Dog food manufacturers have devoted extensive research to induce dogs to eat things
that they would normally never touch.
Agribusiness scientists and corporate marketing teams know that it's possible to take a mixture of inedible food oddments and manufacturing debris (including textured vegetable product—TVP—formed and dyed to look like meat), "fortify" it with baked artificial vitamins and minerals, preserve it with very nearly toxic chemicals so that it can sit on the shelf for years, extrude it into fanciful shapes that appeal to the human consumer, and finally... spray it with “palatants” (animal digest: hydrolized waste grease or oils) to imitate the smell or taste of meat. Modern, profit-driven manufacturers have found means to make the term “no artificial…” virtually meaningless. Packaging—even if it is illusory—is paramount. After all… its proven effective by massive profit figures;
The competitive landscape of US pet food manufacturing industry includes about 200 global companies with combined annual revenues exceeding $20 billion. Major companies include divisions of Nestlé (Nestlé Purina), Procter & Gamble, Colgate-Palmolive, Mars, and Del Monte. Of approximately 200 US businesses, the industry is highly concentrated: the 50 largest companies hold nearly 100% of the market. Profitability is heavily dependent on effective marketing and economies of scale in manufacturing, marketing, and distribution, with major players spending millions annually to maintain share. In late 2013, Del Monte sold its consumer products division to concentrate solely on it's biggest business: pet foods, and will re-name itself in 2014 to reflect this focus. Capital-intensive, market researchers estimate average annual revenue per employee at nearly $850,000. As consolidation continues, consumers are often increasingly unalert to who parent companies actually are and confidence in brand integrity is waning.
Although consumers are generally unaware of the practice, pet food manufacturing is a highly automated process that supports “co-packing” arrangements though which the “manufacturer” outsources the production and packaging of products that bear its brand label, and over which they exercise astonishingly meager oversight.
Chestnut: targeting a low-flying gull...
(LACK OF) REGULATION OF DOG FOOD Agribusiness lobbyists insist that the pet food industry is more highly regulated than for human food; but that’s simply not true. Pet food exists in somewhat of a regulatory vacuum: laws are “on the books,” but enforcement is uneven, and given the horrific events of the 2007 recalls, many would argue, virtually meaningless. In the US, the Food & Drug Administration (FDA), the US Department of Agriculture (USDA), and the Federal Trade Commission (FTC) regulate manufacture and labeling of dog food at the federal level; with further regulation conducted at the state level. Food & Drug Administration.The FDA is an agency of the US Department of Health and Human Services, one of the US federal executive departments. Within its broad purview, the FDA is charged to establish and administer (enforce) regulations intended to ensure that dog foods are safe to eat, produced under sanitary conditions, contain no harmful substances, and are truthfully labeled. Manufacturing plants are subject to FDA inspection, generally with notice. In addition, canned pet foods must be processed in conformance with the Low Acid Canned Food Regulations (LACF) to ensure the pet food is free of viable microorganisms, (and evidenced by filing of acceptable processing methods; Code of Federal Regulations:[CFR] Title 21, Part 113).
Many ingredients such as meat, poultry and grains are deemed reliable owing to their “long history of safe use in foods” and do not require pre-market approval. These and other substances, such as sourced minerals, vitamins or other nutrients, flavorings and preservatives, or processing aids, may be generally recognized as safe (GRAS) for their intended use (Title 21 CFR 582 & 584). Food additives must have approval based on “scientific evidence” supporting their safety and utility (Title 21 CFR 570, 571 & 573). Colorings (and their quantities) must have approval as specified for a particular use (Title 21 CFR Part 70, and be listed in Parts 73, 74, or 81).
Bodie: the little torpedo, takes momentary pause
Current FDA labeling regulations for all animal feeds (Title 21, CFR 501) require proper identification of the product, net quantity statement (weight, volume, or count), name and place of business of the manufacturer or distributor, and a proper listing of all the ingredients in the product in descending order from most to least, based on weight.
Through its Center for Veterinary Medicine (CVM) branch, the FDA must approve foods containing drugs, and evaluates claims for therapeutic benefit on pet food (“maintains health of urinary tract,” “low magnesium,” “reduces plaque and tartar,” “reduces hairballs in cats,” “improved digestibility,” etc.).
