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Letter to the FDA

post #1 of 97
Thread Starter 

We have talked about what really is in cat food and deceptive labeling enough to make me want to do something as soon as I finish reading a six-page thread LDG started and all the related webpages TCS members posted links to. Emily's Bridge Day is July 1, so I decided that would be a great time to start.

 

Of course, one person is not enough. I never had a dog. I have only had three cats my whole life. People who have or had both species and a lot of pets over many years need to write their own letters. If all of your cats only eat raw food explain why you are disgusted with the pet food industry. I can't do this alone.

 

The FDA might reject our complaints no matter how valid they are. I am aware of that. But I will never forget a quote that the Columbus (Ohio) Zoo and Aquarium put on a wall: "The man who makes the biggest mistake is he who did nothing because he could do so little."

 

I am begging you like a cat begs for tuna treats. Please help me send the message that deceptive labeling practices are making our pets sick, fat, or more likely to suffer chronic medical conditions because the FDA is not doing its job, which is to make sure cats and dogs eat what any animal nutrition expert knows they need and demand transparent labeling.

post #2 of 97
Thread Starter 

This is what I have written so far:

 

     I have full respect for the FDA veterinary department’s efforts to make lives better - and many times possible - for the millions of adopted pets and working animals in America.

     That said, I am one of many pet owners who are appalled about the FDA’s failure to control how pet food is made and labeled. Most cats and dogs from Maine to Hawaii and Alaska to Florida eat bad foods for two reasons:

     1. The ways commercial pet foods are made (keep reading for detailed explanations)

     2. Deceptive labeling that makes people think they are feeding good food to their pets

     Both problems need to be changed as soon as better methods can be created and implemented. All cats and dogs that are not eating 100 percent raw food exclusively, which is the vast majority of adopted, sheltered, and fostered pets in America, are affected by the FDA’s failure to control the pet food industry.

     I know and fully understand you are more concerned about human foods, which makes sense to me. I greatly appreciate that, as I do care about people too. However, with so many cats and dogs eating bad foods when part of your job is to feed them right, I have no reason not to be very upset about all pet food made of waste products and useless ingredients harming millions of cats and dogs.

     I apologize for offending you if any comments seem to be inflammatory. Such statements should be taken as an expression of how passionate many cat and dog lovers are on correcting both issues. Yes, I do have first-hand experience from caring for my own cats to prove the points.

 

Of course, I will do a lot of research before proceeding to make sure every statement is factual and not opinionated.

post #3 of 97
Emily, what you are doing is admirable. Just a suggestion....lol at this url:http://www.fda.gov/animalveterinary/resourcesforyou/ucm047113.htm.

The AAFCO controls the labelling of pet foods. You'll likely find that the fear and three AAFCO work together if you know what I mean. The pet food industry is yucky to put it plain but there is a lot of politics involved. If you want to read more read " Feed Your Pet Right" it gives a good summary of what goes into pet food. Not very s scientific but the authors analyze the AAFCO definitions and actually visit places where pet food is made, including rendering plants (the discussion of which may disgust you). Good luck and I look forward to reading more of your letter and the results!
post #4 of 97
Thread Starter 

Don't worry; I am going to do a lot of research before I finish my letter. Kitty%20Food.gif caticon.gif

post #5 of 97
I'd recommend keeping track of all the scientific references, and citing them in the letter. Here's an example: (not pet food, but a letter to government that uses references and citations): http://www.straypetadvocacy.org/PDF/NJDFWChandaLetter.pdf
post #6 of 97
Thread Starter 

Great idea Laurie!

 

I added a little bit more:

 

     My understanding is the FDA does have control over the production and labeling of pet foods. If that was not true, its veterinarian would not try to investigate when thousands of cats and dogs were killed by melamine poisoning in 2007. Why would the FDA get involved with that massive recall if controlling how pet food is made was not part of its job?

     I am not just complaining about toxins here, but toxins are part of the problem. If you care enough to worry about melamine poisoning, there is no reason not to care about all of the other bad stuff cats and dogs eat every day. There are strict rules to minimize toxins in human food. Why don’t they apply to cats and dogs, who are like children to their caretakers?

post #7 of 97
Have you ever eaten a Hot Pocket? Totino's Pizza? Packaged bologna? Colored sugar cereal? Because those are all very similar to cheap pet food laughing02.gif. Do you understand the health effects of food colorings and processed meats? What about BHA/BHT? Did you know a lot of frozen pizzas don't use real cheese (they use cheese-like soy product)?

