What's Really in Dog Food?

Consumers generally don’t realize that the pet food business is an extension of the human food and agriculture industries. 

Today, most pet food companies are owned by agribusiness conglomerates: production of pet food presents an opportunity to turn discarded food components such as spoiled, inedible grains, beverage industry wastes, and slaughterhouse offal (dictionary definition: “refuse,” “rubbish” and “garbage”) or carrion (dictionary definition: “dead or putrifying flesh”) into profit, in order to weave sustainability and necessary “least cost mix” protocols throughout their organizations.

Rendering[1] companies that process ingredients for pet food manufacturers can secure supplies from salvage food brokers.  These are companies who broker spoiled, rotting ingredients (“distressed or reconditioned distressed merchandise”) so that they can be converted into stable, “value added” materials.  

Some states even regulate the practice, defining salvage as: “any food, drug, device, or cosmetic that has been subjected to prolonged or improper storage, loss of label or identity, or abnormal environmental conditions such as extremes in temperature, humidity, smoke, water, fumes, pressure, or radiation that are due to natural disasters or otherwise, or that may have been rendered unsafe or unsuitable for human consumption or use for any other reason.” 

Instead of destroying it, (example: bread and cereal rejects, such as cobs, stalks, and mill sweepings), salvage food brokers can help sell it to pet food manufacturers.  This “recycling” is defended in a self-congratulatory way by the pet food industry as supporting environmental “sustainability” through “customized, specialized... nutritional...
pet food solutions.”

Recycling the Garbage...

This waste includes undeveloped eggs, intestines, udders, heads, lungs (perhaps congested with pneumonia or bronchial bacteria), brains, hooves, hair & feathers, cirrhotic or worm-invested livers (“liver flukes”), “viscera”; rotted, diseased and cancerous tissues, drug injection sites (“stick marks”) and bone matter cut away from healthy slaughtered animals or salvaged from zoos or research laboratories; as well as bagged or crated roadkill and corpses from animal shelters, veterinary clinics or pest control companies (its cost-effective: to have the carcasses carted off instead of having the expense of incinerating the animal remains; and without removing the plastic bags), and foals from the Pregnant Mare Urine (PMU) industry (sourced for human hormone replacement therapy)... that have been processed into dry (powdered) “meals” by commercial rendering plants. 

These plants— 286 in the US alone, who quietly dispose of more than 18 billion pounds of dead animals, fat and meat wastes annually— also pulverize plastics or heavy metals from pet collars and cattle ID tags, surgical pins, needles, or insecticide patches...

...BECAUSE IT
COSTS MONEY
TO REMOVE THEM.

Waste also enfolds the salvaged mixed species carcasses of “4-D” (dead, dying, diseased, or “downed”) animals; (see below: often the term “destroyed” is exchanged for downed).  In an eyewitness account published in the Earth Island Journal: “The (delivery dock and) rendering plant floor (are) piled high... waiting to be processed. In the ninety degree heat, the piles of dead animals seem to have a life of their own as millions of maggots swarm over the carcasses.”

Referred to as by-products, this waste can include rancid restaurant oils and grease, expired/past-date supermarket meats, spoiled fish or poultry by the truckload: still in their original styrofoam trays, shrink wrap, or cardboard boxing—its time consuming to separate it— and anything remaining of decomposed (and insect infested) animal corpses after the parts destined for human consumption (or any more commercially lucrative use)
have been removed.

In fact, the National Renderers Association simply identifies tissue as from “fallen animals,” not even regarding specific species, and: not qualifying the term “fallen.”

Profit-driven desperation to bring these animals to the slaughterhouse door and into the food supply-chain is so intense, that horses and cattle that are sick and near death (unable to stand or walk: known as “downers”) are commonly tortured to force them to rise
or keep moving.[2]

But even beforehand, they are pumped with synthetic growth hormones (zeranol, trenbolone acetate and melengestrol acetate) and antibiotic drugs (arsenic, erythromycin, penicillin, procaine, streptomycin and, trimethoprim are examples) to combat the effects of stressful, overcrowded, and filthy conditions of factory farming[3] production.

Arsenic is used to control parasites and stimulate growth in poultry factory farming environments, also known as confined animal feeding operations (CAFOs).  Some 29.9 million pounds of antibiotics were sold in 2011 for meat and poultry production–compared with the 7.7 million sold for human use (FDA: 2011 NARMS Retail Meat Annual Report).

