Dog guardians should knowwhat is in the foodthey are feeding their animals.
The dog food label contains a profusion of information...
yet consumers rarely read it.Much of this information is regulated... but you’ll need resistance to marketing gimmicks and "unqualified claims," which are not. Reputable manufacturers will have means for you to contact them, or you should ask the appropriate regulatory agency if you have questions. Continuing our discussion, on this page, we canvass what is actually written on the label, and offer guidance on interpreting that information to make informed purchase choices. (Read Page 1 of this essay HERE).
Food Safety Advocates are critical that, unlike any other non-durable product, consumers have no public access to definitions regarding pet food ingredients. The ingredients used in pet foods and treats each have their own specific definition written by and owned by AAFCO; through an agreement (a “Memorandum of Understanding”) between AAFCO and the FDA, consumers may only access information by purchasing the yearly AAFCO “Official Publication.”
Baxter: pensive thoughts...
PRODUCT NAME.Pet food manufacturers exploit that the product name may be a key factor in the consumer's decision to buy a product. Marketing teams use fanciful names or other techniques to emphasize a particular aspect of the product. Recognizing that many consumers purchase based on the presence of a specific ingredient, many product names incorporate the name of an ingredient to highlight its inclusion in the product. The percentages of named ingredients in the total product are dictated by four AAFCO rules: (“95%, 25%/Dinner, 3%/with,” and
The “95%” Rule. Applies to products consisting primarily of meat, poultry or fish; most often, canned products with simplistic names (“Salmon for Dogs”). At least 95% of the product must be the named ingredient (salmon, in this example), absent water added for processing and condiments. Counting the added water, the named ingredient still must comprise 70% of the product. Because ingredient lists must be declared in the proper order of predominance by weight, “salmon” should be the first ingredient listed, followed often by water, and subsequently other components or vitamins and mineral additives.
If the name includes a combination of ingredients, (“Salmon & Chicken Dog Food”), the two named ingredients together must comprise 95% of the total weight; the first ingredient of the product name must be the one of higher predominance in the product. A product could not be labeled “Salmon & Chicken Dog Food” if there is more chicken than salmon in the product. Because this rule only applies to ingredients of animal origin, ingredients that are not from a meat, poultry or fish source (such as grains and vegetables), cannot be used as a component of the 95% total. As such, a product named “Salmon & Rice Dog Food” would be misbranded unless the product was comprised of at least 95% salmon.
Esau: indefatigable... it seems
The “25%” or “Dinner” Rule.Applies to many canned and dry products. If the named ingredients (of the product name) comprise at least 25% of the product (absent the water added for processing), but less than 95%: the name must include a qualifying descriptive term, (such as “Dinner” as in “Salmon Dinner for Dogs” ). Counting the added water, the named ingredients still must comprise 10% of the product.
Many descriptions beyond “dinner” are used, however, (Platter, Entree, Nuggets and Formula are examples), some of which may impart an image of higher quality or quantity of ingredients. In the example “Salmon Dinner for Dogs,” only one-quarter of the product must be salmon; and salmon would likely be the 3rd or 4th element on the ingredient list.
Because the primary (largest percentage) ingredient is not always the named ingredient (in this example: salmon), and may in fact be an ingredient that you do not wish to feed, you should always check the ingredient list before choosing to buy. Cheaper or more currently available meats are commonly used (“Beef” dinners are often higher in tuna than beef itself), may be less palatable, or, may represent issues with food sensitivity.
If more than one ingredient is included in a “Dinner” name, the combination of the named ingredients must total 25% of the product and be listed in the same order as found on the ingredient list. Also, each named ingredient must be at least 3% of the total. Thereby: “Salmon & Beef Dinner Dog Food” must have 25% beef and fish combined; and at least 3% beef. Further, (unlike the “95% rule”), this tenet applies to all ingredients, whether of animal origin or not. So, a “Salmon & Rice Formula” or “Dinner for Dogs” would represent a suitable name provided there was more salmon in the product than rice (ordered by quantity), and the combined amounts of salmon and rice totaled 25%.
Bradley: shoreside sportsman
The “3%” or “With” Rule.Originally intended to apply only to ingredients highlighted on the principal display panel, but outside the product name, in order to allow manufacturers to highlight the presence of minor ingredients that were not added in sufficient quantity to merit a “Dinner” claim. For example: a “Duck Dinner,” with 25% duck, would be costly to produce (and therefore, unmarketable at certain price points); but either a “Salmon Dinner for Dogs” or “Salmon Formula Dog Food” could include a side burst “with duck” if at least 3% duck is added.