I think you might be a little optimistic about the quality of human food and the rules about how it's labeled.
post #8 of 97
Thread Starter 

People can choose to not eat those things. We can avoid fake cheese by buying real cheese. We can avoid processed meat by buying plain meat. It is your choice. But cats can only eat what we give them. They can't avoid certain bad ingredients by favoring something else because the truth is there is nothing else. We have options. Cats do not.

post #9 of 97
Pet owners have as much choice over what they feed their pets as over what they feed themselves dontknow.gif. I just don't feel that pet food labeling is any more deceptive than human food labeling.
post #10 of 97
Thread Starter 
Quote:
Originally Posted by Willowy View Post

Pet owners have as much choice over what they feed their pets as over what they feed themselves. I just don't feel that pet food labeling is any more deceptive than human food labeling.

We have to agree to disagree on this one.

post #11 of 97
I guess. . .can you point out deceptive labeling? Or at least anything more deceptive than what's on a frozen pizza box? Or any lack of choice? If the labels are deceptive and I don't have a choice I'd like to know about it.
post #12 of 97
Quote:
Originally Posted by Willowy View Post

I guess. . .can you point out deceptive labeling? Or at least anything more deceptive than what's on a frozen pizza box? Or any lack of choice? If the labels are deceptive and I don't have a choice I'd like to know about it.

IMHO the current rules are very deceptive indeed.... Perfect example is the 95, 25 and 3% rule. I bet not many know about this.
Quote:
1. Pet Food Labels

Although AAFCO’s labeling requirements appear modest, the complexities of the rules, such as the different “percent” rules, often result in confusion over the product’s ingredients. Consider the “95 percent” rule and the “3 percent” rule. The “95 percent” rule applies to products that primarily consist of meat, poultry or fish.[121] The rule requires that if an ingredient is to be used in the name of the product, such as “Beef for Dogs” then the named ingredient must constitute at least 95% of the product.[122] Seems simple enough. Compare the “3 percent” rule; originally the 3 percent rule applied only to ingredients highlighted on the food container, but not included in the name of the product.[123] Under the “3 percent” rule if the manufacturer wished to include a side statement of “with cheese” then at least 3% of the product must contain cheese. However, recent amendments to AAFCO regulations now permit manufacturers to use “with” as part of the product name. The result? It is now perfectly legal for a manufacturer to name a product “Cat Food with Tuna” even if the product only contains 3% tuna. Even more confounding, this product sits on the grocery shelf next to a product named “Tuna Cat Food” which consists of 95% tuna.

After navigating the 95% rule and the 3% rules, the consumer then faces the perplexing 25% rule, or the “dinner” rule. A manufacturer wishing to include an ingredient name in its product name (i.e. “Chicken Formula Cat Food”) must comply with the 25% rule, which requires that the ingredient constitute at least 25% of the product (excluding water for processing) and that the label include a qualifying descriptive term such as “dinner” or “formula”.[124] The purpose of the descriptive term is to imply to the consumer that the product contains other ingredients.[125] Confusion arises due to the fact that the “named” ingredient on the label can constitute as little as one quarter of the ingredients. Moreover, such a rule permitting the product name to include something other than the primary ingredient results in a confusing ingredient list. It is perfectly plausible that a consumer will find that “Beef Dinner for Dogs” lists beef as the third or fourth ingredient on the list, after corn, grain, and rice.[126] The results are even more perplexing when one considers the fact that “Chicken Formula Cat Food” could contain salmon or beef or liver as its primary ingredient. Since many pet owners do not understand pet food labels,[127] this 25 percent rule can have damaging results if a pet has an allergy to any of these ingredients. For example, the owner of a cat with a lamb allergy could feasibly purchase Chicken Formula under the logical assumption that the product contained only chicken. But under AAFCO’s rules, it is permissible for a product labeled Chicken Formula to contain 25% chicken, and 50% lamb or beef or fish.