These drugs are further necessary to help negate the consequences of the fouled, recycled/waste product diets these unfortunate animals themselves are forced to consume.  For example, consumers are generally unaware that, as a cost management issue, dried “Poultry Litter” is used in “animal feed”: which simply means that cows are fed floor sweepings containing chicken excrement… from chickens that ate cows.

Still-useful
leftovers are typically
not  organ meats, and generally
retrieved for products other than pet food.
  More plainly: each chicken only has one liver;
but agribusiness manufacturers have many products, ranging
from human foodstuffs and personal care products, to (at the bottom)
pet food, competing for it.  Unsurprisingly, the best and least damaged parts
are directed to grocery store shelves: for people… and the rest goes… where?

Exclusive Rights:
to Process “Garbage/refuse/rubbish”
into Pet Food...

It’s true that a lost and starving dog raiding the chicken coop would surely ingest some feathers and a fair amount of “by-products” in his meal.  But there’s a significant difference in the nutritional profile of that dinner on the lam and what the luckless animal would have been given (with pride) from his guardian shopping at the grocery store: and he
would be the better for it.
 
The 20% animal protein in that 30-lb. bag often consists of only chicken feet, heads, bones and feathers (generally a mix of horse and cattle by-products as well): largely comprising those parts that are strictly not usable for anything else, except perhaps fertilizer, soap and solvents, and lard. 

However, profit metrics for pet food are considerably more robust than any of those uses.  In fact, Mars Inc. (Mars Petcare: US $17B sales in 2016) holds a patent (US 7,575,771 B2) for a procedure to process offal (dictionary definition: “garbage/refuse/rubbish” and: “waste or by-product”) into pet food.

A single Mars brand alone represents 10.9% of the total dry food market in the US (2017).  In response to complaints about stiff “plastic shards/wires” in that product, the company responded: “Our team has conducted testing on affected kibble and determined these are natural fibers from meat and bone meal, like pig hair, that occur with products made using those ingredients. (It) is completely safe for your dog to enjoy.”  Meat and bone meal (so-called because it is from animals of unidentified origin: or un-named animals) is among the lowest quality ingredients that can be
in a dog food.

In 2000, the FDA concluded that: “There appear to be associations between rendered or hydrolyzed ingredients and the presence of pentobarbital in dog food. The ingredients Meat and Bone Meal (MBM), Beef and Bone Meal (BBM), Animal Fat (AF), and Animal Digest (AD) are rendered or hydrolyzed from animal sources that could include euthanized animals.”

Pentobarbital is a barbituate, used to sedate and euthanize cats, dogs, and horses.

Mars may define ingredient sourcing different than many consumers would expect—or, that federal law defines—declaring that dogs should actually prefer “garbage”: “By-products are the clean, internal organs, including liver, lungs, intestine, etc. In fact, when eating in the wild, dogs naturally gravitate toward the internal organs as their first choice of food. One reason may be because organ meats are a more highly concentrated source of essential nutrients, as compared to muscle tissues (meat), thus providing more nutrition to the dog.” 

The term “clean” is simply used falsely; and the term “etc.” implies that the by-products are only internal organs.  Mars also carefully describes “artificial preservatives” as “essential” and that “filler (ingredients)” are appropriate because they have a “specific purpose” in their products.

In 2017, Mars acquired VCA Inc.'s U.S. and Canada hospital and animal diagnostic imaging companies in a $9B transaction, adding to its reach from Banfield Pet Hospital (largest chain of veterinary hospitals in US: $774M US sales in 2017), Blue Pearl veterinary hospitals, and Pet Partners veterinary clinics (also: in Europe, Anicura AB; in the UK, Linnaeus).  In this way, Mars-employed veterinarians diagnose and treat (with Mars veterinary prescribed products and foods) illnesses that their own products can create in their clients.

You wouldn’t buy a food labeled
“Slaughter House Waste Flavor Dog Food”
... would you?

Is this the imagery peppering the bag of dog food (known as: “label presence”) a consumer totes home from the supermarket?  More likely it is pictures of fresh whole chickens in a bucolic “farmhouse” setting: choice cuts of beef and pork, fresh grains... and the like, a “human grade”cornucopia tumbling earthward in vivid color across the package. 

With $27 billion spent annually in the US on pet food at stake, millions are invested in research funded to determine how to make that package and the name of the pet food appealing (it may be more accurate to say, "legally deceptive") to the consumer. 

However, no long-term studies on the safety of these food components have been conducted; nor are they required.  It seems reasonable to conclude that to perform them would yield results that would surely expose the manufactures to liability, and hold potential to de-legitimize the rendering industries as places of honest business.
 