AAFCO model regulations now allow use of the term “with” as part of the product name, such as “Dog Food with Duck.” So now, even a minor change in the wording of the name has a powerful impact on the minimum amount of the named ingredient required; (a can of “Dog Food with Duck” could be confused with a can of “Duck Dog Food”, but, whereas the second example must contain at least 95% duck, the first needs only 3%. Then also, the term “duck” is open to some manipulation. As consumer, you must read labels carefully before purchase to ensure that the desired product is obtained.
Scout: the athletic outrider
The “Flavor” Rule. A specific percentage is not required, but a product must contain an amount sufficient to be detectable and adequate to “impart a distinctive characteristic” to the food.
Using animals trained to prefer specific flavors, as an explicit test method, can be used to confirm this claim. In the example of “Salmon Flavor Dog Food,” the word “flavor” must appear on the label in the same size, style and color as the word “salmon.” That ingredient may be salmon… but often it is a small amount of another substance that will furnish the characterizingflavor: such as grease, fish meal (likely, another less costly fish) or fishby-products(manufacturing debris retrieved from the parent company’s production lines of human foods).
To develop flavors—and pursue “least cost mix” protocols—dog foods commonly contain animal digests, which are materials (by-products and manufacturing waste) processed with heat (to stabilize rancidity), enzymes, and acids to form concentrated “natural flavors.” Only a small amount of a “salmon (fish) digest” is needed to produce a “Salmon Flavored Dog Food,” even though no actual salmon is added to the food. Stocks (grease) or broths may be added. Whey(milk plasma: the liquid remaining after milk has been coagulated and strained) is often used to add a “milk flavor.”
“No Artifical Flavors”
= No Consumer Information. Often labels will bear a claim of“no artificial flavors,” however, this term has little meaning, since artificial flavors are rarely used in dog foods, owing to inumerable ways to steer clear of that marketing stigma: rancid restaurant grease can provide the basis for natural meat flavorings. A lingering exception would be artificial smoke or bacon flavors, which are added to some treats.
NET QUANTITY STATEMENT. FDA regulations dictate the format, size and placement of the net quantity statement. This is important, since modern profit-driven manufacturing has caused many brands to creatively shrink packaging, leading consumers using visual cues to mistake quantities when comparing products. Cost-per-ounce comparison is especially important for dry products, which may differ greatly in density: a so-called specialized line of “lite” food may be merely an aerated (puffed up) product.
Oshkosh: observing, above the fray...
MANUFACTURERS'S NAME AND ADDRESS.The “manufactured by...” statement identifies the party responsible for the quality and safety of the product; and its location. Despite consumer perceptions, most dog foods are not made by (the Brand Name of the product), but by co-packers (outside contract manufacturers)—regardless that the product label may not state “manufactured for...”; (“distributed by...,” is a reasonable caption used by more forthcoming brands).
Co-packers are large industrial businesses that produce pet foods by agreement with the parent companies, as a generally recognized means to outsource manufacturing. Co-packers use global bulk-purchasing to leverage supply cost metrics, housing large stocks of ingredients. A single plant may make dozens of products under many different trade (brand) names, and which may enfold a broad range of goods: ranging from low-priced economy, to premium and expensive “all natural/holistic” brands. By contractual agreement, co-packers are expected to follow brand recipes, and use specified quality of ingredients.
Carlos: the sly one...
CO-PACKING ARRANGEMENTS as industry-standard business practice was not widely known by consumersuntil the pet food recalls of 2007; and is still generally misunderstood. Following the illness and death of thousands of dogs and cats, it was revealed that leading co-packer Menu Foods—through negligence at just two plants—was responsible for problems with pet foods across a broad spectrum of cost/quality labels. Over 90 brands of pet foods were recalled by Menu Foods alone. Among other issues, questions revolved around adequate standards for cleaning of equipment prior to “changing brands” on the factory line. As the scandal broadened, one leading “natural” brand, which recalled a third of its product line, terminated its contract with American Nutrition, insisting that the co-packer had “deliberately deceived” the parent company and “tampered with [its] intellectual property” (the recipe) by substituting cheaper ingredients, presumably, to pocket profits (known as economically motivated adulteration).
As part of a post-9/11 measure to protect the food supply, federal law requires food companies to be able to trace products one step forward and one step back (HR 3850, The FDA Amendment Act of 2007: FDAAA). This, however, may prove meaningless, owing to the industry’s complex and interrelated international networking, where supplies are purchased “at the moment,” based on continuously variable costs, with numerous opportunities for mischief, and beyond reach of US standards for oversight. Institutionalized problems with the integrity of supply-chain metrics, and the corruption of profit-hungry vendors that provide source ingredients to co-packers, leave the unwitting consumer at their mercy. Clearly revealed through the 2007 recalls was that even many “premium” brands had poor quality control in that they were not monitoring their co-packers, making certain that they used specified ingredients in the specified amounts, keeping accurate batch records, or ensuring that their products were kept separate from the other products in the plant(s).
in an address?Troubled by the reality of substantially un-monitored global supply networks, or the surprising concept of co-packing arrangements, consumers may be even more startled to realize that those co-packers themselves may not even be in the US at all; raising questions about the impossibility of oversight. How many labels have we actually read with any care? Perhaps too trustingly, we rely on one premium brand (highly Americanized name), in Agawam, MA, labeled: “healthy & natural,” “grain free,” with “no gluten” and “no by-products”... not noticing: “Product of Thailand.”
