the answer isn't as clear-cut as, "Yes, it's all taken care of."
There are numerous government and industry agencies that oversee various aspects
of pet food production, but there really is no single office that provides
seamless overall supervision of the industry. So is there anyone making sure
that a "duck and potato" food really contains ducks and potatoes? Or testing the
food to see whether it really contains a minimum of the 20 percent protein it
claims in its "Guaranteed Analysis"? Maybe, depending on where you live. There
are many opportunities for pet foods to fall between the cracks of testing and
enforcement. A walk through the many halls of pet food regulation reveals why a
reliance on some branch of the government to ensure a food is "nutritionally
complete and balanced" is pure folly.
FEDERAL AND STATE REGULATIONS
You might rightly assume that the Federal government has some sort of
control over the production of food, even pet food. The Food and Drug
Administration is charged with the enforcement of the Federal Food, Drug, and
Cosmetic Act. A division of the FDA called the Center for Veterinary Medicine (CVM)
is responsible for regulating animal drugs, medicated feeds, food additives and
ingredients, and pet food, making sure that they conform with the Food, Drug,
and Cosmetic Act. This Act requires that pet foods contain no harmful
substances, and be truthfully labeled. However, only in extreme cases does the
FDA or the CVM get involved in an investigation of a food maker, and generally,
only as a last line of enforcement. The most meaningful regulation of pet foods
occurs at the State level.
Each individual state has its own regulations and its own Department of
Agriculture (or similar department, in a few states), which oversees the sale of
pet food within its borders. Before a new brand or a new type of dog food can be
sold in a given state, the maker is required by law to register the new food in
each state in which it will be sold. The state's feed control officials are
responsible for examining the food's label claims and the food itself. Some
states have very proactive feed control officials, who aggressively examine and
test new foods being sold or made within their states' borders. Kentucky, Texas,
and Minnesota, for instance, have a reputation for thoroughness when it comes to
testing pet foods. California, in contrast, does nothing because the legislature
budgets no money for enforcment.
Most states at least have a program to look at pet food labels. Yes, the size,
shape, and color of the fonts and panels, as well as what they say, are
regulated. Pet food companies can't make unsubstantiated claims, nor can they
make health or treatment claims without going through several hoops, including
What do the states test for? The main area of focus is the Guaranteed Analysis
(GA), which the FDA requires to be printed on every container of pet food. The
states can (and most do) test for everything that is included in the GA. The
only things that are required to be in the GA include the minimum percentages of
crude protein and crude fat, the maximum percentage of crude fiber, and the
total percentage of moisture in the food; that's all. Some companies include
more information in their GA, adding minimum levels of certain vitamins, fatty
acids, or other nutrients they believe the consumer will appreciate. This is
going out on a limb for the maker, because it just about guarantees that at
least some states will test for these items as well. Pet food companies that
ship nationwide tend to stay within these guidelines.
Before we discuss other tests or standards a pet food might be held to, we have
to introduce another organization, one that influences the states' policies on
Many people have heard of the Association of American Feed Control Officials
(AAFCO), and assume that this is the agency that polices the pet food industry.
However, AAFCO has no regulatory power whatsoever; it can neither approve nor
ban foods. Rather, AAFCO is a non-governmental, non-regulatory, voluntary
organization of feed control officials (FCOs) from each state (as well as
several other countries). Its role is advisory. AAFCO exists to provide a forum
for discussion by all interested parties, address issues of quality and
standardization for animal feed and pet food, provide nutritional standards for
pet foods and guidelines for feed and pet food manufacturing and labeling, and
outline enforcement actions for regulators.
AAFCO influences the production of pet foods only as far as states (25) that
have adopted its "model" regulations in whole or in part. (Some states have
adopted their own standards, which may or may not be similar to AAFCOs, and some
states have no regulations at all.) AAFCO is the place where the state feed
control officials can go to discuss issues of feed safety, animal health, and
inter-state commerce with the all the other people who know the most about these
issues. Then they go home and set policy for their states.
In order to obtain the best information about every imaginable aspect of pet
food, AAFCO invites certain experts from many different fields to join the
conversation, as it were, to educate the Association in the finer details of
associated specialties. Formerly called "liaisons," these advisors do come from
the pet food industry, as well as the grain and feed industries, the rendering
industry, laboratories, farm co-ops, and other groups with an interest in
AAFCO's decisions. The Animal Protection Institute, for instance, had an
advisory position on the Pet Food Committee and Ingredients Definitions
Committee for several years. Many of these invited experts participate in AAFCO
subcommittees as members and liaisons; there are committees on botanicals and
herbs, environmental issues, feed safety, ingredient definitions, state/industry
regulations, and many more.
The presence of so many vested experts, all of whom would like to influence the
feed control officials to benefit their own aspect of the industry, worries many
animal welfare activists, and some even regard AAFCO as a sort of pawn of
industry that does not have our animals' health at heart. However, only the
state feed control officials and the FDA and USDA representatives,are voting
members of AAFCO.. At AAFCO meetings, which are held twice a year, advisors
often speak on issues where they have an interest or stake in the outcome.
Advisors' comments are taken under advisement by the FCOs and then the issue is
voted on by the FCOs. In my experience, the FCOs, as a group, are definitely not
pro-industry; they take their role as watchdog very seriously, and it is not a
case of "the fox guarding the henhouse" as some have claimed.