Still, some other types of studies are done: carefully categorized as so-called “nutritional research”—perhaps medically gruesome: naturally conducted in secret—including muscle tissue-sampling on live animals (vivisection); and laboratory-based (long-term/permanent) caged “feeding trials” to capture a palatability threshold (spraying dried kibble with taste- enhancing “top coat” recipes: carefully derived addictive slurrys of rendered (heat-processed animal digest, fats, salts, and missing nutrients) that will encourage the dog to eat biologically inappropriate food which he would otherwise never touch.  These fats account for the smell when the bag is opened). 

But... not long-term nutritional testing, which would be “expensive” and is not legally required; and would likely expose shortcomings and lifetime medical costs of consuming an inappropriate, grain-based diet.  The wandering dog we just discussed?  Instinctively protein-starved: he'll head for the chicken coop ...not the corn silo. 
 

Industry scientists assign a profile of synthetic colors and additives to give the mixture an appealing color or texture (to achieve the marbled-look of real meat, the mixture may be cooked unevenly: with half of the batch colored red and the other white); or to design gelatinous “gravy.” 

FDA “generally recognized as safe” (GRAS) products include transglutaminase, commonly known as “meat glue,” (produced through the fermentation of bacteria): used to bind together scraps of “meat.”  Or more simply, just use Textured Vegetable Protein (TVP) as a manufactured meat analogue: a substitue for meat.  They also configure protocols for emulsifiers (colloidal suspension tools, such as gums: to bind completely imiscible ingredients), grinding agents, anti-fungal agents, thickeners, and stabilizers. 

Since the dog is clearly not concerned with the color or appearance of his food: this carefully researched, high-tech factory makeover is solely on behalf of his guardian's conscience, and to appeal to his sensibilities as a consumer.

Finally, cooking high carbohydrate food components and grains at high temperatures (which is necessary to sterilize decaying and moldy ingredients, or to control insect infestation) may stimulate the creation of genotoxic Maillard reaction products (MRPs),[7]  heterocyclic amines and acrylamides,[8] (carcinogens that cause DNA mutation), and mycotoxins (fungal waste products: see below), which are known to have developed resistance to degradation from heat sterilization. 

Many dry dog foods are formulated to withstand sitting on store shelves for years: a 50-pound dog on a dry diet consumes an average of 18-pounds of
preservatives annually. 
 

Maillard Reaction Products

Despite claims of rendering trade association lobbyists, research has shown that pathogenic bacterial toxins (endotoxins:[8] toxins that are released on bacterial death), fungal toxins, pharmaceutical drugs, chemical residues, GMO’s, toxic AGEs (advanced glycation end products) generated in late-stage Maillard Reaction products,[7] and heavy metals are not destroyed during the process of rendering diseased or otherwise unfit animal tissues for pet foods. 

AGEs speed up oxidative damage to cells, altering their normal behavior: through the association with receptors that bind with AGEs (RAGE) in the glycation process, glucose can tie to proteins which reduce cell pliability, resulting in activation of pro-inflammatory genes that subject cells to damage and premature aging.  The compounds can affect nearly every type of cell and factor in chronic aging diseases, vascular damage, diabetes, and renal failure.

Grinding
Poultry Feathers
for "Feather Meal"

A dog fed dry “convenience” food
is continually exposed
to these toxins
across his lifetime

The costs: proclivity for developing diabetes, lipidosis and pancreatitis, urinary tract infections, inflammatory bowel disease, renal failure, hyperthyroidism, bacterial infections & peridodontal disease, heart disease, arthritis, atopic dermatitis, mycrotoxicosis, and broad chronic inflammation that supports life threatening afflictions.  Based on valueless high carbohydrate grains, the protein-starved dog instinctively overeats to compensate: obesity being the gateway to a myriad of heath issues.

White adipose tissue (used as energy storage), which expands when excess calories are available and the body stores as fat, is linked to numerous health issues. A 2018 (University of Liverpool) study of medical records across 12 common breeds of client-owned dogs demonstrated a negative association between overweight body condition and life span.

The detoxification mechanisms of dogs were developed over thousands of years, designed to cope with the natural pathogens an animal would encounter over its lifetime.  As much as 80% of a dog's immune system resides in his digestive intestinal tissues and is known as GALT (gut associated lymphatic tissue); 
or simply: his gut.