Tiba: eyes as windows to a gentle soul
INGREDIENTS LISTING. All ingredients are required to be listed in order of predominance by weight, under standards established by the Center for Veterinary Medicine for the FDA. Weights of ingredients are established as they are added in the formulation, including their inherent water content. Water content is important when evaluating relative quantity claims, particularly comparing ingredients.
As an example, a dog food may list “meat” (cattle, not poultry) as its first ingredient, and “corn” as the second ingredient. The manufacturer trumpets that a competing brand lists “corn” first (“meat meal” is second), suggesting the competitor's product has less animal-source protein than its own.
“First Ingredient” claims. However, meat is very high in moisture (approximately 75% water); whereas water and fat are removed from meat meal (a dry, lightweight powder: mostly protein and minerals), so it is only 10% moisture. This rendering process creates a concentrated protein product (a reason why dry foods appear high in protein). As a marketing protocol, it takes very little unprocessed beef to weigh more than this powder: so in reality the food in question is based on the protein meal, and in fact very little “meat” as the consumer perceives dog food. Understanding this, “first ingredient” claims should be ignored. If both products are compared on a dry matter basis (mathematically “remove” the water from both ingredients), it is clear that the second product had more animal-source protein from meat meal than the first product had from meat, even though the ingredient list (and the vendor) suggests otherwise.
Remember that “meat meal” “poultry meal” or “byproduct (waste) meals” are not fresh, but dry rendered ingredients, and we should not conclude that the second product has more “meat” than the first, (or in fact, any meat at all). Rendering (boiling) separates fat (used as an ingredient elsewhere), removes water, and kills bacteria, viruses, parasites, and other organisms. However, the high temperatures (270 - 300°) used can alter (denature) or destroy natural enzymes and proteins found in the raw ingredients, which can contribute to food intolerances and allergies, and inflammatory bowel disease in dogs. These problems are more common with dry foods, because the ingredients are cooked twice: first during rendering and again in an extruder; and the baking process—perhaps 500°—can further stimulate the formation of carcinogenic (cancer causing) compounds; (In production, all of the ingredients (meats, grains, vitamins, minerals) are mixed together and run through the extruder: the extruder cooks the mixture by adding steam and water, producing shapes familiar to consumers as “kibble,” and is subsequently dried. Fat is then sprayed on as a “palatant”).
Pippin: Flight test
Ingredients must be listed by their “common or usual” name with a corresponding definition in the AAFCO Official Publication. But consumers may have little understanding of industry-standard terminology, and it is fair to argue that use of that vocabulary favors that status-quo. For example, while there are chicken, turkey, and poultry by-product meals, there is no equivalent term for mammal “meat by-product meal”: it is called meat-and-bone-meal (MBM).
As we’ve discussed, MBM is a product of the rendering industry, primarily used to improve the amino acid profile of animal feeds (MBM is typically about 50% protein, 35% ash, 8-12% fat, and 4-7% moisture). Feeding of MBM to cattle is thought to have been responsible for the spread of Bovine spongiform encephalopathy (BSE, “mad cow disease”). In most parts of the world, MBM is no longer allowed in feed for ruminant animals (having a four compartment stomach, such as cows). However, in some areas, including the US, MBM is still used to feed monogastric animals (single stomach, such as dogs and pigs),
as a low-cost “meat” in pet foods.
Sonny: fabulously rugous style
Definitions... or not?
“Meat” itself (cattle, not poultry) is AAFCO defined as the “clean flesh derived from slaughtered mammals, and is limited to that part of the striate muscle which is skeletal or that which is found in the tongue, in the diaphragm, in the heart, or in the esophagus; with or without the accompanying and overlying fat and the portions of the skin, sinew, nerve, and blood vessels which normally accompany the flesh.” But while the AAFCO definition of meat by-products begins with the term “non-rendered,” in the same sentence it is contradictorily defined to include “partially defatted low temperature fatty tissue.” However, “meat meal” is defined as “the rendered product from mammal tissues, exclusive of any added blood, hair, horn, hide trimmings, manure, stomach and rumen contents.”Thus, in addition to the effects of processing and additives, it could also contain parts of animals one would not think of as “meat,” and contain more minerals than meat. Although a dog does not hold aesthetic concerns about the source and composition of his food, his guardian may make choices based on inaccurate or confused perception. The distinction must be made in the ingredient list (and in the product name), and for this reason, a product containing “salmon (fish) meal” cannot be named a “Salmon Dinner,” because it would not meet the expected 25% threshold.