There is no requirement that dog food products earn pre-market FDA approval; however, violations can result in offical requests for voluntary compliance, manufacturer fines, removal of a product from the market, and product seizure, pursuant to enforcement of the Federal Food, Drug and Cosmetic Act (manufacturing), and the Fair Packaging and Labeling Act (sale). The Food Safety Modernization Act (FSMA: January 2011) imparted the FDA authority to invoke mandatory recall authority, generally preceded by issuance of a “last chance” letter (a FSMA required formality, called a Prehearing Order to Cease Distribution and Give Notice,
or a “423(a)” letter).
Federal Food, Drug and Cosmetic Act.The Federal Food, Drug, and Cosmetic Act (FFDCA) enfolds requirements for both human and animal foodstuffs, and requires that pet foods be pure (uncontaminated) and wholesome, contain no harmful or toxic/lethal substances, and be honestly (truthfully) labeled. The FFDCA delineates that a food may be deemed to be adulterated if it contains poisonous or deleterious (harmful) substances which may cause it to be it injurious to health; if it has been prepared, packed, or held under unsanitary conditions through which it may have been contaminated with soil or debris or rendered injurious to health; if it contains any part or product of a diseased animal; or if its container is composed of any poisonous or harmful material which may render its contents injurious to health. It may also be contaminated if any important ingredient has been omitted or substituted.
Casey: cheer that is invulnerable to the icy cold
Pursuant to the FFDCA, dog food may be considered misbranded (untruthfully labeled) if it •1) contains any statement on the label which is false or misleading;
•2) does not contain a statement of ingredients; does not show the name of the food and correct identification of it as a dog food; •3) does not contain the net weight; or •4) fails to state the name and address of the manufacturer, packer, or distributor. The ingredients must be listed in descending order of predominance by weight, and identified by their common or usual names. The label must list any artificial flavoring, artificial coloring, or chemical preservative. If the food is to be used only under certain conditions, or only with other foods, this must be stated on the label, along with any other necessary information.
Fair Packaging and Labeling Act. The Fair Packaging and Labeling Act (FPLA) contains additional regulations designed to prevent unfair or deceptive packaging and labeling, and to help make it possible for consumers to make value comparisons between products. Federal regulations concerning the labeling of pet food are published inTitle 21 CFR, part 501.
United States Department of Agriculture.The(USDA) is the federal executive department responsible for developing and executing U.S. federal government policy on farming, agriculture, and food. In its charge to protect food safety, the USDA is concerned with regulations regarding dog food labeling, including identification and sanction of ingredients. USDA regulations also afford for voluntary inspection of canned pet foods. These voluntary inspection regulations specify the amount of meat ingredients which must be used in the product, along with minimum nutrient requirements and label specifications. Manufacturers that undergo this inspection may apply an inspection seal to the label. This option is not widely used.
Ozzie: a contemplative moment
Federal Trade Commission. The Federal Trade Commission (FTC), an independent agency, promotes consumer protection and works to prevent prevention of what regulators perceive to be harmfully anti-competitive business practices, including misleading advertising, and as such, dog food manufacturers must conform to the FTC's general truth in advertising standards.
REGULATION OF DOG FOOD
AT THE STATE LEVEL
The FDA has nominal authority over pet foods shipped across state lines, which is held by State feed control officials. Every state can have its own Feed Control Laws and Regulations, which regulate distribution of pet foods everywhere within a state; (in Connecticut: CGA, Title 22, Chapter 428a, §22-118). States also draw their own Food and Drug Acts, and Weights and Measures Acts. Laws and enforcement varies widely. Pet foods are subject to these regulations whether sold in a grocery store, feed supply, or by a veterinarian; and can reach to online vendors as well. Violating manufacturers can be warned, fined, or ordered to cease marketing a product in that state until they comply. States also have manufacturing plant inspection authority in their laws and in conjunction with FDA actions.
States commonly require registration of the company, and label review and registration of each product prior to placing the product on the market. State laws generally require labels conform to rules of the FFDCA and FPLA, and typically incorporate definitions from the Association of American Feed Control Officials (AAFCO); but further require the manufacturer to provide guarantees of the minimum percentage amounts of crude protein and crude fat, the maximum amount of crude fiber, and in most cases, the maximum amount of moisture and “crude ash.”
Otto: spirit makes the surf an unchallenging hurdle...
The Association of American Feed Control Officials(AAFCO) is a voluntary commercial enterprise (listed as a not-for-profit corporation) that attempts to regulate the quality and safety of fodder (livestock feed) and (secondarily) pet food in the US.
The AAFCO itself has no regulatory authority, but establishes standards on which states base their feed laws and regulations, in part, to “Provide a level playing field of orderly commerce for the animal feed industry.” These regulations are more specific in nature, covering aspects of labeling such as the product name, ingredient definitions, the guaranteed analysis, the nutritional adequacy statement, feeding directions, and calorie statements.