For example, a few years ago the rendering industry pushed to have the official
feed term "by-products" re-named "animal proteins." This was debated in the
Ingredient Definitions Committee (IDC). The proposal was turned down because the
IDC felt it was anti-consumer, and they felt that the new term was being
requested not because of a change in the ingredient itself, but merely to
obscure and confuse the issue for consumers.
In spite of that defeat, the renderers approached the IDC not long afterward
with another request, this time to change the name "poultry by-products" to
"poultry and bone meal." As an advisor to the IDC from the Animal Protection
Institute, I argued strongly against this change, as did representatives from
two major pet food companies and others. (FYI, they were Nutro and Purina, in
case you want to give them credit.) The IDC voted unanimously against the
PET FOOD STANDARDS
Perhaps AAFCO's biggest legacy to the state feed control officers has been
the development of two tools for the standardization of pet food formulation.
Most, but not all, states have adopted these development tools, and require
foods sold in those states to adhere to one of the two AAFCO standards. But,
remember, it is the state feed control officials who check to see whether the
food makers are compliant with the standards.
1. Nutrient Profiles. The first standard is the AAFCO Nutrient Profiles, an
effort to identify the minimum (and a few maximum) levels of "macronutrients"
(protein, fat, and fiber) and the "micronutrients" (vitamins, minerals,
essential amino acids) that research has shown to be necessary for dogs and
cats. Years ago, pet food makers manufactured foods to the nutritional standards
set by the National Research Council, there were numerous faults with those
standards. AAFCO convened panels of experts in canine and feline nutrition to
develop new, better standards. These were adopted by AAFCO around 1990 (a little
earlier for dogs, a little later for cats).
Although the Nutrient Profile system has done a lot to standardize the business
of pet food production, it's not without its critics. There are studies that
suggest some nutrient levels may be too high, and others too low. The Nutrient
Profile system of formulation does not address the issue of ingredient quality
whatsoever. One critic of this method of feed formulation designed a "food" that
met all the AAFCO nutrient profile requirements – even though the food was
primarily formulated from old shoe leather, sawdust and motor oil with a
multi-vitamin-mineral supplement. Obviously, there would be no guarantee that
any animal would eat such a food, or could digest it, even though it contained
all the vitamins, minerals, protein, fat, etc. that the nutrient profiles
2. Feeding Tests. The second method for pet food formulation addresses those
concerns – but contains some loopholes, as well. AAFCO developed a protocol for
a six-month feeding trial that can be used as a tool to determine whether a food
can sustain life in a target test population (dogs or cats in all life stages,
or specific stages of growth of maintenance). (The growth/lactation protocol is
only 10 weeks, but they have to run more extensive blood tests to analyze it.)
The test population is fed nothing but the food in question for six months, and
if the subjects test normal (on weight and a few blood tests), the food passes.
This method at least would help a maker demonstrate that the food is palatable
and digestible enough to maintain life in the test population – something the
nutrient profile system doesn't do. And this method is good if a feed maker has
some brilliant research that indicates the levels of certain nutrients in the
AAFCO nutrient profiles are inadequate for promoting maximum health, and they
can formulate a food that they think is better; and they can conduct feeding
trials to prove their food works. At present, some large breed puppy foods are
being feed tested because the companies believe that the Nutrient Profiles don't
address their special requirements.
However, the feeding test requires only eight test subjects, and require that
only six finish the trial. Many nutritional deficiencies or overdoses would not
appear in this short period; the feed's fitness for maintaining longevity,
reproductive, or multi-generational health would not be demonstrated. (In
reality, most pet food companies using feeding tests use many more animals than
the 8 required.)
These two systems necessarily miss a lot of potential problems. A food meeting
the Nutrient Profile may or may not pass a feeding trial; not all foods that
have passed a feeding trial meet all specifications of the Nutrient Profiles.
Clearly, it would be possible for a marginal food to pass these tests, yet fail
to provide adequate nutrition in the long run, and in fact such problems are
well documented. In generational studies, where animals were kept on the same
food for three to five generations, researchers at the University of California
at Davis found that some foods that pass feeding trials still won't support
animals over the long term. They estimated that, of 100 foods that pass AAFCO
analysis criteria, 10 to 20 would not pass the feeding trials, and of those, 10
percent would not be adequate for long-term feeding. A former FDA nutritionist
emphasizes, "The formulation method does not account for palatability or
availability of nutrients. Yet a feeding trial can miss some chronic
deficiencies or excesses."
In the case of minimum requirements without a corresponding maximum, some foods
contain significant nutrient excesses that may actually be dangerous in the long
run. The Kentucky feed control officials analyzed test data from all pet foods
tested during 1994 and 1995, and found that certain nutrients, such as
magnesium, iron, and manganese, were present in most dry dog and puppy foods at
200-400 percent or more of their AAFCO Nutrient Profile values. Their
conclusion: the AAFCO profile for certain nutrients is not a reasonable
indicator of the actual level present in many products. An excess of many
minerals, including copper, magnesium, iodine, and iron, may produce signs of
toxicity over time. Excess iodine, for instance, is thought to be one factor
contributing to the explosion of hyperthyroidism among older cats.
And there is still one big wrench in the works: manufacturers are allowed to
test one food of a similar "family" of foods, and apply that certification to
all foods in that family. There is no way for the consumer to know which foods
were actually tested by feeding trials certification.