Further down the ingredient list, the common or usual names become less common or usual to most consumers. The majority of ingredients with chemical-sounding names are, in fact, vitamins, minerals, or other nutrients; others may include artificial colors, stabilizers, and preservatives (remembering how meaningless the term “natural” can be). Although all should be Generally Recognized as Safe (GRAS) or approved additives for their intended uses, as a consumer, you should question the reasoning and safety of their presence.
Emma: floating on panache
It's Not Safe... Then it Is... The FDA’s Center for Veterinary Medicine (CVM) can act to prohibit or modify use of an ingredient or additive in dog food if scientific data are presented that reveal a health risk. For example, propylene glycol was used as a humectant (stabilizer and texturing agent) in soft-moist pet foods, having been affirmed GRAS for use in human and animal food before the advent of soft-moist foods themselves. Although well known that propylene glycol caused Heinz Body formation (protein accumulation) in the red blood cells of cats, it could not be shown to cause overt anemia (reduction in the amount of red blood cells/hemoglobin) or
other clinical effects.
However, reports in the veterinary literature of scientifically sound studies have since shown that propylene glycol reduces red blood cell survival time, and renders red blood cells susceptible to oxidative damage. In light of this data, CVM amended the regulations to prohibit the use of propylene glycol in cat foods. It is still, however, common in dog foods, particularly dry formulations. It is also used in antifreeze, hydraulic fluids, and as an industrial solvent.
Games. You should be wary of the means used by manufacturers to disguise less desirable ingredients. Corn and wheat are especially common in dog foods—often, the main ingredient—as a base, and as a cheap protein source. Breaking a major ingredient into several different smaller ingredients (ground yellow corn, corn bran, grits, or middlings; corn gluten or corn gluten meal, corn germ meal, corn cellulose) and listing them individually is used to push these undesirable components farther down the ingredient list, where they might appear to be more minor additives. Conversely, consumers should also recognize that the presence of fruits and certain vegetables in premium brands is often based on marketing appeal (or the need for starch as a binding agent), since many of these ingredients don’t provide significant health benefit, the quantities are small, and are commonly rejected from human food processing.
Skeeter: K-9 liftoff... (no countdown!)
IS:NOT A GUARANTEE. The “Guaranteed Analysis” statement found on pet food labels was created nearly a century ago when some manufacturers used undesirables like sand or lime-stone to add weight to their pet food. Today, at minimum, many state regulations require a dog food to guarantee the minimum percentages of crude protein and crude fat, and the maximum percentages of crude fiber and moisture.
“Crude” measurements, however, only indicate the amounts of nutrients present based on certain analytical methods. As an example: the method for measuring protein does not measure protein: it measures the nitrogen content and compensates for the amount of nitrogen in an average protein (this was the situation that created the pet food recalls of 2007; when Chinese suppliers substituted melamine—67% nitrogen—to surreptitiously meet contract standards for “protein”). Crude protein does not indicate quality of the nutrient, and can be deceiving, since it is not indicative of its bioavailability (total protein digestibility) to the dog.
Some manufacturers include guarantees for other nutrients as well; maximum percentage of ash (the cumulative mineral component: ordinarily, bone content and mineral additives) may be captioned, as may be minimum percentage levels of calcium, phosphorus, sodium, and linoleic acid.
Guarantees are declared on an “as fed” or “as is” basis, or, the amounts present in the product as it is found in the can or bag. This may not appear to bear when guarantees of two products of similar moisture content are compared (example: two dry dog foods). However, when comparing guaranteed analyses between dry and canned products, it may be confusing, that levels of crude protein and other nutrients are much lower for the canned product. This is because of the relative moisture content: canned foods typically contain 75-78% moisture, whereas dry foods contain only 10-12% moisture. So, a canned food containing 10% protein actually has much more protein than a dry food with 30% protein. Meaningful comparisons should be expressed by converting the guarantees for both products to a
moisture-free or dry matter basis.
Ozzy: the very nearly "Invisible Man"
How to Properly Calculate
and Compare Wet vs. Dry Foods.
The dry matter percentage of the product is 100% minus the percentage of moisture guaranteed on the label. To convert a nutrient guarantee to a dry matter basis, the percentage guarantee should be divided by the percentage of the dry matter, then multiplied by 100. Example: a canned food guarantees 8% crude protein and 75% moisture (or 25% dry matter); while a dry food contains 27% crude protein and 10% moisture (or 90% dry matter).