Members of AAFCO are employees of State Department of Agriculture (though not all states participate). That means they are state and federal employees (with regulatory authorities) in their “day jobs.” FDA representatives participate at all AAFCO meetings, and three FDA employees sit on
the Board of Directors of AAFCO.
AAFCO established subcommittees for canine and feline nutrition in 1990/91. AAFCO panels consult with advisers from the pet food industry and livestock feed industries, and with academics and researchers. Recent legislation in the Food and Drug Administration Amendments Act of 2007 requires FDA to establish by regulation: 1) ingredient standards and definitions for pet food; 2) processing standards for pet food; and, 3) updated standards for the labeling of pet food that include nutritional and ingredient information. The FDA is researching this legislative mandate, and many of these regulations are based on a model provided by the AAFCO.
P.D. & Guinness: Frosty explorers
Dog foods labeled as AAFCO “complete and balanced” meet standards established by the AAFCO by either:
•1) meeting a published standard of content: the AAFCO 1992 nutrient profile;or •2) passing a feeding trial. Products formulated with ingredients meeting the nutrient profile would include the following statement: “(Product name) is formulated to meet the nutritional levels established by the AAFCO Dog Food Nutrient Profiles.” Two separate nutrient profiles are established: “growth and reproduction” or “adult maintenance,” and the adequacy statement would indicate the corresponding life stage(s) the product is suitable for. A product labeled “for all life stages” must meet the (higher) nutrient profile for “growth and reproduction”; products labeled as “intended for intermittent or supplemental feeding” (examples: treat or snack foods, or “meat only” foods) need not meet either profile.
AAFCO modus operandi requires that 75% (6 of 8) of test animals complete a 26 week feeding trial without showing clinical or pathological signs of nutritional deficiency or excess. To determine this, four of the animal’s blood values (hemoglobin, packed cell volume, serum alkaline phosphatase, and serum albumin)are measured after the trial, and the average values of the test subjects must meet minimum levels. No animal is allowed to lose more than 15% of its starting weight. Products meeting AAFCO standards can bear the designation: “Animal feeding tests using AAFCO procedures substantiate that (product name) provides complete and balanced nutrition…”
Finn: eyes as window to a gentle soul
COMPLAINTS: THE COST OF
Until the late 1980s, nutritional standards for dog food used by the industry were set by The National Research Council(NRC) of the Academy of Sciences,“a private, nonprofit institution that provides science and technology advice under a congressional charter.” The original NRC standards were based on purified diets, and required feeding trials for pet foods claimed to be “complete” and “balanced.” However, pet food manufacturers deemed the feeding trials onerous and expensive, and subsequently AAFCO designed an alternate procedure for asserting the nutritional adequacy of pet food: by testing the food for compliance with “nutrient profiles.” To establish these standards, AAFCO created “expert committees” for canine and feline nutrition.
which have not been incorporated into AAFCO protocols.
The actual AAFCO feeding trial protocols—the more expensive alternative—for an “adult maintenance” diet dictate that a manufacturer must exclusively feed the test food to only six animals for six months; (eight animals are required at the start; two of them may be dropped from the trial for non-diet-related reasons).
Foods intended for “growth and reproduction” must be tested for only 10 weeks. In lieu of these tests, however,
a standard chemical analysis may also be used to determine that a food meets the profile:
AAFCO only requires a statement on the label stating which method was used.
The Dog Guardian Conducts “Feeding Trials.” The consumer typically interprets the AAFCO compliance statement on a product label as indicating a standard of “quality.” But given what we know about the state of the industry, with thousands of pets sickened, permanently injured, or killed by foods tainted by profit-mongers in 2007 (with recalls continuing to this day); amidst no responsibility having been taken by the industry; and with consumers unable to determine the who/what/why role of “co-packers” that actually make pet foods… it’s fair to question the incestuous nature of the relationship between AAFCO and state and federal regulators. Manufacturers can use broad “complete and balanced” AAFCO endorsement language on foods labeled for use as the singular food for the lifetime of a pet (“for all life stages”) which cannot be validated unless scientific (replicable) testing has been completed over the lifetime of many animals, with comparison made to other, species-appropriate foods, and focused on nutritionally related diseases.
This type of (costly to the industry) testing has never been performed:
in essence, it is the dog guardian himself who conducts “lifetime” testing of these products.
Crispy: an exciting first snowfall
Shortcut: The AAFCO “Family Rule.”