Past the product name, the consumer must decipher the nutritional adequacy statements found on labels indicating for which life stages the product is suitable. Examples include “for maintenance,” “for growth,” and “for all life stages.” While the “for maintenance” and “for growth” claims must meet strict nutritional AAFCO standards, the labels claiming that a product is intended for “senior” animals or specific breeds of dogs have no such requirements.[128] The result is that a consumer buying a dog food “for seniors” could be buying something that is either exactly the same formula as the “for maintenance” product at a higher price, or even worse, something that is of a lesser quality and actually accelerates the onset of related maladies such as arthritis and hip dysplasia.http://leda.law.harvard.edu/leda/data/784/Patrick06.html
post #13 of 97
Thread Starter 

Thank you Carolina. I knew somebody was better than me at proving pet food labels are extremely deceptive.

 

That is just the beginning of it. Don't forget the thread about chicken byproducts and chicken meal.

post #14 of 97
I'm still not seeing it as really deceptive. If people don't learn how to read a pet food label, it's like someone buying frozen pizza and expecting Totino's to have the same quality ingredients as the organic, artisan cheese, preservative-free pizza because both of them are called "pizza". The differences are obvious for those who care to look. The consumer's lack of education isn't really the FDA's problem.

I agree some clearer labeling would be nice. In percentages, how much meat, grains, veggies, etc. are in the food. But I don't think the current labels are deceptive. You can easily look something up if you want to. And it's true that certain definitions are vague (like trying to find out if "poultry by-products" are rendered or not), but try to find out exactly what's in "mechanically separated chicken"--same thing. I don't think we can expect more from pet food labels than from human food labels.
post #15 of 97
My basic point is: asking the FDA for greater clarity in pet food labeling is a great thing to do. But I think accusing them of deceptive labeling will make them ignore the letter.
post #16 of 97
Quote:
Originally Posted by Willowy View Post

You can easily look something up if you want to.
Really?
How much chicken is on Fancy Feast Grilled Chicken Feast in Gravy? Can you tell?

Chicken broth, chicken, liver, wheat gluten, meat by-products, corn starch-modified, artificial and natural flavors, salt, calcium phosphate, soy protein concentrate, added color, potassium chloride, taurine, magnesium sulfate, choline chloride, thiamine mononitrate, Vitamin E supplement, zinc sulfate, ferrous sulfate, niacin, calcium pantothenate, Vitamin A supplement, menadione sodium bisulfite complex (source of Vitamin K activity), copper sulfate, manganese sulfate, pyridoxine hydrochloride, riboflavin supplement, Vitamin B-12 supplement, biotin, folic acid, Vitamin D-3 supplement, potassium iodide.

9LivesTender Nibbles with REAL Chicken in Gravy

Water sufficient for processing, meat by-products, chicken, fish, wheat flour, soy protein concentrate, modified starch, steamed bone meal, animal digest, guar gum, titanium dioxide, sodium tripolyphosphate, potassium chloride, caramel color, choline chloride, salt, taurine, vitamins (vitamin E supplement, vitamin A supplement, thiamine mononitrate, niacin supplement, d-calcium pantothenate, riboflavin supplement, pyridoxine hydrochloride, menadione sodium bisulfite complex, vitamin D3 supplement, folic acid, biotin, vitamin B12 supplement), minerals (ferrous sulfate, zinc oxide, manganous oxide, copper sulfate, calcium iodate, sodium selenite), iron oxide.

Chicken is after meat by-products..... Is that not deceptive? How much Chicken is in there? Can you easily tell?
Edited by Carolina - 6/29/12 at 6:00pm
post #17 of 97
Can you tell how much chicken is in a chicken pot pie by the labeling? How much beef is in canned beef stew (or how much of the "beef" is soy protein)? Expecting higher standards for pet food than exist for human food is unrealistic.
post #18 of 97
Well, one thing I think we could expect would be to be able to tell whether or not the food could be marketed for people to eat or not. Whether a person would CHOOSE to eat it (because it contains "by-products") or not is a different issue. But does it include stuff that isn't safe for human consumption, or wouldn't be allowed for human consumption (whether ingredient-wise or due to the way the food ingredients are allowed to be handled and stored - e.g. treated for rodent feces and bugs or not)? Let's have a clear definition of "Human grade" ingredients, for example.

Also, and I don't have a reference for this, but I do believe it is actually not legal to list the carbohydrate content on the food label.