Which has more protein, the dry or canned?Calculating the dry matter protein of both: the canned contains 32% crude protein on a dry matter basis (8/25 X 100 = 32), while the dry has only 30% on a dry matter basis (27/90 X 100 = 30). Thus, although it looks like the dry has a lot more protein, when the water is counted out, the canned actually has more.
It is especially important to look at the moisture guarantee for canned foods: AAFCO regulations stipulate the maximum percentage moisture content for a pet food is 78%, excepting products labeled as a “stew,” “in sauce,” “in gravy,” or similar terms. The water imparts qualities for appropriate texture and fluidity. Some of these exempted products have been found to contain as much as 87.5% moisture. That extra water may not appear significant: until the dry matter contents are compared. Example: a product with a guarantee of 87.5% moisture contains 12.5% dry matter; only half as much as a product with a 75% moisture guarantee (25% dry matter).
Consumers should also be wary of how these levels are realized. Example: the amount of protein is not reflective of its worth: it is a protein’s digestibility and its biological value that are important. Protein can come from just about anywhere: often, from non-nutritious sources like by-products (leather, hair, feathers, chicken beaks, “poultry litter,” and other manufacturing debris), or that enigmatic meat substitute… gluten. Gluten is what remains from grains (wheat, corn or rice) after the all of the starchy carbohydrate is washed out. This rubbery protein residue can be considered as a sort of vegetable-based protein concentrate.
Within protocols for “least cost mix” manufacturing, glutens represent an appealing means to cheaply boost claimed protein levels: the parent company may integrate glutens into its recipe in order to position its product at a certain price point. However, in the instance of the 2007 pet food recalls, it was discovered that unscrupulous suppliers to co-packers had gone even further, substituting melamine (an organic base and trimer of cyanide, used in manufacture of plastics) to meet the stipulated levels within their contracts.
Shadow: ever the gentleman...
NUTRITIONAL ADEQUACY STATEMENT. Any claim that a product is “complete,” “balanced,” “100% nutritious,” or that suggests a product is suitable for sole nourishment when it is not, in fact, nutritionally adequate for such purpose is a potentially unsafe product, and is misbranded.
A “complete and balanced” pet food must be substantiated for nutritional adequacy by one of two means. The first is for the food to contain ingredients formulated to provide levels of nutrients that meet established AAFCO profile, and may be captioned as: “(Product Name) is formulated to meet the nutritional levels established by the AAFCO Dog Food Nutrient Profiles.” The alternative is for the product (or the “lead” member of a “family” of products) to be tested using the AAFCO Feeding Trial Protocol(s). Such products may bear the statement: “Animal feeding tests using AAFCO procedures substantiate that (Product Name) provides complete and balanced nutrition” to meet the needs of a healthy dog, at the specified life stage. A product labeled as a “snack” or “treat” is not required to bear a nutritional adequacy statement. However, unless a product that does not meet either of the 2 methods is conspicuously labeled as a “snack,” “treat,” or “supplement,” it must state “this product is intended for intermittent or supplemental feeding only.”
FEEDING DIRECTIONS. Feeding directions instruct the consumer on how much product should be offered to the dog. Minimum-ally, they should include verbiage such as “feed (X) cups per (X) pounds of body weight daily,” and logically, are a spare guideline, (and many cases, properly be seen as encouraging overfeeding), since breed, activity level, physiological factors, and environment should be incorporated into the decision. Exceptions for puppies or nursing mothers are typically added.
Paco: "I know... I just hide here!"
CALORIES STATEMENT. Not required for AAFCO approval. The American Veterinary Medical Association voiced support for mandatory calorie content statements on dog foods and proposed requirement of a “not evaluated by FDA” disclaimer on pet foods bearing health-related claims. Dog foods can vary greatly in calorie content, even among foods of the same type (dry or canned), or “formulated” for the same life stage. Manufacturer directions also vary, so the number of calories delivered in a daily meal of one (similar) food may be quite different from another. The best way for you to compare
products and determine how much to be
fed is to know the calorie content.
The number of calories in a product roughly relates to the amount of fat, although varying levels of non-calorie-containing components, such as water and fiber, can manipulate this correlation. “Diet” or specialized “indoor” and “senior” animal formulations are commonly ordinary recipies that are reconfigured to have higher levels of indigestible fiber added to “take the place” of calories in a given quantity of food. The fiber is often wood pulp (sawdust) but labeled "cellulose." Extending a food in this way would necessitate altering additives, so that the nutrient profile remained constant across the new, less calorie-dense recipie; and the guardian should rightly question what the implications of those changes may be.