If a food has met either AAFCO requirement, it may state on the label that the
food is "complete and balanced." These label statements are why many people are
under the mistaken impression that AAFCO actually regulates the food industry,
or is a governmental agency. Neither is true.
Remember, it's the states that are in control – but they control only the pet
food manufacturers who try to sell food within their borders. Only the state's
feed control officials have the ability to approve or deny the right of a
manufacturer to sell a particular food in their state, or to punish
manufacturers for labeling infractions. And the only way they can make these
decisions, is to test the various foods that the makers register for sale
VIOLATIONS AND ENFORCEMENT
As mentioned above, some states test only the Guaranteed Analysis information
(protein, fat, fiber, moisture). Others test individual nutrients (amino acids,
vitamins, minerals) as well. California tests nothing. Kentucky tests nearly the
entire AAFCO Nutrient Profile. Nearly every manufacturer has had one or more
foods fail various tests at one time or another. Many foods fall short, usually
on the stated protein levels. Some are too high in ash or fiber. Even more
ominous is the failure of tests for major minerals such as phosphorus or
calcium. The manufacturers assert that tests on any particular batch or lot of
food may not be representative of all their foods, but because such failures are
so widespread, from the cheapest generic to the most specialized and expensive
foods, it is a very disturbing trend.
State feed control officials can and do enforce violations of their states'
regulations, but this process is not sweeping and surely not swift. Depending on
the nature of a problem they discover with a food, there are numerous levels of
notification and correction; in the mean time, tons of non-compliant food can be
sold and consumed by our pets. Each state compiles an annual report which lists
the violations; these documents are public record. Many states publish this
data; a few, like Missouri, and Indiana, post it on the Internet
Regulation and enforcement of the pet food industry varies widely from state to
state. Some states have adopted very tough legislation, and others have minimal
pet food laws. Some states scrutinize foods carefully, and others hardly at all.
And you can't assume any coordination between the state's regulatory aims and
its follow-through on enforcement. California, for example, has one of the
nation's most restrictive pet food production Acts in the country, the "Pure Pet
Food Act of 1969." It prohibits 4D meat and other bad stuff in pet food.
However, the Act isn't enforced at all. Texas has adopted the AAFCO nutrient
profiles, tests the Guaranteed Analysis, and enforces everything. The annual
feed report from Texas averages around 100 pages (in very fine print) of
violations and actions taken. There are almost 30 pages just listing Stop Sale
orders of animal feed and pet food!
In reviewing the states' reports, it's obvious that every food fails something
somewhere, some time. But the most striking trend is that the foods with the
most problems tend to be locally produced and regionally marketed; there are
numerous small pet food companies that make foods that are sold in one state
only or across one state border only. The national manufacturers stick closer to
the rules; if they ship nationally, they pretty much have to make their products
to whichever state standards are the strictest.
THE BOTTOM LINE
If you're like us, the more you learn about the pet food industry, the more you
feel you should worry about your pets' food! The kind of regulation and
oversight that many of us assume is present over the industry as a whole really
doesn't exist. Instead, existent regulation and the vicissitudes of the market
itself tends to promote the better products, and weed out the "bad actors" over
time. It really is amazing that the industry is as "clean" as it is – but this
isn't, perhaps, saying much. In an ideal world, every food in the country would
have to pass feeding trials and lab tests that prove sufficient (and not
harmful) nutrient levels on an ongoing basis. But in this world, our pets
represent the "test animals," and we are providing the feeding trials.
Pet Food Marketing Hype
― The Inside Scoop From a Holistic
By Jean Hofve, DVM
A trip down the pet food aisle these days will boggle the mind with all the
wonderful claims made by manufacturers for their particular products. But
what's the truth behind all this marvelous hype? You might be very
surprised...let's take a look.
1. Niche claims. Today, if
you have an indoor cat, a canine athlete, a Persian, a Bloodhound, a Yorkie,
or a pet with a tender tummy or itchy feet, you can find a food "designed"
just for your pet's personal needs. Niche marketing has arrived in a big way
in the pet food industry. People like to feel special, and a product with
specific appeal is bound to sell better than a general product like "puppy
food." But the reality is that there are only two nutritional standards
against which all pet foods are measured (adult and
growth/gestation/lactation)-everything else is marketing. Your best bet is a
food made with good quality ingredients that satisfies "All Life Stages."
2. "Natural" or "Organic" claims. The definition of
"natural" adopted by AAFCO is very broad, and allows for artificially
processed ingredients that most of us would consider very unnatural indeed.
The term "organic," on the other hand, has a very strict legal definition
that the USDA has ruled applies to pet food. However, some companies are
adept at evading the intent of these rules. For instance, the name of the
company or product may be intentionally misleading. For instance, some
companies use terms like "Nature" or "Natural" in the brand name, whether or
not their products fit the definition of natural.