And yes, let's define how much protein comes from animal sources for our obligate carnivores.
post #19 of 97
Thread Starter 
Quote:
Originally Posted by Willowy View Post

My basic point is: asking the FDA for greater clarity in pet food labeling is a great thing to do. But I think accusing them of deceptive labeling will make them ignore the letter.

I am not accusing the FDA of deceptive labeling. I am complaining they allow pet food companies to create deceptive labels despite the fact it has a veterinary department. My point is if the FDA has any kind of responsibiliies regarding pet food, it should require pet food labels to have more transparancy. I know the FDA has some responsibility because it played a major role in the melamine recall five years ago.

post #20 of 97
Quote:
Originally Posted by Willowy View Post

Can you tell how much chicken is in a chicken pot pie by the labeling? How much beef is in canned beef stew (or how much of the "beef" is soy protein)? Expecting higher standards for pet food than exist for human food is unrealistic.
I can tell how much protein, how much Carbohydrates, how much sodium, how many calories, additives, soooo much more! The guaranteed analysis of the food I buy is for sure way more complete than the pet food I used to buy for my pets, that's for sure!
When carbs are such an issue for cats..... yep, IMHO it should be listed, you shouldn't need a calculator or an excel spreadsheet to calculate DMB dontknow.gif
post #21 of 97
Thread Starter 
Quote:
Originally Posted by Willowy View Post

Can you tell how much chicken is in a chicken pot pie by the labeling? How much beef is in canned beef stew (or how much of the "beef" is soy protein)? Expecting higher standards for pet food than exist for human food is unrealistic.

You are comparing apples and oranges, Willowy. The only thing we don't know by reading labels for our food is how much cholesterol is LDL. If they don't use real beef, they say that on the label.

 

Did you ever read LDG's thread about meal and byproducts? You will learn a lot on those four pages about how pet food labels are deceptive if you have not checked it out yet.

post #22 of 97
She was responding to Carolina's post. And Willowy participated in that thread. laughing02.gif
post #23 of 97
"Incomplete", sure, but I'm not willing to go with "deceptive". To me, "deceptive" would be calling Froot Loops "sugar-free". But if they say that a fortified cereal has "23 essential vitamins and minerals", that's perfectly true. If you decide not to serve your kid his veggies because his cereal has so many vitamins!, whose fault is that?
post #24 of 97
Quote:
Originally Posted by Willowy View Post

"Incomplete", sure, but I'm not willing to go with "deceptive". To me, "deceptive" would be calling Froot Loops "sugar-free". But if they say that a fortified cereal has "23 essential vitamins and minerals", that's perfectly true. If you decide not to serve your kid his veggies because his cereal has so many vitamins!, whose fault is that?
So, you don't think it is deceptive how the labeling and marketing of "Chicken Cat Food" "Chicken Formula Cat Food" "Chicken Dinner for Cats" and "Cat food with Chicken" when they are side by side on the shelves? You don't think the rules used in labeling/naming those foods are used in any way shape or form to confuse the consumer and sell food in a deceptive manner?
Let's remember that not everyone is on TCS..... And when those cans are on the same shelf, all with pretty darn similar name, the customer thinks they are buying cat food made of chicken.... All the while you have 95% chicken, 25% and 3% chicken in there. The rest is fillers.
Edited by Carolina - 6/29/12 at 6:49pm
post #25 of 97
Quote:
Originally Posted by Carolina View Post

So, you don't think it is deceptive how the labeling and marketing of "Chicken Cat Food" "Chicken Formula Cat Food" "Chicken Dinner for Cats" and "Cat food with Chicken" when they are side by side on the shelves? You don't think the rules used in labeling/naming those foods are used in any way shape or form to confuse the consumer and sell food in a deceptive manner?
All advertising/marketing is deceptive to a degree. Is there any fruit in "Fruity Pebbles"? How much fruit in "fruit drink" (which is right next to "fruit juice", which is a pretty similar situation to the "cat food with chicken"/"chicken cat food" thing)? Yes, the pet food situation is. . .icky. But the human food situation is not much better. You can't expect pet food to be held to a higher standard than human food.
post #26 of 97
Quote:
Originally Posted by Willowy View Post