In reality, many diet formulations are created not as healthful alternatives but as market niche products. Reduced calorie claims are related only to a manufacturer's own product lines: labeled as “Diet” or “Lite” formulas, they in fact may be higher in calorie content than other, so-called standard or “regular” foods from other manufacturers. Consumers, however, rarely understand this distinction.
If a voluntary calorie statement is made on the label, it must be expressed on a “kilocalories per kilogram” basis. Kilocalories are the same as the calories you see on your own food labels; a kilogram is a unit of metric measurement equal to 2.2 pounds. Manufacturers may also express calories in familiar household units (example: “per cup”). Even without this additional information, however, you can make meaningful comparisons between products and pick the product best suited for your dog's needs. As for “guaranteed analysis,” the calorie statement is made on an “as fed” basis, corrections for moisture content should be made, as we describe above. But to roughly compare the caloric content values between a canned and a dry food, you can multiply the value for the canned food by 4.
Comet: the beach rocket
ABOUT “QUALITY” Many pet foods are labeled as “premium,” and even “super” or “ultra premium”; others flaunted as “gourmet” items. The FDA has no standards to protect consumers from misleading unqualified claims of superiority using such expressions, and you must be especially vigilant when considering the purchase of high-end dog food. Although it may be generally true that more expensive foods are made with higher quality ingredients, such terms have no AAFCO designations and products labeled this way are not required to contain any different or higher quality ingredients; nor are they held up to any higher nutritional standards for AAFCO labeling compliance.
The term “natural” is often used on dog food labels, although it has no official definition, and can be substantially meaningless. Per AAFCO stipulation, “natural” only means an ingredient that is not subject to a
chemically synthetic process.
For a low-quality dog food, a statement “has everything needed for a healthy skin and shiny coat” requires no scientific substantiation. It is a structure-function claim governed by the Dietary Supplement Health and Education Act (DSHEA) of 1994. This act required the FDA to permit claims that foods “help,” “maintain,” and “support” body structure or functions, so that dietary supplements were allowed greater leeway in making health claims. As such, structure-function claims are generally left to the discretion of manufacturers.
The AAFCO has developed a feed term definition for what types of ingredients can be considered “natural,” and “Guidelines for Natural Claims” for pet foods. Those categories marketed as “holistic,” “ultra healthy,” and “premium” often emphasize the use of “human-grade” meat sources only, without meat by-products. Similarly, AAFCO has no official definition of this term, and wrote to pet food manufacturers in 2004, advising that using it is “false and misleading.” It is important to note that, AAFCO only governs its own approval for the dog food packaging itself, and has no authority over websites or advertising. Also, the growing awareness of the realities of pet food manufacture subsequent to the 2007 recalls has led vendors to misuse the term “human-grade” without revealing that while indeed intended for human consumption, ingredients may in fact be rotted, moldy, and vermin infested salvage of “human grade” warehouses.
Blaze: luminous... pure sunshine
ARTIFICIAL INGREDIENTS. Basically, there are three kinds of artificial ingredients: 1) artificial flavoring, 2) artificial coloring, and 3) artificial preservatives. Artificial flavoring is rarely used to make dog food. Artificial colors are added to dog foods soley as a marketing decision: so that the food can mimic the appearance of “quality” ingredients and thus appeal to consumer expectations. Most commonly, they are used to color ingredients so that they have the appearance of meat. Another example is colored “textured vegetable product” (TVP) formed to look like meat. Preservatives can be either natural… or artificial.
Natural preservatives are usually made from anti-oxidants… like vitamins C or E. You’ll see them printed on a dog food’s ingredients list using some form of the word “tocopherol” or “ascorbate” (example: “…chicken fat preserved with alpha-tocopherol”).
Artificial preservatives are mcuh different, adding a notable risk of toxicity to any dog food. Consumers should question the presence of these additives. An example: the humecant (moisture preservative) propylene glycol is a common (cost effective) preservative in dry foods. You may recognize propylene glycol by its use in certain types of non-automotive anti-freeze. Due to its proven risk of blood toxicity, propylene glycol has been banned by the FDA for use in cat food. It seems fair to question that it is still used as an artificial preservative in dog food. Another conventional dog food preservative, ethoxyquin, is used as an industrial pesticide, and as a hardening agent in the manufacture of synthetic rubber. The World Health Organization openly names both butylated hydroxyanisole (BHA) and butylated hydroxytoluene (BHT) as probable carcinogens (cancer-causing compounds). Fat and oil preservatives added to dog foods to increase shelf life include tertiary butylhydroquinone (TBHQ)… but also used to stabilize certain explosive compounds… and to make varnishes, lacquers and resins. Butylated hydroxytoluene (BHT) can also be found in cosmetics, pharmaceuticals, jet fuels, rubber, petroleum products, electrical transformer oil and embalming fluid.
