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 1
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.

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 the FDA.

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 pet food.

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 change.

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 required.

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 there. 

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.

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 Veterinarian 2
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 "Hype Alert."

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 be found.

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? 3
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 4
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 marketing.)

  • "Chicken for Dogs" must contain at least 95% chicken (excluding water).
  • 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.

INGREDIENTS. 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.




A Holistic Vet's Guide to Pet Food, Part III Additives, Preservatives, and Contaminants 5
By Jean Hofve, DVM

ADDITIVES.  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? 6
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 of growth/reproduction.

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 debatable.



Mad Cow Disease and Your Pets 7
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 time.

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 cases."

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.