3. Ingredient quality claims. A lot of pet foods claim
they contain "human grade" ingredients. This is a completely meaningless
term-which is why the pet food companies get away with using it. The same
applies to "USDA inspected" or similar phrases. The implication is that the
food is made using ingredients that are passed by the USDA for human
consumption, but there are many ways around this. For instance, a facility
might be USDA-inspected during the day, but the pet food is made at night
after the inspector goes home. The use of such terms should be viewed as a
4. "Meat is the first ingredient" claim. A claim that a
named meat (chicken, lamb, etc.) is the #1 ingredient is generally seen for
dry food. Ingredients are listed on the label by weight, and raw chicken
weighs a lot, since contains a lot of water. If you look further down the
list, you're likely to see ingredients such as chicken or poultry by-product
meal, meat-and-bone meal, corn gluten meal, soybean meal, or other dry
protein. Meals have had the fat and water removed, and basically consist of
a dry, lightweight, high-protein powder. It doesn't take much raw chicken to
weigh more than a great big pile of this powder. Not only that, but the
"chicken" used in dry food is actually a slurry of about 90% water; so in
reality the food is based on the protein meal, with very little "chicken" to
This has become a very popular marketing gimmick, even in premium and
"health food" type brands. Since everybody is now using it, any meaning it
may once have had is so watered-down that you may just as well ignore it.
5. Special ingredient claims. Many of the high-end pet
foods today rely on the marketing appeal of people-food ingredients such as
fruits, herbs, vegetables, and a variety of supplements such as glucosamine
or probiotics. However, the amounts of these items actually present in the
food are small and not therapeutic. Fruits and vegetables are usually scraps
and rejects from processors of human foods-certainly not the whole, fresh
ingredients they want you to picture. Such ingredients don't provide a
significant health benefit and are just a marketing gimmick.
It's a jungle out there...Pet food marketing and advertising has become
extremely sophisticated over the last few years. It's important to know what
is hype and what is real, so you can make informed decisions about what to
feed your pets.
A Holistic Vet's Guide to Pet Food, Part I Pet Food Marketing Hype
― Who's in Charge?
By Jean Hofve, DVM
In 2007, when thousands of pets were sickened or killed by pet food
contamination, and the recalls went on for months, the pet food industry
claimed that it was highly regulated and therefore trustworthy. Clearly,
that was then and still is not true. There are regulations that apply to pet
food, but nearly all of them apply only to the post-production period-that
is, labels, marketing, and advertising. What goes into pet food and how it
is made is virtually unregulated. And yet, the labels can provide a great
deal of information about that very process, tell you about the quality of
the food, and help you decide which ones to avoid and which are the best and
healthiest food for your pets.
Despite all the "small print" and vague
terms on the average pet food label, the rules governing pet food labels are
actually quite simple. Once you know these few basic rules, you'll be
scanning the label like a pro and actually understanding what it says, what
it means, and whether it's good for your pet.
First, let's take a look at who makes the rules. There are two primary
groups involved: state governments and the federal government. At the
federal level, the U.S. Food and Drug Administration (FDA) and the U.S.
Department of Agriculture (USDA) are involved. At the state level, the state
agriculture department in most states (a different department in a few
states) designates one or more of its feed control officials―the folks that
inspect all animal feed, including pet food―to participate. The body to
which these representatives belong is called the Association of American
Feed Control Officials (AAFCO). AAFCO is not itself a regulatory body and
does not do any tests or enforce any laws.
Every year, AAFCO has meetings to discuss potentially needed changes, and
publishes a book containing everything an animal feed or pet food maker
needs to know: what nutrient levels are needed in a food, the rules
governing labels, and how to conduct tests. These are "model" regulations
that can then be adopted by the states, where they then become law. Only
about half the states have actually adopted the AAFCO rules; and several
others have something similar on the books. However, in order to ship
nationally, all major pet food companies follow the AAFCO guidelines in
order to avoid problems when the inspectors check out their foods.
There is a lot of confusion about AAFCO, and many writers have accused
the organization of being "the fox guarding the henhouse" because their book
lists not only the government officials, but also a long list of "advisors"
from the industry, including many pet food companies. However, these
advisors are basically just lobbyists; they do have some influence with the
officials, just like any government lobbyist, but they don't make the rules.
The state and federal representatives are the only voting members with power
to change the rules. AAFCO takes its consumer protection role seriously and
has rejected many attempts by the pet food industry to change ingredient
names, label requirements, and other items that would make it harder for the
consumer to make informed choices.
So what does this all mean for your pet? First, this knowledge helps you
understand how laws and rules do and do not protect your pet. And
second―and perhaps more importantly―as a result of this understanding,
you'll be better equipped to evaluate other information you might find in
books or on the internet. After all, those who have a false concept of how
pet food regulation actually works are likely to be wrong about other things
as well―so you probably shouldn't take their advice!
A Holistic Vet's Guide to Pet Food, Part II
― The Secrets You Can Learn From a
Pet Food Label
By Jean Hofve, DVM
Despite the confusing lists and terms on a pet food label, you can discover
a lot about the quality of the food from the label - and make an informed
decision about whether it's going to be good for your pet or not!
CONTENT. It might surprise you that the name of the flavor is
strictly defined, and tells us about the animal product content of the food.
(This rule applies only to animal products; listing rice, barley, spinach,
or other plant product in the name is essentially meaningless and simply
- "Chicken for Dogs" must contain at least 95% chicken (excluding
- Similarly, "Chicken and Beef for dogs" will be 95% chicken and beef
together, and there must be more chicken than beef, since chicken
appears first on the label.
- If the label says "dinner," "platter," "entrée," "nuggets,"
"formula," or similar term, there must be 25% of the named ingredients.
That is, "Beef Dinner" must contain 25% beef.
- If more than one animal ingredient is named, such as "Beef and Liver
Entrée," the two together must comprise 25% of the total, and the second
ingredient must be at least 3%.