Many dog guardians serve up these chemicals at every meal over their dog’s lifetime.
Griffy: furrowed concentration
FINAL THOUGHTS. The pet food industry is gearing up to meet the requirements of newly passed (January 2011) Food Safety and Modernization Act (FSMA), which grants the FDA broader authority to regulate and supervise the growing and production of food. It is considered the first major piece of federal legislation addressing food safety since 1938, and was prompted by a number of food contamination cases in the 2000s. Expected to influence the general environment is the growing criticsm the FDA has endured owing to its perceived lack of focus as it investigates illness and death of dogs from imported chicken jerky treats. In February of 2013, FDA abruptly released its inspection report of Kasel Associated Industries Denver, CO plant and warned the company that it would invoke its new mandatory recall authority: Food Safety Advocates suggested this was a a defensive reaction to that withering appraisal.
Through this new jurisdiction, FSMA imparts to the FDA authority to recall food in the case of contamination or illness. (subsequent to a Prehearing Order to Cease Distribution and Give Notice, or a “423(a)” oe “last chance” letter). Additionally, farms will be required to track their food and implement strategy to deal with recalls or outbreaks of disease, and give FDA officials access to their records in this instance. The bill will also require food importers to verify that they meet US food safety standards. Small farms that sell locally or sell less than $500,000 a year are exempt from these new rules. Also exempt: facilities that produce food solely for non-human animals.
The Petfood Forum and Petfood Workshop is held annually. According to a press release in 2011 from Pet Food Industry Magazine (WATT Publishing: Mount Morris, IL; an affiliate member of The Pet Food Institute): “This leading industry event offers more expert content and networking than ever—plus, learn about new safety requirements during Petfood Workshop.” Also: “This seminar will help you understand and prepare for the new US food safety regulations by bringing you face-to-face with experts on: How to prepare for—and survive—an FDA inspection; (and) Creating and improving a HACCP program.”
Interestingly, WATT Publishing, after consulting with its “owners, advisors, and business partners,” about “what kind of risk does it pose” has refused to allow the press, representatives of consumer groups, or the public access to the annual conference, (even as $US1,700 paid attendees), stating that: “they” (the manufacturers, ingredient suppliers, and importers) “are very protected.” So while consumers support the industry (US$18.28 million in 2009, in the US), the industry is reluctant to reveal to consumers what goes on inside, where exhibitors at the Forum will speak about what buyers of their products are feeding their dogs (and cats).
Libby: challenging all, "catch me if you can!"
ENDNOTES:  The three major co-packers in North America are: American Nutrition (Ogden, Utah), Evangers (Wheeling, IL), and Menu Foods (Pennsauken, NJ).
Reports indicate that Menu Foods, which had been producing 95 brands, received word of a possible contamination with some of its products as early as December of 2006. The company, however, did not acknowledge receiving the first complaints of sick pets until February 20, 2007.
On February 26 and 27, the Chief Financial Officer of Menu Foods, Mark Wiens, sold approximately half of his Menu Foods stock, referring to that timing as a “coincidence.” On February 27, 2007, the company began internal testing of its food, which it later described for press inquiries as ordinary “taste testing,” denying that it was owing to rising complaints. When the test animals began dying, the company began investigating possible problems on March 2, 2007; and on March 16, 2007, issued a US nation-wide recall for dog and cat foods produced at two of its facilities between December 3, 2006, and March 6, 2007.
The poisoned product was imported by ChemNutra Inc. (Summerlin, NV) into the US and purchased by Menu Foods (brands from: Hill’s Pet Nutrition, Mars, Inc., Nestlé Purina PetCare Co., Royal Canin, The Iams Co. and Procter & Gamble). Known through advertising as “The China-Source Experts,” ChemNutra imports ingredients for pet food, animal feed and pharmaceuticals from China for North American manufacturers.
In 2008, a US federal grand jury indicted ChemNutra Inc. and its owners and its owners, Sally Qing Miller, 43, and Stephen S. Miller, 57, of Las Vegas, NV. In 2009 the Millers and the company pleaded guilty to one count each of distributing adulterated food and selling misbranded food: Class A misdemeanors. The Millers were each fined $5,000 and given three years probation in U.S. District Court in Kansas City, MO; ChemNutra was fined $25,000. In addition to ChemNutra and the Millers, two Chinese companies and their leaders — Xuzhou Anying Biologic Technology Development Co., Ltd., and Mao Linzhun; and Suzhou Textiles, Silk, Light Industrial Products, Arts and Crafts I/E Co., Ltd. and Chen Zhen Hao — were indicted in the US. However, federal prosecutors were not able to proceed, as the US does not have an extradition treaty with China. More than 100 class-action suits arose out of the incident, against defendants Menu Foods, Nestlé Purina PetCare Co., Wal-Mart, PETCO and others. Menu Foods was accused of fraud for delaying notification to consumers for months (see above). Those cases were consolidated and addressed by a $24 million settlement in 2008: reduced to a $12.4M distribution to claimants. Menu Foods was bought out by Simmons Pet Food
in August, 2010.