AAFCO's "Family Rule" was heavily promoted by the pet food industry. It allows a manufacturer to have a product that is “nutritionally similar” to another product in the same “family” to adopt the latter's “complete and balanced” statement without undergoing any feeding tests.
The subject nutritionally similar food must be of the same processing type; contain the same moisture content; bear a statement of nutritional adequacy for the same or less demanding life stage as the lead product; contain a dry matter metabolizable energy (ME) content within 7.5% of the lead product's dry matter; meet the same levels of crude protein, calcium, phosphorus, zinc, lysine, thiamine as the lead food; and meet the nutrient levels and ratios of the lead family product or the AAFCO Nutrient Profiles, whichever is lower. It’s important to remember, that these are minimums… not optimums. The label statement on the newer food can be the same as the lead product if the ME is substantiated by the 10-day ME feeding study (AAFCO Official 2010 Publication). Essentially, the “similarity” can be substantially based on similar calorie content, and ultimately, the “feeding test”" label stands as an unreliable indicator of the quality of the food.
Criticism. Among the many critics of the lax, inaccurate and even deceptive AAFCO “complete and balanced” standards is one of their own panel experts, stating: “although the AAFCO profiles are better than nothing, they provide false securities.” (James G. Morris and Quinton R. Rogers, Assessment of the Nutritional Adequacy of Pet Foods through the Life Cycle. Journal of Nutrition, 124: 2520S-2534S, 1994). It is easy to see how an inferior quality diet could be fed for only six months without seeing adverse health effects, and legitimately be labeled as meeting AAFCO standards. Notable are generational studies conducted by researchers at University of California-Davis showing that foods passing AAFCO's feeding trials are not suitable for long term use, and estimating that of 100 foods that pass the nutritional analysis, up to 20 would not pass the feeding trials.
Katrina: the solitude of a cold, snowy beach
Because of concerns regarding over-nutrition, maximum intake levels of some nutrients have been established, but many still lack a highest allowed level and for many others, there is large disparity between maximum and minimum values. The NRC accepts that despite ongoing research, wide gaps still exist in the knowledge of quantitative nutritional information
for specific nutrients.
For example, researchers acknowledge the possibilities of phytochemicalsand other vital nutrients that have yet to be recognized as essential by nutritional science. With such broad guidelines and loose feeding trial standards, critics contend that the term “complete and balanced” is inaccurate and probably deceptive. Regardless, citing their “long and successful working relationship,” in 2007 the FDA signed a “Memorandum of Understanding” that allows FDA to formally recognize the AAFCO list of feed ingredients, and define the FDA's role in deciding on suitability of feed ingredients offered for addition to the list.
Life Stages.There are only 2 life stages recognized by AAFCO standards: “adult maintenance,” and “growth and reproduction,” (includes puppies and pregnant and lactating mothers). Foods posturing adequacy for “All Life Stages”" meet the higher nutritional requirments of “growth and reproduction.” Still, there are no distinct standards—and thus no regulations—for “senior” or “mature” dogs, and foods identified for puppies, “high performance” or “indoor” animals are, regardless of manipulated content, niche marketing hyperbole. A product marketed as “light” or “reduced calories” does have to bear a certain proportion lower calories than the food it is being compared to, but whether such foods actually help pets lose weight in a healthy manner is highly debatable, not the least because weight loss foods are substantially based on improperly modeled protocols for human foods, and focused on reduced fat or high fiber substitutions (powdered cellulose, or wood pulp) for other carbohydrates. Consumers often choose these foods unaware that many so-called "diet" formulations or veterinary prescribed and supplied products are in fact, higher in calories than other "regular" foods.
Argos: covering all the bases...
The Pet Food Institute(PFI) is the U.S. trade (lobby) association of pet food manufacturers. PFI active members account for 98% of the commercial cat and dog food made in the United States. PFI’s mission statement identifies it as “the industry's public education and media relations resource, representative before the U.S. Congress and state and federal agencies, organizer of seminars and educational programs, and liaison with other organizations.”
Well funded, the PFI prioritizes industry profit metrics, representing the industry before the U.S. Department of Agriculture, FDA, FTC, AAFCO and Congress. Members of PFI serve on AAFCO advisory boards including the Ingredient Definitions and the Pet Foods Committees. PFI promotes industry interests, opposing potentially costly legislation including federal or state legislation that would impose more concentrated supervision over pet food manufacture.