Under an unrelenting assault from toxins and impurities in poor quality foods, the level of beneficial gut bacteria (the “microbiome”) diminishes and the gut can no longer maintain the balance of appropriate immune response.  This leads to a general state of inflammation known as “leaky gut syndrome”: the intestinal wall becomes permeable and undigested food particles along with other foreign bodies can pass directly into the blood stream prior to being properly digested in the small intestine. 

Although many systemic and chronic conditions might seem unrelated to the digestive system, in fact, problems such  as joint issues (weakened joints, dysplasia,  arthritis), upper respiratory infections and rhinitis, autoimmune diseases, ear and eye infections, skin issues and even anxiety/stress are inflammatory processes. 

So-called convenience foods are a recent phenomenon: dry foods materializing only in the last few decades.  During that time, the average lifespan of dogs has declined by 18%; and the cellular lifespan (how long cells live and reproduce/replace themselves) of dogs is nearly double the actual average lifespan.  If modern dog foods are as nutritious as advertisements claim they are, why do dogs die so young?  

It’s important to understand how nutritional value of a food can be affected by the source of the ingredients used.  Probably the most important nutritional component the consumer looks for is “protein,” but labels can be misleading.  A protein biological value (referring to the nitrogen balance index) depends on the food’s unique composition of amino acids: the “building blocks” the body uses to repair tissue.  On this scale, the egg is the most useful protein (100 scale); while, for example, wheat gluten (a common source of protein in pet food) is 40 scale. 

Moreover, the digestibility of a protein (the extent to which the gastrointestinal tract can absorb it) affects its usefulness and should be considered when comparing products.  Additionally, prolonged high temperatures used to sterilize putrified ingredients can destructure and denature the bioavailability of proteins and oxidize (destroy) vitamins; and is a contributing factor in the necessity for employing a legion of chemists to add back a brew of compensating—but nearly invariably artificial—nutrient supplements.

But the consumer examining the label of a dog food for information would be underinformed.  Almost invariably, the designation is crude protein, referring to ingredients in their original (and pre-rendered) state, and with little or no information about the source of that protein.  

Many dry foods are built upon multiple sources of low biological proteins that are combined to reach a threshold value that would ordinarily be present in higher quality sources.

The use of grains or “by-products” in pet food can help to artificially boost the appearance of protein levels, while providing relatively little usable nourishment (bio-availability) for your dog.  Adding to the confusion for the consumer, that pre-rendered state includes moisture which is extracted during processing, and we must remember that on the label, ingredients are listed in order of weight: a teaspoon of dried “meat by-products” will weigh more than a teaspoon of “fresh” meat or even dry chemicals.  With that leverage, much can be accomplished on a label to deceive the customer as to what is in the bag.  So too, consumers are generally unaware that once moisture is eliminated, the dried rendered ingredients yield a concentrated protein product which can boost protein levels to a deceptive level.

If a dog food contains grains, it's important to understand that the “crude protein” percentage in the guaranteed analysis on the package label includes both animal and plant protein (example: soy, a well-documented endocrine disruptor); and manufacturers aren't required to reveal how much protein is derived from animals versus plants.  Since plant proteins are less expensive than meat proteins, pet food manufacturers seize this legal definition, to increase profit margins.  However, many grains, particularly those high in lectins (proteins that bind to particular carbohydrates), can contribute to “leaky gut syndrome” by binding to receptor sites on the dog’s intestinal mucosal cells, thereby interfering with the absorption of nutrients across the intestinal wall, supporting negative autoimmune and inflammatory effects.

Is it possible to
shop with confidence in the grocery store?

A designation the consumer will often see on a label is that of the AAFCO, The Association of American Feed Control Officials, as a “Nutrition Statement,” that the product is “formulated to meet the nutritional levels established by the AAFCO…”  AAFCO is a voluntary private membership association of local, state, and federal officials designated to regulate the sale and distribution of fodder (livestock feed) and (secondarily) pet food in the US.  The AAFCO itself has no regulatory authority, but establishes standards on which individual states base their feed laws and regulations, in part, to “Provide a level playing field of orderly commerce for the animal feed industry.” 

The AAFCO requires no meaningful testing of foods before manufacturers can use its broad “complete and balanced” endorsement language on pet food labels.  For example, a claim that a food is “complete and balanced” (for “maintenance”) as a sole food for the life of a pet 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 “real-world” analysis has never been performed by any pet food company: in essence, it is the dog guardian himself who conducts "lifetime" testing of these food formulas.

