Guest Post! Originally posted by Susan Thixton on TruthAboutPetFood, October 17, 2015, and re-posted here with permission.
AAFCO’s Meetings on Human Grade and Feed Grade
This past week a pet food milestone was reached. Behind the scenes AAFCO held two meetings working to define what will be required of a pet food stating Human Grade on the label/website and what Feed Grade means. Consumer input is requested to share in future meetings.
This past week AAFCO held two online meetings for members of the Pet Food Committee and a special working group to define Human Grade claims on a pet food and to define what Feed Grade (and/or what ‘suitable for use in animal food’) means. Dr. Jean Hofve, Mollie Morrissette and myself were all participants at these meetings.
First, these meetings were something that we’ve been waiting on for a long time. A little more than a year ago, consumer advocates sent questions to FDA and to AAFCO asking both agencies to explain what feed grade is and/or explain in common language what ‘suitable for use in animal food’ means. As it turned out, neither FDA or AAFCO could explain the terms. A decades old, multi-billion dollar a year industry (pet food/animal feed) built solidly on the foundation of ‘feed grade’ ingredients had no legal definition for the term. It is unknown how or why – in the touted ‘highly regulated pet food industry’ – that no clear definition had not been developed in the past. But…finally arriving to a point to discuss/define these types of ingredients was reaching a milestone for consumers.
Also in discussion was an AAFCO legal definition for human grade claims on a pet food label. Earlier this year, FDA dropped (without warning) their program to verify human grade claims on pet food. The role of verifying human grade claims was put in State Department of Agriculture’s hands which meant that AAFCO needed to develop model bills (that will become state laws) to guide each state’s verification of the ‘human grade’ claims.
At this point in our discussions (more will happen in the near future), all members of the Pet Food Committee and the smaller working group seem to be in agreement for human grade claims. In general (in general is all I am allowed to share – cannot share specific information until the final definitions are made), for a pet food to state “human grade” on the pet food label or as extension to the label (this is important) for a pet food to state “human grade” on the pet food website – 100% of the ingredients (including all supplements) must be fit for human consumption AND all ingredients and finished product(s) must be stored, handled, processed and transported according to human food safety regulation.
Example: if a pet food uses USDA inspected and approved human grade meat, but uses feed grade (non-human grade) vitamin and mineral supplements – the pet food will not be allowed to make any reference to ‘human grade’ on the pet food label or on its website.
Example: if a pet food uses USDA inspected and approved human grade meat, human grade vitamin and mineral supplements, but manufactures the pet food in a pet food plant (non-approved human food plant) – the pet food will not be allowed to make any reference to ‘human grade’ on the pet food label or on its website.
Each requirement must be met in order to make the human grade claim (on the pet food label and on the pet food website)…
- Human grade ingredients
- Human food certified manufacturing facility
- All ingredients and finished product(s) must be stored, handled, processed and transported according to human food regulation.
Your thoughts on these proposed regulations are requested. Do you agree with, disagree with this proposed requirement for human grade claims? You can post in comments below or send to me (or Dr. Hofve or Mollie Morrissette) directly.
The definition for ‘Feed Grade’ proved to be not as simple to define (note: feed grade is also referred to as pet grade). Your three consumer advocates submitted – well in advance of this meeting – our suggested definition of ‘Feed Grade’. Our proposed definition was somehow ‘lost’ prior to the first meeting. We resubmitted our proposed definition prior to the second meeting, but there was no mention of it.
We submitted the following as definition of ‘Feed Grade’: “Material that does not meet the legal requirements of food, including but not limited to inedible and/or condemned foods, diseased animal material and/or material from animals that have died other than by slaughter, and adulterated human food contaminated by filth, industrial chemicals or drug residues* (*with CVM pre-approval).”
The definition for ‘Feed Grade’ that was discussed included the words “Material shall be safe” and “nutritious”. Dr. Hofve and I adamantly disagreed with ‘safe’ and ‘nutritious’ being included in the legal definition (Mollie would have too – she didn’t have microphone capabilities at the time of the call). The rendering industry adamantly defended their products as ‘safe’ and ‘nutritious’ even stating they have “science” to prove the safety and nutritional value of rendered dead and diseased animal tissues. We asked to see that ‘science’ and were told it was public information (strange…we’ve never found it in the past). The discussion could have turned very ugly, but the AAFCO moderator took control and asked me…”Susan, if this material is processed to destroy all pathogenic bacteria – would you agree it is then safe.” Wrong question to ask…
My response was an adamant “NO”. The question opened the door to discussing endotoxins and the scientific evidence proving their risk. (In case anyone missed it, Click Here to read about the dangers of endotoxins in pet food). Dr. Hofve joined in this discussion and we left them a bit tongue-tied – there was no denying it, endotoxins are a risk that has been ignored in pet food for far too long.
Within the ‘Feed Grade’ definition discussion, federal law (the Food, Drug and Cosmetic Act) and FDA Compliance Policies was also mentioned. An AAFCO representative had already compiled the FDA Compliance Policies in a document and shared with all in the meeting on our computer screens (thank you for this!). Again, it was a true struggle to claim “safe” and “nutritious” when you looking at the FDA Compliance Policies allowing “diseased animals” and “animals that have died otherwise than by slaughter” into pet food/animal feed. Dr. Hofve brought up a fantastic point in the meeting that “Poultry litter” (poultry feces) is an approved feed grade ingredient. (One more time…Safe? Nutritious?)
There was no agreement within the members of the working group to a definition of Feed Grade. We will meet again in two weeks.
Your thoughts on a proposed definition of Feed Grade are requested. What do you as a consumer need to understand about Feed Grade Ingredients that needs to be included in a definition? You can post in comments below or send to me (or Dr. Hofve or Mollie Morrissette) directly.
The good news is…we got this discussion to happen. This is truly a milestone for pet food consumers. Once these two terms are defined and become state law – pet food will fall soundly into one of two categories. Pet food will be human grade or feed grade. The goal is to tie up all loose ends in order to prevent misleading pet food labels and websites from inferring they are food grade/human grade when they are actually feed grade.
Please support your consumer advocates. All three of us (myself, Dr. Hofve, and Mollie Morrissette) work behind the scenes on a daily basis with FDA and AAFCO with hopes to change the regulations that govern pet food – making it easier for all pet food consumers to understand what they are buying for their pet. I am confident – that without our pushing and pushing of regulatory authorities – the meetings that happened this week would have never happened. We need pet food consumers’ support to continue this work.
Dr. Hofve’s website: http://www.littlebigcat.com/
Mollie Morrissette’s website: http://poisonedpets.com/
As these discussions continue, I will post more information (when allowed).
Wishing you and your pet(s) the best,
Susan Thixton
Pet Food Safety Advocate
Author Buyer Beware, Co-Author Dinner PAWsible
TruthaboutPetFood.com
Association for Truth in Pet Food
Tracy here.
This is a HUGE step forward, and well worth taking a moment to celebrate. But we have a lot more work ahead of us if our goal is safe, healthy manufactured pet foods, with transparent processing and labeling practices. Please follow Dr. Hofve, Mollie Morrissette and Susan Thixton on their websites and social media accounts. Respond to the questions Susan asked above; your input and visible support is critical! And if you have a few dollars you can spare, I encourage you to donate them to the Association for Truth in Pet Food.
Together we can, we ARE, and we will continue to make a difference.
