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Fda & aafco

post #1 of 15
8/28/11 at 11:59pm
Thread Starter 
Just some quotes and links directly from the FDA and AAFCO websites. Respond to them as you like.


http://www.petfood.aafco.org/
From the front page: AAFCO does not regulate, test, approve or certify pet foods in any way.

AAFCO establishes the nutritional standards for complete and balanced pet foods, and it is the pet food company's responsibility to formulate their products according to the appropriate AAFCO standard.
(Bold was used by the AAFCO website)

http://www.fda.gov/ICECI/ComplianceM.../ucm074712.htm
*CVM is aware of the sale of dead, dying, disabled, or diseased (4-D) animals to salvagers for use as animal food. Meat from these carcasses is boned and the meat is packaged or frozen without heat processing. The raw, frozen meat is shipped for use by several industries, including pet food manufacturers, zoos, greyhound kennels, and mink ranches. This meat may present a potential health hazard to the animals that consume it and to the people who handle it.*
(Bold is mine)

http://www.fda.gov/ICECI/ComplianceM.../ucm074710.htm
Pet food consisting of material from diseased animals or animals which have died otherwise than by slaughter, which is in violation of 402(a)(5) will not ordinarily be actionable, if it is not otherwise in violation of the law. It will be considered fit for animal consumption.
(Bold is mine)

http://www.fda.gov/AnimalVeterinary/.../ucm047120.htm
Dog and cat foods labeled as "complete and balanced" must meet standards established by the Association of American Feed Control Officials (AAFCO) either by meeting a nutrient profile or by passing a feeding trial.
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post #2 of 15
8/29/11 at 12:33am
Completely misleading as you are aware from previous discussions, as the FDA acts on AAFCO recommendations in an official relationship and enforces ingredient definitions.
Quote:
The Food and Drug Administration's (FDA) Center for Veterinary Medicine (CVM) has signed a Memorandum of Understanding with the Association of American Feed Control Officials (AAFCO) that allows FDA to formally recognize the Association's list of feed ingredients and defines the role FDA can play in deciding on the suitability of feed ingredients offered for addition to the list.

AAFCO uses a "New and Modified Feed Ingredient Definitions Process" to determine the suitability of feed ingredients and to establish standard ingredient names, which FDA considers the common or usual name, used on feed labels as required by state and federal law. This memorandum allows FDA to recognize formally the AAFCO process and to have a clearly defined role in reviewing ingredients for the list.
4-D meat is permitted in pet food, however, an ingredient like "chicken" or "chicken meal" is not permitted by law to include 4-D meat. Ingredients such as "animal digest" or "meat by-product" however are not limited in this fashion. This was discussed in tremendous detail in another thread where it was falsely stated that there was little distinction between the ingredients "chicken" and "poultry by-product".
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post #3 of 15
8/29/11 at 1:21am
Thread Starter 
Quote:
Originally Posted by Ducman69 View Post
Completely misleading as you are aware from previous discussions, as the FDA acts on AAFCO recommendations in an official relationship and enforces ingredient definitions.

4-D meat is permitted in pet food, however, an ingredient like "chicken" or "chicken meal" is not permitted by law to include 4-D meat. Ingredients such as "animal digest" or "meat by-product" however are not limited in this fashion. This was discussed in tremendous detail in another thread where it was falsely stated that there was little distinction between the ingredients "chicken" and "poultry by-product".
Except I didn't mention anything about ingredient definitions or what 4-D was or wasn't a part of...
Please keep on topic.
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post #4 of 15
8/29/11 at 2:41am
Quote:
Originally Posted by Minka View Post
Except I didn't mention anything about ingredient definitions or what 4-D was or wasn't a part of...
Exactly, you left that information out, which is why it is very misleading IMO.

If you do not have mystery meat by-products, bone/meat meal, or animal digest as ingredients in your commercial wet or dry food, and it carries the AAFCO seal, then no such concern is warranted.

I assume "the topic" is to create the appearance that commercial meat is of horrible quality and the FDA/AAFCO powerless, as a counter to safety concerns raised over raw-food and how raw-food is by and large not regulated for safety by the FDA and AAFCO in the "best food" thread.
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post #5 of 15
8/29/11 at 10:23am
Quote:
Originally Posted by Ducman69 View Post
If you do not have mystery meat by-products, bone/meat meal, or animal digest as ingredients in your commercial wet or dry food, and it carries the AAFCO seal, then no such concern is warranted.
From what I can gather, there's no such thing as a AAFCO seal, because that would be "certifying" it, and they don't do that. They only put forth the requirements, and the foods can say they meet those requirements.
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post #6 of 15
8/29/11 at 12:18pm
A portion of an article from the Truth About Pet Food.com, under their regulation section:

The EPA Food Waste program states "Recovering food discards as animal feed is not new. ... There are also companies that convert food discards into commercial animal feed and pet food. Feeding waste food to livestock or having the food processed into animal feed is a viable option for recycling food scraps and provides economic and environmental benefits for all involved."