Of its two methods to ascertain nutritional adequacy, AAFCO's supposedly more intensive is feeding trials, which enfold only a six-month trial and as few as eight test subjects to determine if a formula can sustain life.  Only six of the eight animals need to finish the feeding trial, and if weight and certain basic blood tests (that don’t even measure blood nutrient levels) are normal: AAFCO deems the food is certified as “complete and balanced” for “maintenance.”  But in lieu of this test, a standard chemical analysis may be used to qualify that a food meets the AAFCO standards for nutritional profiles.   This change was made in the 1980s when pet food manufacturers complained that the existing protocols set by the National Research Council were onerous and expensive.

AAFCO regulations specifically regard “nutritional adequacy,” or the amount and ratios of nutrient levels, and ingredients are reviewed on that basis: “the specific nutrients may be assembled from a variety of ingredients... of agricultural surplus.”  AAFCO also readily acknowledges that manufacturers adapt recipes to add minuscule amounts of vegetables or fruits simply for “label presence, ” and that “labeling and marketing information is designed to appeal to the latest trend in marketing human products.”

Given what is known about the nutritional uselessness, unsanitary storage and production, and frequently unsafe standards for “by-products,” biologically inappropriate starchy grains, and dried additives: we should rightfully recoil at the ingredients list and claims that Beneful® will “keep your dog happy and healthy with a perfect balance of healthful ingredients, quality nutrition and superb taste;” posted on  Purina’s own site:

Nine of the first 10 ingredients are high carbohydrate grains, starches and flours,
(corn is listed twice)
low-bioavailable proteins, "by-products,"
industrial chemicals, and sugars. 
Farther down the label is:

• corn gluten meal = livestock feed and herbicide, used to boost protein levels: by-product after the manufacture of corn syrup or starch/the dried residue after the removal of the bran, germ, and starch; (the second time corn appears);

• propylene glycol = artificial preservative, proven toxic to red blood cells;

• tricalcium phosphate = “bone ash” (crude ash, the residue of complete incineration of food components);

• phosphoric acid = low cost synthetic bulk alternative to natural flavorings (lemon or lime), used to impart a tangy taste; commercially, phosphoric acid is used to remove rust from metal.

• animal digest = palatability enhancer, made by reducing meat and fat, in this case from un-named animal sources (unidentifiable origin);

• potassium chloride = metal halide salt, (used in fertilizer, and as the last in a three-drug combination of lethal injection);

• dicalcium phosphate = nutritional supplement added to dog foods and poultry feed;

• calcium propionate = antimicrobial/ antibacterial/ antiviral;

• monohydrochloride = a red dye;

• calcium propionate = a mold inhibitor;

• choline chloride = added to poultry feed as a growth stimulator;

• DL-Methionine = an amino acid, used to reduce PH of the dog's urine;

• ferrous sulfate = green colorant and iron supplement;

• calcium iodate = a dough conditioner.

Question: What exactly is “Cellulose”?
Answer: Industrial waste.

Pet food manufacturers stress the importance of fiber in dog diets, despite that the canine ancestral diet contains only minimal amounts of fiber. It’s fair to question why. The answer lies in “least cost mix” protocols.

Fiber increases bulk and water in the intestinal contents, benefiting conditions of both diarrhea and constipation, by controlling the rate at which food passes through the digestive tract. Fiber can also help balance a dog’s gut microbiome: some fibers break down in the intestine into fatty acids, which help prevent overgrowth of hostile bacteria. Fiber binds certain toxins in the gut and removes them from the body in feces; while allowing time for nutrients and water to pass from the large intestine into the bloodstream.

Fiber in dog food may be soluble or non-soluble (insoluble). Soluble fiber dissolves in and absorbs water, and is more digestible than insoluble fiber. Soluble fiber promotes smooth passage of food to the GI tract, while insoluble fiber speeds up the rate at which food passes through: this is why many so-called “diet” or “reduced calories” foods are fiber heavy.

Certain legumes, oats, rye, barley, some fruits and vegetables, root tubers, root vegetables, psyllium husk, flaxseeds and nuts are sources of soluble fiber. Insoluble fiber is found in wheat and corn bran, beans, peas, particular nuts and seeds, as well as the skin of potatoes, plant polyphenols (lignans) found in green beans, cauliflower, zucchini and fruits, including avocado; also the skin of some fruits, including kiwifruit and tomatoes.

Fibers are fermentable and non-fermentable. Fermentable fibers—generally soluble rather than insoluble—are broken down by bacteria in the gastrointestinal (GI) tract; the nutrients can be converted to energy.