All advertising/marketing is deceptive to a degree. Is there any fruit in "Fruity Pebbles"? How much fruit in "fruit drink" (which is right next to "fruit juice", which is a pretty similar situation to the "cat food with chicken"/"chicken cat food" thing)? Yes, the pet food situation is. . .icky. But the human food situation is not much better. You can't expect pet food to be held to a higher standard than human food.
The difference is, a person will not survive on fruit pebbles or fruit drink for life, eating it day in and day out, like cats do with cat food. That is a very big difference.
Pet parents unfortunately tend to feed a food long term, especially because of the "Balanced and Complete" label - which we know it's a whole other massive subject.....
It is an issue for cats..... Humans have variety - cats, the way the industry is, have a variety of junk. So being deceptive on a candy, or a juice that's consumed by a human once in a while might not pose a problem, but being deceptive in a pet food that is relied upon for nutrition exclusively - that can certainly be a major issue for pets.
post #27 of 97
Quote:
Originally Posted by Willowy View Post

I guess. . .can you point out deceptive labeling? Or at least anything more deceptive than what's on a frozen pizza box? Or any lack of choice? If the labels are deceptive and I don't have a choice I'd like to know about it.

 

I'm only talking about pet food here, without getting into deceptive human food labels, so please bear with me. rub.gif BTW, I agree about human food labeling practices.

 

An example of deceptive would be the amount of protein that is listed on a label. One might think this means the meat in the food, right? In reality it is a combination of the meat with grains, vegetables, and fruits--as grains, vegetables, and fruits contribute to both the carb and protein content of food. Cats are carnivores; our little meat-eating machines. rryumy.gif They derive little nutritional value from grains, vegetables, and fruits. I find this confounding that cat food in particular contains these ingredients all wrapped up with a pretty picture of real meat on the label. Pet food manufacturers are in it for the money, not the welfare of our kitties by providing bioavailable, digestible real meat protein in their foods. Sorry, just a wee little rant. smile.gif Buying a cat food without these ingredients can help.

 

Another thing they do is "ingredient splitting" e.g. brown rice, brewers rice, rice bran, etc. as fractions of the total grains listed on the label of a can or bag of food because this allows the practice of listing grains and other plant-based ingredients to be listed lower on the ingredient list. If you were to add all these up, they could, by weight, be more than the actual meat protein in a food--on a DM basis. Why do this? Why not just list their darn grains, etc. first instead of splitting them like this? Because a lot of cat guardians have gotten smarter and aren't going to buy a food with grains listed first.

 

Transparency in labeling for pets and humans should be the goal. Sadly, I don't see this happening anytime soon. Ya almost have to be a scientist to figure out all the crappy [deceptive] ingredient practices that are done to pull the wool over our eyes just to sell, sell, sell to a sometimes unknowing consumer.

 

Me? I'm just happy I've fed raw for a number of years. biggrin.gif


Edited by WhollyCat - 6/29/12 at 7:28pm
post #28 of 97
I kind of think it's more the fault of the AVMA or whoever likes to tell people not to feed their pets "table scraps" or meat. Not really the FDA's thing. Back when kibble first came out, I think most people gave their pets the meat trimmings. Of course, most people eat junk now, too, so their table scraps wouldn't be healthy.
post #29 of 97
Thread Starter 

OK, here is the run-up to my complaints about how commercial pet food is produced. Does it look accurate?

     I am not just complaining about toxins here, but toxins are part of the problem. Other problems with commercial pet food include the meat sources for carnivores and inclusion of plant foods cats can’t use. As the U.S. government’s food safety watchdog, the FDA needs to take responsibility for this and fix the problems detailed below.

     Problem #1: Dead, dying, downed, and diseased (4D) animals are rendered.

     Problem #2: Non-rendered meat is what did not pass human safety testing.

     Problem #3: Animal parts without much protein are used as protein sources.

     Problem #4: Obligate carnivores get most of their proteins from plant foods.

     Problem #5: Things like feces and dead cats find their way into some foods.

     Problem #6: Higher levels of toxins are allowed in pet foods than in our food.

post #30 of 97
Well, problem number one isn't worded right. If 4D animals are allowed in pet food at all, they HAVE to be rendered. I think the problem is that they're allowed in pet food. dontknow.gif
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