- Ingredients labeled as "with" must be present at 3%. "Beef Dinner
with Liver" needs to contain only 3% liver.
- An ingredient labeled as a "flavor," such as "Beef Flavor Dinner,"
may not actually contain any beef meat at all, but more likely will
contain a digest or other by-products that give the food a beef flavor.
. The FDA and AAFCO determine the ingredients
that can be used in food for animals, and define them specifically with a
particular ingredient name so that they are standardized. However, many
currently used ingredients were defined many decades ago in the terminology
of the day, so today they are sometimes confusing.
Meat: Contrary to what
many writers have said, meat is defined in the AAFCO book as being from only
four species: cattle, sheep, goats, or swine (pigs). Meat is specifically
defined as striated muscle, which is what most of us think of as meat but
also includes the heart, diaphraghm, and esophagus. If the meat is labeled
with a name, such as "lamb" or "beef" then that must be the predominant
species in that product.
By-Products: On many products, you will notice that one of the major
ingredients listed is "by-products," usually "meat by-products" or "poultry
by-products." By-products are basically defined as "parts other than meat."
These may include internal organs not commonly eaten by humans, such as
lungs, spleens, and intestines, other parts such as cow udders and uteri,
and in the case of poultry by-products, heads, guts, undeveloped eggs, and
feet. By-products must be from "freshly slaughtered" animals; meaning that
the animal had to be alive and upright as it went into the slaughterhouse.
By-products are used mostly in wet food, such as those in cans or pouches.
Certain by-products, such as livers, kidneys, and hearts, are sometimes
referred to as "giblets."
Rendered Products: Rendering is a process of grinding and cooking that
separates water, fat, and protein. Rendering produces two major items:
animal fat or tallow, and a processed product usually called "meat meal,"
"meat and bone meal," or "by-product meal." These meals, which are
essentially dried proteins, are used in dry foods and are usually the
primary protein source in a given dry food. Rendered ingredients vary
greatly in quality. Many rendering facilities are closely associated with
slaughterhouses, which are in turn connected with feedlots or poultry farms.
Such rendering facilities are more likely to produce a good quality,
relatively pure meal. They are likely to be designated with the name of the
source animal, such as "chicken meal."
Independent renderers process such items as road kill, euthanized shelter
dogs and cats, and other unappetizing ingredients. These items are not
supposed to find their way into the food chain but are more often used in
cosmetics, cleaning products, fertilizers and industrial applications.
However, over the years there have been numerous unproven reports of this
material being processed into dog and cat food. The Center for Veterinary
Medicine, a branch of the FDA, admits that dead dogs and cats are commonly
rendered, and although there is no legal prohibition against it, they do not
"condone" the practice. Today, most pet food makers "certify" that they do
not use this material in their foods; in reality, it may still happen, but
much more rarely since the public's awareness was raised.
Animals that are dead, dying, diseased, or disabled prior to reaching the
slaughterhouse are known as "downers" or "4D." These are condemned for human
consumption, and are generally sent for rendering along with other parts and
items unsuitable for human use, such as out-of-date supermarket meats (along
with their plastic wrappers), cut-away cancerous tissue, and fetal tissue
(which is very high in hormones). Some animals may have been dead and left
to rot in the sun for days before rendering. The rendering process kills the
maggots and bacteria inhabiting these carcasses, but their toxic wastes are
not destroyed, and are thought by some experts to contribute to digestive
problems in dogs.
Vet's Guide to Pet Food, Part III ― Additives,
Preservatives, and Contaminants 5
By Jean Hofve, DVM
Nearly all commercial pet foods contain at least some
additives. These include coloring agents, texturizers, drying agents,
humectants, binders, and dozens of other items with numerous other purposes.
For instance, all those "slices" and "bits" and "shreds" in canned dog and
cat foods―you didn't think those were really meat, did you? No, they're
mostly textured vegetable protein (such as wheat gluten) that's been formed,
cut, dyed, and shaped to look like pieces of meat. Even some of the
vegetables in canned foods are fake: carrot chunks and peas may be mainly
colored wheat gluten.
An interesting ingredient you'll see in many canned foods, especially the
cheaper ones, is titanium dioxide. This is the compound that makes white
paint white. It is used to lighten the color of the mix so that added
colors―those appealing browns and reds that make pet food look sort of like
meat, will show up. One reason for this is the use of condemned ingredients
in the food. At the slaughterhouse, carcasses and parts condemned for human
consumption are required to be marked to make sure they don't find their way
back into the human food chain. This is done by dousing the meat or other
parts with either purple dye (the same stuff used by the USDA to mark the
quality of beef, such as "USDA choice"; it's made from grapes), or liquified
charcoal. Both of these are harmless, but will obviously contribute their
color to any mix they're used in. Since most pet parents aren't going to
find purple or black pet food appealing, the food is dyed white with
titanium dioxide and then dyed again to the desired color.
All dry pet foods contains even more additives and preservatives than
canned food; canning is itself a preserving process. The most worrisome are
the chemical preservatives BHA, BHT, propyl gallate, and ethoxyquin.
Ethoxyquin is banned from nearly all human food products (except certain
spices) due to its cancer-causing properties. Most manufacturers have
changed to less-controversial preservatives, such as Vitamin E (tocopherol),
but ethoxyquin is still used in many "prescription" foods. Ethoxyquin is
required for imported fish meal, a prominent ingredient in many pet foods,
but not listed on the label; there is a natural substitute (NaturOx) but it
is expensive and few companies use it.