A recently published study identified development of biomarkers for nonalcoholic fatty liver disease in rats who were fed ultra-low (that is: federally allowable) doses of the seemingly omnipresent agricultural herbicide glyphosate, and “demonstrate… a causative link between an environmentally relevant level of [Roundup®] consumption over the long-term and a serious disease.”[9]  Other notable reports: a 2016 study rats fed genetically modified (GM) corn for only 90 days suffered serious damage to membranes of the small intestine;[10] and a 2009 study linked GMO corn to kidney and liver disease, damage to heart, adrenal glands, and spleen in rats after only a 90-day feeding trial.[11]
 

In 2016, The World Heath Organization, International Agency for Research on Cancer (IARC), catalogued glyphosate as a 2A “probable” human carcinogen.  Food Safety Advocates describe manufacturer Monsanto's vigorous rejection of that classification, augmented by a campaign to discredit IARC scientists. 

Additional research focusing on common commercial surfactants such as polyethoxylated tallowamine (POEA: which helps the herbicide penetrate the waxy surface of plants), and other co-formulants and additives in various formulations of Monsanto's Roundup® has shown that many of the declared inert ingredients may be more toxic than glyphosate alone.  These factors have led to a growing number of countries banning their import or use, on the basis of their potential to destroy biodiversity, and, citing mass honeybee die-offs.  
 
In the US, the EPA continues to deflect criticism linking the herbicide to endocrine disruption, reproductive effects, and kidney and liver damage; which Food Safety Advocates attribute to especially intensive legislative pressure brought by Monsanto.  Recent court filings in a civil complaint assert that Monsanto held influence within the US Environmental Protection Agency’s (EPA) Office of Pesticide Programs (OPP), had close ties specifically to its deputy division director coordinating the review of Roundup®; and request that the federal court to lift a seal on documents detailing the company’s interaction with the official regarding the EPA’s safety assessment of glyphosate.
 

Glyphosphate is absorbed by genetically modified crops (GMOs) that have been engineered to contain a pesticide derived from the Bacillus thuringensis bacteria, to resist applications of herbicides such as Roundup® as a weed killer. 

Most US-produced corn (88%), soy (93%), sugar beet (54%), cotton (94%) and canola (90%) are GMOs.  The chronic exposure to these chemicals is inevitable for dogs that are forced to consume a steady diet of grain-based (convenience/dry) foods.
 
While recent research links fatty liver disease to glyphosate levels of 0.1 parts per billion, a 2015 study[12] utilizing high performance liquid chromatography (HPLP: the EPA’s accepted method of analysis) has identified levels of glyphosate as high as 300ppb in just a limited range of pet foods.  The authors discuss that NaNO2 (sodium nitrite), a common preservative in pet food manufacture, reacts with glyphosphate to produce N-Nitrosoglyphosate, a carcinogen, and phosphonic acids AMPA and MAMPA.
 
Food Safety Advocates suggest that the biologically inappropriate inclusion of GMO grains and vegetables as well as glyphosate-sprayed dry wheat and imported GMO rice used by pet food manufacturers in pursuit of “least cost mix” protocols may support explanation for the rising toll of abnormal liver enzymes, intestinal dysbiosis, allergies, autoimmune diseases, metabolic syndrome and the obesity epidemic that is, by obvious measure, so common in dogs today.

2018: "Regulatory Capture" (redux)

Twenty years on, neither has the FDA met a Congressional directive from 2007 (after the deadly melamine scandal) to upgrade labeling and safety standards for pet food – providing consumers more transparency and assurance that pet food is safe.  Food Safety Advocates describe a situation similar to that of the 1930s, where the FDA was in “regulatory capture,” created as a state regulatory agency to act in the public interest, but instead advancing commercial or special interests that dominated the industries it was charged with regulating.  As a “failure of government,” regulatory capture ultimately encourages a business model wherein large firms impart negative economic and moral social costs on consumers (the third party in the relationship).

Endnotes

The rendering process involves rupturing fat cells, either by heat or enzymatic- and solvent-extraction, and concurrently dries the material and separates the fat from the protein and bone, yields fat commodities, and animal protein meals (meat and bone meal, poultry byproduct meal, etc.), which as concentrated protein products can be used to boost stated protein levels of inferior pet foods.  Rendering plants also process materials such as slaughterhouse blood (blood meal), feathers, (feather meal) and hair as protein vendibles.