PFI readily acknowledges the use of by-products in pet foods as additional income for processors and farmers: “The growth of the pet food industry... created profitable additional markets for American farm products and for the byproducts of the meat packing, poultry, and other food industries which prepare food for human consumption.” (Pet Food Institute. Fact Sheet 1994. Washington: PFI, 1994).
Buca: sunlit spirit
American Feed Industry Association(AFIA) is the lobby organization representing US animal feed businesses and it’s ingredient suppliers, in its mission statement: providing “one industry leadership voice on matters involving federal and state legislation and regulation” for the industry.
National Grain and Feed Association(NGFA) is the lobby organization for grain pet food ingredient suppliers, and under its government and regulatory affairs activities “focus on enhancing the growth and economic performance of U.S. agriculture… in a free market environment… through effective education and communication to the public and government” at both the state and federal levels.
National Renderers Association (NRA) is the lobby organization for rendered pet food ingredient suppliers, and promotes the interests of the rendering industry, improve market access, and “for governmental research and policy consideration, NRA may suggest new protocols in food safety.”
American Pet Products Manufacturers Association(APPMA) was founded in 1958, and despite its name, consists of nearly 900 global pet product manufacturers, importers and livestock suppliers. APPMA is a diverse trade association devoted to promoting the interests of the industry and providing “the services necessary to help its members prosper.” APPMA authors industry research, coordinates trade shows, and has its own Government and Regulatory Affairs Department, dedicated to identifying and responding to regulations and legislation. Also, similar to PFI, the APPMA places representatives on a variety of important AAFCO advisory committees.
Murray: Eyes as windows to a gentle soul
THE GARBAGE. Today’s US pet food industry is largely owned and operated by major international agribusiness conglomerates connected with the human food industry—not pet care specialists—and not associated with natural products of any kind. Four vendors dominate this space (Colgate-Palmolive Co., Del Monte Corp., Mars, Inc., Nestlé S.A., and Procter and Gamble Co.), controling 80 percent of the world's US$48.12 billion pet-food market; the US segment in 2013 comprising
Acquiring pet food businesses is evaluated as a practical business decision: waste materials (by-products) considered unsuitable for human consumption generated by those industries can be channeled to dog or cat food for expedient (and profitable) disposal. This captive market strengthens bulk purchasing power and reliability of pet food supply chain metrics,
and benefits the capital position of both the human and pet food businesses.
Many of these remnants may be very nearly indigestible on their own, and provide a questionable (or, at the least, unappealing) source of nutrition. The amount of nutrition provided by meat by-products (offal: food manufacturing waste), meat meals (not fresh, but rendered meat ), and animal digests (animal fats, oils, and restaurant grease sprayed on dry food as “palatants”—a word not appearing in the dictionary—to make it appetizing) varies widely, yet is principally important for a manufacturer or “co-packer” to realize “least cost mix” protocols. Researchers assert that there is virtually no information on the bio-availability (usabilty/absorption) of nutrients for companion animals in many of the common dietary ingredients used in pet foods. These ingredients are generally byproducts of the meat, poultry or fishing industries, and large agribusiness concerns: with the potential for wide variation in nutrient composition and nearly endless opportunities for contamination or adulteration.
Claims for nourishment value of dog foods based on the current AAFCO nutrient allowances (profiles) cannot impart assurance of nutritional adequacy, and will not,until ingredients are analyzed and bioavailability values are incorporated. A manufacturer/co-packer can synthesize a food containing sufficient amounts of each ingredient according to the AAFCO Nutrient Profiles, but it may not be nourishing: vitamins and minerals in certain forms (or post processing) are poorly absorbed from the digestive tract, and a noted veterinary nutrition textbook claims that a food can be created from old leather boots, wood shavings, and crankcase oil that will meet the technical requirements for protein, carbohydrates, and fats.
Who Cares AboutCARBOs? Despite the deleterious impact that carbohydrate-loaded foods hold on canine health, The Official Publication of the AAFCO specifically discourages the use of the word “carbohydrate” anywhere on a pet food label. For justification, AAFCO maintains that consumers aren't interested in that information.
Jack: all but the smile, nearly blending into the snow
NEVER HEARD THAT WORD BEFORE?
PET FOOD NOMENCLATURE:
Example: Consumers may be confused by terms which make grains—known sources of a myriad of toxins—sound better than they may in fact be. For a consumer attempting to avoid corn and wheat ingredients, Brewer's Rice (used as a common protein source) can sound appealing (even expensive), but is a by-product: simply broken or chipped rice; the small fragments of rice kernels that separate out from the larger kernels of
milled (ground) rice.