CONTAMINANTS. Consumers these days are concern about pet
food contamination, for good reason. The 2007 recall of pet food made with
contaminated wheat gluten and rice protein from China sickened tens of
thousands of pets, and thousands of dogs and cats died.
Consumers should also be concerned about pesticide residues, antibiotics,
and molds contained in pet food ingredients. Meat from downer animals may be
loaded with drugs, including antibiotics and barbiturate used for
euthanasia; some of these are known to pass unchanged through all the
processing done to create a finished pet food. The FDA did a study on
pentobarbital euthanasia solution and found it in multiple dry dog foods;
they attributed it to euthanized livestock, and said the levels were too low
to harm dogs, but no one has considered the cumulative effects of eating
such food day after day, year after year. The ingredients most often
associated with a positive test for pentobarbital were animal fat and
meat-and-bone-meal. Tests for dog and cat DNA were, fortunately, negative.
Fungal contamination of grains is also a serious consideration. Corn is
commonly affected by aflatoxin mold, which secretes toxic wastes. There have
been several incidents in which fungal toxins resulted in food recalls after
dogs became sick; at least 120 dogs died in just 2 such cases.
Crops that are condemned for human consumption due to excessive pesticide
residues can legally be used, without limit, in food intended for animals,
including pets. Not only are our pets directly exposed, the livestock eating
such crops are going to end up back in the human food chain! As well, toxic
sewer sludge has also been used as fertilizer in several states, feeding the
crops that feed us, livestock, and our pets.
Perhaps the scariest thing about contamination is that no one can predict
what the next catastrophic contaminant will be. After the aflatoxin cases,
pet food companies started testing for fungus and mold. After the melamine
debacle, they started testing for melamine. But there are thousands, if not
millions, of toxins and chemicals that could potentially find their way into
pet food; they can't test for everything. But pet food recalls are quite
common; there's usually at least one per year and sometimes many more than
that. The best we can do is buy products from reputable manufacturers, made
with better quality ingredients, and then hope that the next big recall
doesn't affect your brands!
A Holistic Vet's Guide to Pet Food, Part IV
― "Complete and
Balanced" ― What Does That Really Mean?
By Jean Hofve, DVM
On most pet food labels, there will be a statement indicating that the food
is "complete and balanced" for a particular life stage of the pet (there are
only two: growth/reproduction and adult).
A pet food may be labeled as "complete and balanced" if it meets AAFCO
standards. There are two methods for achieving this: (1) meeting published
standards for content, or (2) feeding tests. If a food does not meet either of
these standards, it will be labeled "for intermittent and supplemental feeding
only." Such foods are fine as treats or for short periods of time, but should
not be fed as the sole diet. Keep in mind, too, that the standards, such as they
are, set only "minimums" and "maximums," not "optimums." Commercial pet foods
are designed to be adequate for the average animal, but may not be suitable for
an individual animal's variable needs.
(1) Nutrient Profiles. These standards set the required amounts of protein,
fat, vitamins, minerals, and so forth. When adopted in 1989, they were the best
information available on canine nutritional needs. New research was published in
2003 that provides up-to-date information, but new standards are still in the
process of being adopted by AAFCO and/or the states, and are not currently being
followed by pet food manufacturers.
Moreover, any manufacturer can synthesize a food containing sufficient
amounts of each ingredient according to the Nutrient Profiles, yet dogs may not
do well on it because the standards do not address the issues of
"bioavailability" of nutrients to the animal. Certain forms of vitamins and
minerals, for example, are poorly absorbed from the digestive tract. A noted
veterinary nutrition textbook claims that a food can be created from old leather
boots, wood shavings, and crankcase oil that will meet the technical
requirements for protein, carbohydrates, and fats, yet would be completely
indigestible. Unfortunately, given the ingredients used by some manufacturers,
"Old Boot" may be closer to the truth than anyone wants to admit!
(2) Feeding Trials. These are considered the "gold standard" of pet food
formulation. However, when you look at the actual AAFCO protocols for an adult
maintenance diet, a manufacturer must feed exclusively the test food to only six
animals for six months. (Eight animals are required at the outset; however, two
of them may be dropped from the trial for non-diet-related reasons.) Foods
intended for growth and reproduction must be tested for only 10 weeks.
Most of the large, reputable pet food producers, such as Iams, Hills,
Walthams and Purina, maintain large colonies of dogs and cats, and test their
foods on hundreds of animals over years or even multiple generations. Other
manufacturers rely on facilities that keep animals for this purpose to do the
studies for them.
It is easy to see how a poor quality diet could be fed for only six months
without seeing adverse health effects, and legitimately be labeled as meeting
AAFCO standards. In fact, studies have confirmed that even foods that pass
feeding trials may still be utterly inadequate for long-term maintenance.
Worse still is AAFCO's "family rule" which was heavily promoted by the pet
food industry. This rule declares that foods that are "nutritionally similar" to
a food that has passed an actual feeding test may also carry that claim. The
"similarity" need only be that the foods have a similar calorie content. This
leaves the "feeding test" label as a completely unreliable indicator of the
quality of the food, and its status as a "gold standard" in serious doubt.