Feather meal is a byproduct of processing poultry; containing up to 12% nitrogen, it is used in formulated animal feed (for ruminants in “factory farm” environments: see note #7, below) and as a source of slow-release/high-nitrogen fertilizer for organic farming.  The bio-availability of this nitrogen, however, may be low.
 
In a pet food industry publication, (“Adding Value to Feathers”), a feather meal manufacturer (GoldMehl) states: “Processed by-products have become an important protein source for the industry …[as] an economical feed ingredient.”  The statement continues: “Unprocessed feathers are high in crude protein (90 percent),” but notes that because they are “highly indigestible… feathers have to be processed.”
 
In order to have bio-availability (making the protein available), feathers need to be broken down to an amino acid level: the feathers are hydrolyzed (separating chemical bonds by adding water) during rendering, and then dried for grinding into a powder.  Other common methods are prolonged boiling in a strong acid (acid-HVP) or a pancreatic protease enzyme.  Then, a palatant is added so that the feathers have “taste.” 

Feather meal is mostly insoluble keratin (fibrous protein) with high cystine (an amino acid) content, which places stress on the kidneys: cystine may become concentrated in the urine, leading to the formation of crystals, then, kidney stones.

A 2012 study found caffeine, pharmaceuticals (including acetaminophen and fluoxetine) and residues of fluoroquinolones: broad-spectrum antibiotics banned for use in poultry production by the FDA in 2005.  Still, despite that antimicrobials used in poultry production have the potential to bio-accumulate in poultry feathers as a “(toxicity) pathway,” feather meal itself is not directly tested as part of the U.S. Department of Agriculture’s Food Safety and Inspection Service and National Residue Monitoring Program(s).

After a mere seven-day feeding trial, GoldMehl determined that once processed, “digestibility for feather meal” was “comparable to regular poultry meal.”  Royal Canin states that they are pursuing use of feather meal for an “Anallergenic formula” as well as “worm meal” for pet foods in China: “For us, terms like ‘organic’ are irrelevant,” a company spokesman declares, since “… we take nutritional science to a whole new level;” adding that the matrix for sourcing protein ingredients is contracting: “We’re using something that would otherwise end up in a landfill... [and] it’s incredibly nutritious.” 

Nearly 5 billion pounds of rendered animal waste is produced annually in the US into animal protein meals.  The largest markets for these commodities are poulty (livestock) and pet foods/treats, the latter identified as a significant “growth market” by the National Renderers Association.  The cooked ingredients can be the most scandalous: diseased animals, diseased or cancerous animal tissues, and 4-D/downer animals.

The National Animal Control Association estimated that each year about 5 million pets were shipped to rendering plants and recycled into pet food during the 1990s. Euthanized animals would generally be captioned as meat or bone meal in the ingredient lists.
 
Meat and bone meal is one of the ingredients FDA testing determined to be associated with euthanized animals (the detection of pentobarbitol in pet foods suggesting that euthanized shelter animals were being rendered into pet food); and can also include diseased tissues and drug injection sites cut away from healthy slaughtered animals.  Presently, only 4 products: Friskies® Cat Food (Purina), Ol Roy™ Dog Food (Walmart), Kibbles & Bits® (Del Monte), and Pedigree® (Mars) disclose “meat (or beef) and bone meal” as an ingredient on their package labels, and this would not account for industry sales.  Thus, it is reasonable to question whether some pet food companies are using meat and bone meal but label it as another ingredient.

[2]  The HSUS investigation into the Hallmark Meat Packing Company plant is our most ready example: (read more).

To hide the “often sadistic treatment of factory-farmed cows, pigs and chickens” agricultural lobbyists have pressured state legislatures to enact so-called ag-gag laws, decried by animal welfare advocates as a type of “government sanctioned censorship,” as it seeks to suppress speech by making it a crime to secretly videotape industrial feedlots and slaughterhouses for the purpose of exposing animal mistreatment and abuse. 

These laws criminalize investigative journalism and threaten a violator with imprisonment and fines of multiple the “economic loss” a farm suffers as a result of its abusive practices being made public.  Several have become law, but in striking down Idaho’s version, a Federal District Judge wrote that “food production is not a private matter,” [Case No. 1:14-cv-00104-BLW, USDC for the District of ID] and the activists’ undercover methods “actually advance core First Amendment [free speech] values by exposing misconduct to the public eye and facilitating dialogue on issues of considerable public interest.”