Brewers rice and second heads are one of the many byproducts created by milling rice: second heads are milled rice kernels that are ½ - ¾ of the original kernel; while Brewers Rice is a milled rice kernel that is ¼ - ½ the size of a full kernel. Second heads, if of acceptable quality, are used to make rice flour; but if the quality of the second heads are poor, they will be sold for pet food or dairy feed (but, now called: “Brewer's Rice”) as part of least cost mix protocols, because they have no value for any other use. The term “Brewer's Rice” was created by the AAFCO (see above), and it is sold exclusively for pet food and dairy feed.
“Premium,” “Holistic” and “Natural” mean... nothing?Some manufacturers label their products with terms such as “premium,” “ultra premium,” and “holistic.” Such terms currently have no official AAFCO definitions, although that is under consideration. The expressions “human grade ingredients” or “USDA inspected” are completely meaningless—which is why dog food companies can use them. However, the terms natural and organicdo have definitions: organic products must meet the same USDA regulations as for organic human food. Organic agriculture is conducted according to certain standards, especially the use of only naturally produced fertilizers and non-chemical means of pest control. According to the USDA, a food can only be labeled “natural” if it contains no artificial ingredients or added colors and is minimally processed. Labeling must plainly define this aspect of the product, so that consumers are not misled by the “natural” label.
Penelope: natural blow dry...
Still, it is equally important to understand what the “natural” label does not mean: for example, animal products used in dog food that were raised with the use of artificial hormones can be labeled “natural;” as can genetically modified organisms. Although it is true that as a profit objective, aminopterin (rat poison), melamine and probably cyanuric acid were improperly substituted as protein sources by unscrupulous suppliers, investigations of the 2007 pet food recalls (thousands of dogs and cats killed and injured) have led researchers to theorize that genetically modified vegetables may also have been important, because they may not, in fact, combine in a recipe in the same ways that unaltered (conventional) vegetables would.
Most immediately, natural does not mean organic, although many companies rely on consumer confusion to falsely market foods. The opportunities for abuse abound: “Natural Chicken Flavor” can be realized by adding a few drops of rancid restaurant grease, or fats or oils from the rendering process... (and subsequently, that natural flavoring may be artifically preserved). Interestingly, in 2004, the USDA organized the Organic Pet Food Task Force, as part of its National Organic Program (NOP) “to prevent any disruption to the growing market for organic pet food.” Charged with developing labeling standards for organic pet food (that is: recommending federal regulatory change), the Chair of this committee was the Vice President of The Pet Food Institute.
The legal distinction between food and drug is key in terms of FDA's regulatory authority. The legal definitions of “food” and “drug” become mingled when a food label bears a claim that consumption of the product will treat, prevent, or otherwise affect a disease or condition, or, to affect the constitution or function of the body in a way separate from what would ordinarily be described as from its “nutritive value.”
Such claims effectively establish intent to proffer the product as a drug.In this instance, since the product would not have been subject to the normal premarket clearance mechanism to demonstrate safety and efficacy—as required for drugs—it is unsafe by definition. As such, dog food products with labels bearing drug claims are subject to regulation by CVM as drugs as well as foods. A manufacturer must then remove these claims to restore its regulatory status to only food.
Criteria that constitutes a drug claim reach beyond the specific wording that a product will “treat” or “prevent” a disease or condition. Any claim that suggests that use of the product will be of therapeutic benefit can be an implied drug claim. So, any dialogue of a medical condition on a dog food label implies that the product will affect that condition, and could be a drug claim. Beyond text, symbols or other depictions that may imply medical benefit (EKG tracings, medical insignia) may be drug claims. The FFDCA defines “labeling” as all labels and other written, printed or graphic matter including brochures, flyers, signs or similar promotional material found at the point of sale and may be subject to FDA sanction. Still, the FDA grants that there is an fundamental relationship between diet and disease, as did Congress in 1990, when it passed the Nutrition Labeling and Education Act (NLEA), incorporating regulations to allow for certain “health claims” on foods for human consumption. CVM has built-in the philosophy of the NLEA in its policies in order to allow for “meaningful health-related information” on pet food labels to reach the consumer without violating the intent of the law.