Llazlo: piercing... mysterious... serene
 A ruminant is a mammal (example: cattle) that has a four-compartment stomach, differing from monogastrics, (examples: people, dogs, and pigs), who have a single-compartment stomach.
A ruminant digests plant-based food by initially softening it within its first stomach, then regurgitating the semi-digested mass, cud, and chewing it again. Ruminating is the process of re-chewing the cud to further break down plant matter and stimulate digestion. In the first two chambers, the rumen and the reticulum, the food is mixed with saliva and separates into layers of solid and liquid material; solids clump forming the cud, the cud is regurgitated, chewed slowly to completely mix it with saliva, breaking down the particle size. Fiber, especially cellulose (sawdust) is primarily broken down into the three volatile fatty acids (ethanoic, propanoic, and 3-hydroxy butanoic) by microbes of bacteria and fungi; protein and unstructured carbohydrates are fermeted. The degraded digesta, (now in the lower liquid part of the reticulorumen), then passes into the next chamber, the omasum, where water and inorganic mineral elements are absorbed into the blood stream. It then is moved to the true stomach, the abomasum, (the equivalent of the monogastric stomach), where it is digested here in a similar way. Finally, digesta is moved into the small intestine, where the digestion and absorption of nutrients occurs.
 By-products are ground, rendered, and cleaned slaughtered meat carcass parts such as necks, feet, undeveloped eggs, unborn fetuses, bones, heads, and intestines (and a small amount of feathers in the case of chicken). “The AAFCO definition for Meat by-products: “The non-rendered, clean parts, other than meat, derived from slaughtered mammals. It includes, but is not limited to, lungs, spleen, kidneys, brain, livers, blood, bone, partially defatted low temperature fatty tissue, and stomachs and intestines freed of their contents. It does not include hair, horns, teeth and hoofs. It shall be suitable for use in animal food. If it bears name descriptive of its kind, it must correspond thereto.”
 Normal redox regards the biological system's ability to readily detoxify reactive intermediates or to repair the resulting damage. Disorder in the normal redox state of tissues can cause toxic effects through the production of peroxides and free radicals that damage all components of the cell, including proteins, lipids, and DNA.
 Marion Nestle, Pet Food Politics (The Chihuahua in the Coal Mine), 163, Univ. of CA Press, 2008.
N.B.: This essay is written for informational—not instructional— purposes.
Our goal is to build awareness of concepts and define common terminology to stimulate creative thinking, so that you may effectively conduct your own research. We draw your attention to concepts, issues or authors that are or may be important to the subject at hand, but do not consider that our interpretation is necessarily complete. This essay is by nature, narrowly focused: there are numerous scholarly books on this topic which we would encourage you to seek out. We would welcome your comments or suggestions! We are not medically trained, nor legal experts. Among the most important things a pet guardian may do in his dog's lifetime, is work to build an understanding of canine nutrition, pet food manufacture and the basics of pet food labeling. We encourage you to discuss this topic in detail with your veterinarian, and to be aware that certain medical conditions would not include high-protein diets as part of generally accepted treatment/management protocols. Be aware that an "all meat" diet (used by some guardians to avoid commercially made foods) is not nutritionally/medically complete for your dog. Links are in blue & will illuminate when you pass your mouse over them: click to be directed to a site.
“She is patient. How she waits for me. She waits as I duck into the local
grocery store: looking plaintively, then settling down. She waits at home, warming the bed, the chair, the spot
by the door, for me to return. She waits for me to finish up what
I'm doing before we go outside; for me to finish talking with someone during our walk; for me to figure out when she is hungry.
She waited for me to finally realize where
she liked to be rubbed. And for me to finally begin
to figure her out.
Thanks for waiting, kiddo.” —Alexandra Horowitz, (Inside of a Dog)
You can brighten the long, lonely day of a needy dog:consider volunteering at a shelter. Your used but servicable linens, towels, bathmats, or cushions can provide comfort while he waits. Need help affording veterinary care? click HERE • Find low-cost spay neuter services: click HERE
Food & Safety Recalls/FDA Advisories for Dog Foods: click HERE
To think about: American taxpayers spend more than $1 billion annually to fund municipal animal shelters.
In those facilities, 14,000 animals are killed each day, often brutally: even in archaic gas chambers...
many within merely hours of their arrival: why are they called shelters?