Life Stages. As mentioned above, there are only 2 life stages recognized by
the AAFCO standards: adult maintenance, and growth/reproduction, which includes
puppies and kittens as well as pregnant and lactating (nursing) mothers. Foods
claiming adequacy for "All Life Stages" meet the higher nutritional requirements
This means that there are no separate standards, and thus no regulations
about, food for "senior" or "mature" pets, foods designed for "Yorkshire
Terriers" or "Persian Cats," or foods for "high performance" or "indoor"
animals. These designations are purely marketing hype. Yes, the ingredients may
be a little different, or the protein or fiber content may have been
manipulated, but every single niche food must still meet one of those same two
basic requirements. A claim of "light" or "reduced calories" does have to be a
certain percentage less calories than the food it is being compared to, but
whether such foods actually help pets lose weight in a healthy manner is highly
Mad Cow Disease and Your Pets
By Jean Hofve, DVM
On December 23, 2003, the first official U.S. case of "mad cow disease"
(Bovine Spongiform Encephalopathy or BSE) was reported in the news. However,
astute researchers and even the pet food industry acknowledge that a
BSE-like disease has been present in the U.S. for many years. Is this a
threat to our pets? Let's look a little closer at this unusual disease.
Around the end of 1985, the first cases of a bizarre bovine neurological
disease, nicknamed "Mad Cow Disease," were reported in England. British beef
was quarantined and hundreds of thousands of cattle destroyed. As early as
1988, some experts thought that this disease might be transmissible to
humans. However, a definitive link to a "new variant" of the human
degenerative neurological disease, Creutzfeld-Jacob Disease (nvCJD), was not
established until 1996. Consumption of infected beef meat was considered to
be the cause.
However, more recent research suggests it may not be the meat itself, but
whole-body contamination with brain tissue during the slaughter process,
which is to blame. The brain and spinal cord of infected animals carries a
high concentration of infective particles, called "prions." Captive bolt
stunning, which is the usual way of knocking a cow unconscious just prior to
slaughter, splatters brain matter into the bloodstream, where it is rapidly
disseminated throughout the animal's body, literally within a heartbeat.
This apparently happens faster than the animal can be hoisted and moved to
the next stage of slaughter, where it is bled out, even though this normally
occurs in less than 60 seconds. Subsequent removal of the brain and spinal
cord may thus be inadequate to prevent infected material from directly
contaminating edible tissues.
Cattle presumably acquired BSE from eating food containing rendered material
from sheep infected with scrapie, a common ovine disease. This feeding
practice was banned in the U.K. about 18 months after the first BSE cases
came to light.
One European country after another subsequently discovered BSE within its
borders. France, Ireland, Portugal, Switzerland, the Netherlands, Belgium
and Denmark all reported cases of BSE in the 1990s. It has also leaped to
far-off places as Japan, the Falkland Islands, the Azores, Oman, and Canada.
In 2000, BSE was discovered in Germany, much to the consternation of the
ministers who had prided themselves on strong regulations intended to keep
the fearsome disease at bay. One report stated that Italy and Spain are
"likely to have been infected," and that BSE "cannot be ruled out in four
other European countries, as well as Australia, Canada, and the USA." There
have been some 180,000 infected cows identified worldwide since the outbreak
began in Britain. More than 100 people have died from nvCJD related to BSE.
In addition to human victims, more than 100 domestic and big cats, as well
as several ruminant species in zoos, have been affected.
In 1993 the epidemic reached its peak as the 100,000th BSE case was
identified. Wrangling over which beef or sheep products could be used for
what, and where and how they could or could not be exported, continued
throughout the 1990s and into the new millennium.
Until the end of 2003, the U.S. government kept itself busy congratulating
itself on preventing such transmission in this country by virtue of its
"active surveillance program." However, it was never certain that we didn't
have BSE in American livestock. The U.S. banned importation of
British-origin beef in 1985 for other reasons, but by then the disease was
entrenched in British cattle, and possibly present in imports prior to that
About 500 live British cattle were imported into the U.S. between 1981 and
1989, when the USDA banned the importation of live cattle. While most of
these cattle were traced and located, 34 could not be found. These were
presumed dead, and most of the rest of the other cattle were also known to
have died or been slaughtered. Of most interest, perhaps, is the disposition
of the carcasses, but this is not known in all cases. It is possible, if not
likely, that at least some of these animals were rendered. If any of them
were infected, it is also possible that they may have become "downers," and
routed into the human and/or animal food chains.
A similar scenario was blamed for several outbreaks of a BSE-like disease
among mink in fur farms. We also have sheep scrapie in both the U.S. and
Canada, which was recognized in the 1940s. But not until 1989 did the
American rendering industry initiate a "voluntary ban" on accepting
potentially infected sheep parts for processing. And even then, a USDA
survey three years later found that 6 of 11 inspected plants were still
accepting the banned parts. The feeding of sheep and other ruminants back to
ruminants was not officially banned in the U.S. until October 1997.
In July 2000, a "foreign" spongiform encephalopathy was found in four
imported sheep in Vermont. This prompted the USDA to declare an
"extraordinary emergency." More than 700 animals in three flocks of milking
sheep were quarantined as a result. In March 2001, two flocks were seized
for testing and destruction. USDA assumed the responsibility for ensuring
that, as these sheep are destroyed, they do not enter the human or ruminant
food chain; but there is nothing to prevent them being routed into pet food.