Kassie: controlling the melee
Weight Control Products.Obesity is probably the most common nutritional problem in dogs today: the fourth annual Association for Prevention of Animal Obesity study estimated that up to 55% of US dogs were overweight or obese. Following the tack of identifying profitable market positioning for human food products, many “lite” or “low calorie” dog foods became available in the 1990s. FDA regulations promulgated under the NLEA did not apply to pet foods, and without calorie statements, these terms were meaningless: many foods marketed as “lite” were, in fact, higher in calories than regular foods from other manufacturers. To end misuse of the term, in 1999 AAFCO adopted a standard reference for all products, regardless of manufacturer: kilocalorie (thermodynamics: one thousand small calories). A “lite” or “low calorie” dry dog food cannot contain more than 3100 kilocalories per kilogram (kcal/kg); since canned foods are higher moisture, the maximum allowable calories are lower (900 kcal/kg).
“Dental” Formulas.Failure to control tartar (hardened dental plaque) can shorten your dog’s life. Label claims for “clean teeth” have been on pet food labels for many years: chiefly on dry, hard biscuit products (food, not “treats”). As the field of veterinary dentistry and the recognition of the importance of appropriate dental hygiene have grown, products have borne more explicit claims for market positioning purposes.
Claims to treat or prevent gingivitis or periodontal disease are drug claims and should not appear on dog food labels. Plaque or tartar control claims may also be implied drug claims, as they directly relate to dental disease.
However, CVM has exercised some regulatory discretion with respect to plaque and tartar claims for products that achieve their effects by mechanical actions.The Veterinary Oral Health Council, (VOHC: of The American Veterinary Dental College), has developed protocols for manufacturers to demonstrate that their products are “useful” in reducing plaque and tartar. VOHC reviews data from companies to verify oral health claims, and if valid, permits them to carry its logo on the package. CVM has worked with the VOHC in this process, so consumers can be assured that products bearing the logo are functional for plaque and tartar control.
Rigley: Spotting a long-awaited playmate...
THE SECRET PRACTICE OF INGREDIENT
Pet food manufacturers are responding to growing consumer awareness and a parallel demand for better quality ingredients with a deceptive practice known as “ingredient splitting.”
Manufacturers are required to list each item on the ingredient label in order of precooked weight. Consumers often only examine the first several ingredients when making purchase choice: with surveys revealing nearly half looking for meat. Pet food marketing now commonly focuses this “first ingredient rule.” tack. Through ingredient splitting, a manufacturer can artificially raise a meat ingredient to a higher position on the list; while simultaneously dropping an inferior, plant-based ingredient/filler lower: where it is less noticeable.
Many grain-based foods are primarily made of low-grade and long-term stored corn and rice, inexpensive, plant-based ingredients that are not only biologically inappropriate, but clearly not equivalent to the nutrition provided by animal meat. But many consumers would rightly reject a food if the label divulged, for example, that the main (first) ingredients were these inferior grains, because if meat or fish were present in the food: it would get bumped down the list.
However, after splitting, the manufacturer can use different corn, wheat, rice, potato, and pea products, and list them separately (split them). In this way, “30% corn” becomes “15% corn gluten meal” + “15% corn flour,” (with added qualifiers such as “whole” thrown in to confuse: “whole ground wheat” or “ground yellow corn”); and “20% rice” can become “10% rice gluten” + “10% rice bran,” while a pea ingredient can be broken into peas, pea flour, and pea fiber, and so on. Because the grain ingredients have now been split, their apparent quantities are decreased, making [the smaller amount of meat ingredient rise to the top of the list: which is enough to convince many consumers that the food is more meat-based and higher quality than it really is.
Consumers must remember that the total protein percentage on most pet food labels does not reveal how much of that protein is animal-sourced, the most species-appropriate for dogs. In fact, much if not most of the total protein in most processed pet foods is sourced from plants, not animals.
Carter: plotting a frosty frolic...
ENDNOTES (page 1):  The FDA is responsible for protecting and promoting public health through the regulation and supervision of food safety, tobacco products, dietary supplements, prescription and over-the-counter pharmaceutical drugs (medications), vaccines, biopharmaceuticals, blood transfusions, medical devices, electromagnetic radiation emitting devices (ERED), veterinary products, and cosmetics. Click link for the draft Foods and Veterinary Medicine Strategic Plan 2012 - 2016.
 However, through this broad definition, it may be difficult for the consumer to identify the actual manufacturer of the product. Prior to the horrific events of the 2007 pet food recalls, consumers were generally unaware that contracted “co-packers” such as Menu Foods were the actual manufacturers of branded pet foods. (See discussion, "Manufacturer Name & Address" in page 2 of this essay).
Archie: winter warrior
 “Industry-standard,” as defined by AAFCO—or, as in the case of the term “Brewers Rice,” an AAFCO invented term that implies something other than it is (see discussion, “Other Nomenclature... ” on this page)—and so thereby, not necessarily understandable to the consumer.