[4]  The essay does conclude that: “….feeding poultry litter to beef cattle, while a sound nutritional management option, carries with it certain stigmas that may cause beef consumers to become alarmed.”   Food Safety Advocates remind that both the excrement and uneaten pellets of chicken feed found in poultry litter can contain beef protein—including ground-up meat and bone meal—which means that cows could be, indirectly, eating each other.  The USDA has cautioned that meat and bone meal containing infected bovine protein is the principal vector for spreading bovine spongiform encephalopathy (BSE: “mad cow disease,” see, endnote #5, below).

The FDA temporarily banned feeding of poultry litter to beef cattle in 2003, but ruminant (beef cattle) protein was permitted to be fed to poultry.  To avoid the infectious agents of BSE being passed to beef cattle via spilled feed or manure, FDA mandated the removal of all “specified risk materials” from poultry diets.  In late 2005 poultry litter was re-approved as a feedstuff for beef cattle. 

Among the treatments used to kill pathogenic organisms in poultry litter are heat-processed pelleting, or deep stacking: piling litter in a 6- to 8-foot stack, where it undergoes a fermentation process, spontaneously heating to 130-160 degrees F.  In 2009, consumer and animal welfare groups petitioned the FDA to end the practice, noting bans already in place in Australia, New Zealand, Canada, and the European Union member states.  Citing a backlog of other petitions before the agency, FDA has still not responded to the document.

[5]  Bovine spongiform encephalopathy (BSE), commonly known as mad-cow disease (MCD).  A transmissible neurodegenerative disease with its infectious tissue most concentrated in central nervous system tissues of the brain, spinal cord, or digestive tract of animal carcasses.   The infectious agent—a specific type of misfolded protein called a prion, that creates deformed protein aggregates in an exponential cascade— is distinctive for the high temperatures at which it remains viable, over 1,112 °F.  Rendering, therefore, would ordinarily not serve as an effective “kill step.”  As a disease then, BSE offers fair evidence that cattle, which are normally herbivores (anatomically and physiologically adapted to eating plant material for the main component of its diet), have traditionally been fed the remains of other cattle in the form of meat and bone meal (MBM), a protein supplement in concentrated feeds.  

Since the discovery of mad cow disease in the US, federal officials have begun to restrict the parts of cattle that can be fed back to cattle.  However, most animals are still allowed to eat meat from their own species (rendered carcasses fed back to them); cattle can still be fed cow blood and certain “non-organ” parts.  Under current law, pigs, chickens, and turkeys that have been fed rendered cattle can be rendered and fed back to cattle—a loophole that belies assurances that our food chain is free from “mad cow” agents. 

The current “Feed Ban”, federal regulation 21CFR589.2000 allows for beef spines and brains to be included in animal and livestock feeds and pet foods. Legally, animal feed may contain rendered road kill, dead horses, and euthanized cats and dogs.  Rendered feathers, hair, skin, hooves, blood, and “intestines” may be used under categories of
“animal protein products.”

[09]  Mesnage, Renney, Séralini, Ward & Antoniou, Multiomics reveal non-alcoholic fatty liver disease in rats following chronic exposure to an ultra-low dose of Roundup herbicide: Scientific Reports 7, Art. #39328 (2017), doi:10.1038/srep39328.

[10]  Marwa, Okasha, Effect of genetically modified corn on the jejunal mucosa of adult male albino rat, Experimental and Toxicologic Pathology, Vol. 68, #10, Nov. 2016. 
 
[11]  Vendômois, Roullier, Cellier, and Séralini: A Comparison of the Effects of Three GM Corn Varieties on Mammalian Health; International Journal of Biological Sciences, 2009; 5(7): 706–726.

[12]  Samsel and Seneff, Glyphosate, Pathways to Modern Diseases IV: Cancer and Related Pathologies, Journal of Biological Physics and Chemistry, 15(3):121-159, Jan. 2015

[13] Dona A, Arvanitoyannis IS: Health risks of genetically modified foods; Crit Rev Food Sci Nutr. 2009 Feb;49(2):164-75. Also: de Vendômois JS, Roullier F, Cellier D, Séralini GE, A comparison of the effects of three GM corn varieties on mammalian health, Int J Biol Sci. 2009;5(7):706-726. Published 2009 Dec 10. doi:10.7150/ijbs.5.706. Also: Séralini, GE., Clair, E., Mesnage, R. et al, Republished study: long-term toxicity of a Roundup herbicide and a Roundup-tolerantgenetically modified maize, Environ Sci Eur26, 14 (2014).