The "companies that convert food discards into commercial animal feed and pet food" are renderers. From a 2004 Report to Congress "Renderers convert dead animals and animal byproducts into ingredients for a wide range of industrial and consumer goods, such as animal feed,..."

nationalaglawcenter.org.

Renderers also convert waste/expired food from retail outlets such as Walmart into animal feed. At the January AAFCO (American Association of Feed Control Officials) mid-year meeting, conversation took place at the request of the rendering industry to provide a animal feed/pet food name for grocery store waste (example provided at the meeting was expired Hot Pockets from Walmart). (In other words, trying to come up with a euphemistic name to cover up what it really is.)
The purple writing is mine.

Ducman will say that all is right with the pet food industry, that there's nothing to see here, that we should all move on.

And he will likely be at least partly successful in his endeavor to get folks to look away. It's an uneasy thing to think there might be something fundamentally "wrong" with the foods so many of us are feeding our littlest family members.

I would urge you all to ignore him, however, and make your own decisions. Just a little research will put a crack in his pretty construction and a little more will bring it down entirely. The TruthAboutPetFood.com is one place to start; the Pet Food Products Safety Alliance is another (the PFPSA publishes testing results done on foods submitted by the public which you might find interesting, if not shocking). The Feline-Nutrion.org site also has a few articles, including one titled, "Feeding Ring Dings and Krispy Kremes."

If you'd like more in-depth information, there are many books whose authors have explored this topic in great detail, including visiting pet food manufacturing plants and talking to people who work there. I recommend these books to all of you, but only if you have a strong stomach: Buyer Beware: The Crimes, Lies and Truth about Pet Food; Not Fit for a Dog!: The Truth About Manufactured Dog and Cat Food; Food Pets Die For: Shocking Facts About Pet Food; Protect Your Pet: More Shocking Facts are just a few.

Having said all that, I'm not going to add any more to this topic. Understanding the pet food industry practices is a shocking, nasty revelation and it's a lot easier on folks to come to it themselves. I like the upbeat part where we talk about what's good for our kitties.

AC
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post #7 of 15
8/29/11 at 12:37pm
Quote:
Originally Posted by Auntie Crazy
Ducman will say that all is right with the pet food industry, that there's nothing to see here, that we should all move on.
No, Ducman will say that raw-food advocates are posting very misleading information as a counter to concerns raised about the safety and lack of regulation of the raw-diet, by implying that commercial pet foods with ingredients like "chicken, turkey, chicken meal, brown rice, etc" and lacking "animal digest, meat by-product, bone meal, etc" would include the by-products and 4-D animals. It is indeed important to understand ingredients and avoid unsavory ones, but it is a great disservice IMO to use half-truths as scare tactics to promote the raw-diet agenda.
Quote:
Originally Posted by Willowy View Post
From what I can gather, there's no such thing as a AAFCO seal, because that would be "certifying" it, and they don't do that. They only put forth the requirements, and the foods can say they meet those requirements.
The AAFCO's has an official relationship with responsibility to set standards and definitions along w/ the CVM. The FDA (which sits on the AAFCO board as well), USDA, FTC, and State law then carry enforcement authority, as I understand it.

There are several AAFCO seals. The most common is "xxx is formulated to meet the nutritional levels established by the AAFCO Cat/Dog Food Nutrient Profiles for growth/reproduction, all life stages, maintenance." Another is "animal feeding tests using AAFCO procedures substantiate that xxx provides complete and balanced nutrition." Better yet is "AAFCO feeding trials confirm that xxx is complete and balanced for xxx life stages". It also sets definitions for various wording and ingredients, to define say the difference between "salmon, salmon meal, and fish meal" or "brewer's rice, rice bran, rice, and brown rice" the order that they are in by quantity and specifically what "organic" and "natural" is and to some extent even the name of the food itself (to be called "Lamb and Rice Cat Food" it has to be 95% lamb) along w/ the guaranteed analysis we see. FDA regulations ensure that when "complete" food is found to be lacking or alternatively contaminated with salmonella that it is recalled.
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post #8 of 15
8/29/11 at 12:51pm
Bottom line, if it comes in a can or a bag of kibble you can not guarantee what you are feeding because the product has been processed to the point that it's contents and origins are not longer recognizable.
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post #9 of 15
8/29/11 at 12:52pm
Quote:
Originally Posted by Melesine View Post
Bottom line, if it comes in a can or a bag of kibble you can not guarantee what you are feeding because the product has been processed to the point that it's contents and origins are not longer recognizable.
You can guarantee that it meets the definition of the ingredient on the ingredient list, under penalty of law. Manufacturers cannot call something "chicken" if it contains chicken feet or beaks or entrails or other by-products.