 Crude ash is the final product (mineral nutrients) of food combustion. In other words, if you were to completely incinerate a can of dog food… all three major nutrients… protein, fat and carbohydrates… would burn away… leaving just the food’s minerals (ash) behind.
 Dog Food Nutrient Profiles were last updated by the AAFCO Feline Nutrition Expert Subcommittee (1991-1992) and the AAFCO Canine Nutrition Expert Subcommittee (1990-1991). These profiles replaced previous recommendations set by the National Research Council (NRC). In 2010, AAFCO began examining updating nutrient profiles based on 2006 NRC recommendations.
 Hemoglobin: the iron-containing oxygen transport metalloprotein in red blood cells (deficiency creates “anemia”); hematocrit (HCT) or packed cell volume (PCV) orerythrocyte volume fraction (EVF) is the proportion of blood volume that is occupied by red blood cells; Alkaline phosphatase (ALP, ALKP) is a hydrolase enzyme that removes phosphate groups from molecules, including nucleotides, proteins, and alkaloids; Serum albumin is the protein essential for maintaining osmotic pressure for proper distribution of body fluids between intravascular compartments and body tissues, and acts as a plasma carrier by binding hormones and as a transport protein for fatty acids.
Pennington: imploring his too-slow guardian... !
 Phytochemicals: chemical compounds that occur naturally in plants. The term is generally used to refer to those chemicals that may affect health, but are not yet established as essential nutrients.
 Elizabeth M. Hodgkins, DVM, Esq.: Your Cat, (2009); Marion Nestle & Malden C. Nesheim, Feed Your Pet Right, (2010).
 Nestlé bought Purina (Fancy Feast, Alpo, Friskies, Mighty Dog, Dog Chow, Cat Chow, Puppy Chow, Kitten Chow, Beneful, One, ProPlan, DeliCat, HiPro, Kit’n’Kaboodle, Tender Vittles, Purina Veterinary Diets); Del Monte acquired Heinz (MeowMix, Gravy Train, Meaty-Bone, Canine Carry-Outs, Kibbles ’n Bits, Wagwells, 9Lives, Cycle, Skippy; pet treats Milk Bone, Pup-Peroni, Snausages, Pounce), premium lines Nature's Recipie and in 2013, Natural Balance;MasterFoods owns Mars, Inc., which bought Royal Canin (Advance, Cesar, Dentabone, Dentastix, Exelpet, Greenies, Jumbone, Natural Choice, Nutro, Pedigree, Ultra, Whiskas, Waltham’s, Cesar, Sheba, Temptations, Goodlife Recipe, Sensible Choice, Excel); Procter and Gamble (P&G) purchased The Iams Company (Iams, Eukanuba) and soon after introduced (and heavily marketed) Iams into grocery stores, wherin as a so-called “premium brand” it has flourished; in 2010, P&G acquired Natura Pet Products (EVO®, California Natural®, Innova®, Karma, Mother Nature); Colgate-Palmolive bought Hill’s Science Diet (Hill’s Science Diet, Prescription Diets, Nature’s Best).
 Rendering entails rupturing fat cells, either by heat or enzymatic- and solvent-extraction, and then drying the residue.
Diesel: Mr. Dynamo
 James Morris and Quinton Rogers, Department of Molecular Biosciences, University of California at Davis Veterinary School of Medicine.
 AAFCO: (2003, p.178), “Carbohydrate guarantees are no longer considered as necessary or meaningful for purchaser information, therefore, their use is discouraged,” (see: Brown & Taylor, See Spot Live Longer, 2005).
 See: Dr. Michael M. Fox, Genetic Engineering and Cloning in Animal Agriculture: Bioethical and Food Safety Concerns, (2009).
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N.B.: This essay is written for informational 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. The most important thing a pet guardian may do in his dog's lifetime, is work to build an understanding of 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.
“Just a Dog?” “From time to time, people tell me, lighten up ‘it's just a dog’, or ‘that's a lot of money to spend on just a dog’. They don't understand. Some of my proudest moments were with ‘just a dog’. For many hours, my only company was ‘just a dog’. Some of my saddest moments were with ‘just a dog’, who gave me comfort. ‘Just a dog’ brings into my life the very essence of friendship, trust, and joy.
‘Just a dog’ brings out the compassion and patience that make me a better person.
I rise early, take long walks and look longingly to the future. ‘Just a dog’ brings out what's good in me. I hope that someday you will understand that it's not ‘just a dog’, but the very thing that keeps me from being ‘just a person’.” —Author unknown
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?