In most states in the US, raw (un-pasteurized) milk is allowed to be sold for pet food. But, raw pet milk products are required to disclose that they are ‘raw’. AAFCO has specific regulations for raw milk pet products that require the following disclosure “displayed in a striking way” on the label:
“WARNING: NOT FOR HUMAN CONSUMPTION – THIS PRODUCT IS UNPASTEURIZED AND MAY CONTAIN BACTERIA.”
This label disclosure requirement is fair. Most consumers are familiar with pasteurized milk products, so when a product is not pasteurized it is necessary to disclose it to the consumer. Pet owners should be informed of what they are buying.
But…
US consumers are also familiar with USDA inspected and passed meat. This quality of meat is the ONLY quality of meat sold to US consumers (federal law requires all food to use only USDA inspected and passed meats) so it is the ONLY quality of meat they know.
However in pet food, the FDA makes an exception to what consumers are familiar with. The FDA allows pet foods to use uninspected and/or unapproved (condemned) meats – which are illegal to use in any food, human or animal food.
The former FDA Director of the Center for Veterinary Medicine – Dr. Steven Solomon – said in 2019: “we do not believe that the use of diseased animals or animals that have died other than slaughter for animal feed poses a safety concern and we intend to continue to exercise enforcement discretion.”
So…even if the pet food label includes the familiar ingredient (for example) “Chicken”, chicken in pet food could be something VERY WONDERFUL for you.
But, unlike raw milk for pets, there is no disclosure required for uninspected, condemned meat. No AAFCO regulation, no FDA rule, nothing.
In July 2022 we submitted a Citizen Petition to the FDA confirming that federal law requires disclosure to pet food consumers. Specifically, we found that federal law does not allow two ingredients to have the same common name if they have different food classifications. Such as human food ‘chicken’ which is required to be inspected and passed to the USDA and pet ‘chicken’ which the FDA allows to be condemned and/or not inspected.
Specifically on animal feed, federal law states: “The common or common name of a food, which may be a coined term, must accurately define or describe, in as simple and direct terms as possible, the main characteristic of the food or its distinguishing properties or ingredients. The name must be consistent across all identical or similar products and may not be confusingly similar to the name of any other food that is not reasonably included under the same name.”
In no uncertain terms, federal law requires ‘poultry’ (feed grade) pet food NOT required to be inspected and passed to the USDA to have a name other than human grade ‘poultry’ which is required by the USDA to be reviewed and passed. Federal law requires these two substance names cannot be “confusingly similar”.
Unfortunately, nineteen months later the FDA still has NOT responded to our Citizen Petition. So… as it stands now…
With raw milk, the regulation requires consumers to be informed.
But with illegally (FDA-allowed) condemned animal material, the regulation refuses to warn consumers.
(It’s almost as if there is a secret non-disclosure agreement between the FDA and feed grade pet foods that use condemned animal material.)
As long as the FDA does not require disclosure of the condemned material allowed in pet food, pet owners should be diligent in asking manufacturers: Are the ingredients in your pet food humane? grade or feed grade?
To learn more about the differences between human grade ingredients and feed grade ingredients, Press here.
Wishing you and your pet(s) the best,
Susan Thixton
Pet Food Safety Advocate
Buyer Beware of Author, Co-Author Dinner PAWsible
TruthaboutPetFood.com
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