In early 2001, USDA announced that inspections of feed mills and rendering
facilities found almost 800 lacking required warning labels and/or systems
in place to prevent mixing of banned products into ruminant feeds. Thousands
of facilities had yet to be inspected. In fact, USDA apparently has only a
vague idea of how many such facilities actually exist. Just two weeks after
that announcement, 1,200 cattle in Texas were quarantined because they may
have been fed banned materials.
Is BSE a threat to our companion animals? One industry analyst suggested
early on that potentially infected materials should be excluded from cat
foods, since cats were susceptible to the disease in Europe (about 100
domestic and exotic cats died from TSEs). Food-producing animals that die
from unknown causes (which may include BSE or similar diseases) are
typically routed into pet food and animal feeds. The presumed agent of
transmission of BSE is not inactivated by rendering or most other types of
processing, including cooking, formaldehyde, dry heat, autoclaving, or even
incineration. There are a handful of methods that are known to destroy the
prion, but they are highly impractical for most uses.
BSE-like diseases (transmissible spongiform encephalopathies, or TSEs) have
been present in the U.S. for decades. Chronic wasting disease of elk and
deer is well characterized as a prion disease. Sheep scrapie has been
recognized since the 1940s in the US and Canada. Feeding of scrapie-infected
sheep was blamed for the presence of a TSE disease among mink farms as early
as 1947. However, in at least two instances, affected mink had not been fed
sheep. A variant that caused an outbreak on two fur-farms in Wisconsin in
1985, where mink had been fed exclusively downer dairy cows, was shown to
cause BSE lesions in experimentally infected cattle. Significantly, the
infected steers did not develop symptoms of "madness" like British cattle,
but instead became ataxic and went down.
"What if the strain of BSE in American cattle produces more of a 'downer cow
syndrome' than mad cow syndrome?" speculated the researchers. "This
possibility would definitely complicate surveillance programmes for BSE in
the United States, a country that has hundreds of thousands of downer cows
each year and no means for routinely diagnosing their cause." And in fact
this exact scenario has played out in the U.S.
Downer cows in the U.S. were, until 2004, still slaughtered for human
consumption; and to this day they are commonly used in pet food. Moreover,
with non-ruminant proteins in high demand for ruminant feeds, ruminant
proteins are now more likely to be processed into pet foods.
Interestingly, although many species have been affected, cats seem to be
especially susceptible. No canine cases were ever confirmed in the U.K., and
it was presumed that dogs were somehow resistant. However, in 1997 a golden
retriever who died in Norway had brain lesions consistent with a TSE-like
disease, allegedly from dog food it consumed in the 1980s. Furthermore, a
disease called "hound ataxia" has affected U.K. hunting dogs since the
1930s. Hunting hounds are commonly fed offal from downer cattle and sheep.
Research in the early 1990s showed that microscopically, this disease shares
pathological features with scrapie, and at the electron microscopic level,
Scrapie Associated Fibrils (SAF) were detected. These facts imply the
presence of BSE many years before its official debut in 1986. However, both
the initial study and further research to explore this possibility have been
ignored or suppressed by the British government.
The U.S. and Canada long believed they were free of bovine spongiform
encephelopathy (mad cow disease). However, a significant portion of this
confidence was based on the fact that BSE had not been found in any tested
animals, including downer cows at slaughterhouses. Of the 37 million cattle
slaughtered for meat each year in the U.S., about half a million cattle are
downers. Canada tests fewer than 1,000 cattle a year. The U.S. currently
tests about 7,500 downers per year (about 0.15%). Switzerland tested 20,000
cattle in a single year ― and found five with BSE. Despite the lack of
vigilance and appallingly inadequate testing, confirmed BSE cases were
finally found in both Canada and the U.S. in 2003. One can only imagine how
many cases continue to go unnoticed.
UPDATE: 4/27/05 Whistleblowers claim Mad Cow cover-up by USDA (from
Organic Consumers Association). "The USDA has been covering up cases of Mad
Cow Disease, according to a USDA veterinarian in charge of monitoring cattle
for the fatal disease. On the eve of retirement, Dr. Masua Doi confessed to
sketchy testing since 1997. "I don't want to carry on off to my retirement,"
said Doi. "I want to hand it over to someone to continue, to find out. I
think it's very, very important. How many did we miss?" Doi's concerns are
shared by other USDA contracted scientists, like Dr. Karl Langheindrich who
runs a test lab in Georgia and says the appropriate animal parts are not
sent to him for accurate testing. In addition, two weeks ago, U.S.
agriculture inspector Lester Friedlander offered testimony to a Canadian
House of Commons committee revealing the U.S. has been covering up Mad Cow
What can you do to prevent this disease in your home? The main consideration
is to not buy commercial beef, particularly ground beef (which is plagued
with many other contamination problems as well). However, organically grown
beef from long-established herds, who have never been fed animal proteins,
are most likely safe for human and feline consumption. Commercial pet foods
containing beef (and possibly lamb) may or may not be safe; they are
probably best avoided. Pork is still considered safe, primarily because most
hogs are slaughtered young; lambs, too, are slaughtered by 1 year of
age―before they have time to develop the disease. Because birds' metabolism
is so different from mammals, poultry is still a safe choice, and game meats
(except deer and elk, which can harbor a related prion disease), rabbits,
and other non-commercially raised mammals are unlikely to harbor BSE.