Don't get me wrong, I would enjoy even stricter FDA/AAFCO regulation, however I will certainly take at least some measures to ensure that the food I am feeding is nutritionally complete and will be recalled if found to be contaminated w/ bacteria than a complete and total lack of oversight and regulation.
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post #10 of 15
8/29/11 at 1:26pm
Most any food will past certification. Take what Meg Smart did for example (http://redstarcafe.wordpress.com/200...s-breakfast/):

Quote:
Meg Smart also spends some time in kitchen, brewing up a concoction of work boots, crankcase oil, wood shavings and vitamins. She sends it off to a lab where it passes the minimum industry nutritional standards. The beleaguered industry, meanwhile, says that it’s strictly regulated by the FDA but in fact the rules are written by the industry, and they’re not enforced. Hodgkins wants to see changes such as clear and honest labelling as a start.
http://www.bornfreeusa.org/facts.php?more=1&p=359 is also interesting to read.

http://www.petconnection.com/blog/20...oes-it-matter/ explains AAFCO feeding trials.
Quote:
An AAFCO feeding trial statement packs a bit more punch. A “maintenance†claim requires that 6 out of 8 healthy dogs or cats are kept alive for 26 weeks on the diet, without losing more than 10 percent of their body weight or having certain blood levels fall below specified levels, and passing an examination by a veterinarian at the trial’s beginning and conclusion.
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post #11 of 15
8/29/11 at 1:41pm
Since this has turned into another raw feeding thread, I'm moving it to that forum.
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post #12 of 15
8/29/11 at 2:12pm
I don't see how this is about raw feeding but ok.
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post #13 of 15
8/29/11 at 2:14pm
Quote:
Originally Posted by Ducman69 View Post
You can guarantee that it meets the definition of the ingredient on the ingredient list, under penalty of law. Manufacturers cannot call something "chicken" if it contains chicken feet or beaks or entrails or other by-products.

Don't get me wrong, I would enjoy even stricter FDA/AAFCO regulation, however I will certainly take at least some measures to ensure that the food I am feeding is nutritionally complete and will be recalled if found to be contaminated w/ bacteria than a complete and total lack of oversight and regulation.
Actually you can't even do that, otherwise we wouldn't have had all those pet food recalls that killed pets a few years ago. Also pet food companies have 6 months to change their packaging to reflect formula changes, so that means that what is listed on the package may not reflect what is inside.
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post #14 of 15
8/29/11 at 8:50pm
Thread Starter 
Quote:
Originally Posted by Ducman69 View Post
Exactly, you left that information out, which is why it is very misleading IMO.

If you do not have mystery meat by-products, bone/meat meal, or animal digest as ingredients in your commercial wet or dry food, and it carries the AAFCO seal, then no such concern is warranted.

I assume "the topic" is to create the appearance that commercial meat is of horrible quality and the FDA/AAFCO powerless, as a counter to safety concerns raised over raw-food and how raw-food is by and large not regulated for safety by the FDA and AAFCO in the "best food" thread.
No... the point was to raise awareness about what goes on with the FDA and AAFCO. I didn't know they had any official rules/articles that stated the kinds of things that I quoted and posted.

Quote:
Originally Posted by Ducman69 View Post
There are several AAFCO seals. The most common is "xxx is formulated to meet the nutritional levels established by the AAFCO Cat/Dog Food Nutrient Profiles for growth/reproduction, all life stages, maintenance." Another is "animal feeding tests using AAFCO procedures substantiate that xxx provides complete and balanced nutrition." Better yet is "AAFCO feeding trials confirm that xxx is complete and balanced for xxx life stages".
But this is what the websites of the raw foods I linked said! And you said they were not approved because they didn't have an official 'seal'. Make up your mind. :|
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post #15 of 15
8/29/11 at 11:00pm
Now that this has been moved to raw feeding and won't be read by nearly as many folks, I can participate without feeling too guilty I'm giving people information they don't want.

Per Dr. Hofve's article "Pet Food Regulation" on the LittleBigCat.com site:

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.

Pure folly.

And that's just the first two paragraphs.

AC
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