Clooney_IMG 5053 (labels 2).jpg

Part Two:
Reading Labels
(learning the basics)

Dog guardians should know what is in the food
they are feeding their animals…

The dog food label contains a profusion of information... yet consumers rarely read it… and when they mean to, they often can’t get an accurate understanding of what it really says. Much of this information is “regulated”— but you’ll need to understand how that can be manipulated—and build 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.

The Battersea (UK) Home for Dogs in the 1920s

The Battersea (UK) Home for Dogs in the 1920s

Part 1 of this essay focused on important background issues: co-packing (contract manufacturing), lack of regulatory control, the USDA, FDA and the FTC’s role, the relevant federal regulatory acts, lobbyists and AAFCO dominance, how dog food manufacturers secure premarket clearance for untested products, the issue of by-products, ingredient splitting, and pet food nomenclature. 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).

It’s important to understand 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” ($125).

Requirements on a label: the
(“principal display panel” and “information panel”)

  1. Clearly identify the product as a dog or cat food;

  2. Present a brand name that is not misleading (evaluation includes ingredients and nutritional content);

  3. Display guarantee of the certain nutrients within the product;

  4. Display an ingredient list in descending order by weight: names of ingredients must be accepted by AAFCO or accepted as standard or in common use, and no single ingredient can be given
    undue emphasis;

  5. For products identified as “complete and balanced,” provide feeding instructions so that pet owners understand how much of the product to feed daily;

  6. Indicate how nutritional adequacy was determined if the product is “complete and balanced.” Companies should determine nutritional adequacy by sound “scientific” methods, such as chemical analysis or feeding “studies.”

FDA defines two areas of a dog food label, the principal display panel (PDP) and the information panel (sides and/or back). In this instance, the main ingredient is '‘soya bean meal.” and there are two “meat” ingredients from un-named sources, including “meat meal,” a mix of unidentified species.

FDA defines two areas of a dog food label, the principal display panel (PDP) and the information panel (sides and/or back). In this instance, the main ingredient is '‘soya bean meal.” and there are two “meat” ingredients from un-named sources, including “meat meal,” a mix of unidentified species.


Pet food manufacturers exploit that the product name may be the key factor in the consumer's decision to buy a product

Marketing teams are engaged to devise 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: the “95%,” “25% (or “Dinner”), “3%,” (or “with”), and “Flavor” rules.


“95%” Rule

Applies to products consisting primarily of meat, poultry or fish; most often, canned products (products with with simple names, i.e., “Salmon for Dogs,” are commonly labeled “for supplemental feeding” or “for intermittent feeding,” and may be
even higher).

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 in the finished product, 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 meat 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). 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.


“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 or Bites, 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; moreover that product need only contain 10% salmon in the finished product (remember: water added for processing). In fact, salmon as a costly ingredient, may be well down the ingredient list: this diet could contain chicken or other meat by-products.

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. In any event, absent an understanding of the use of by-products that may be collectively referred to at “beef,” you may be easily fooled.

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, including those of non-animal origin. So, a “Salmon & Rice Formula” (or “Salmon Dinner for Dogs”) would represent a suitable name provided there was more salmon in the product than rice (ordered by weight quantity), and the combined amounts of salmon and rice totaled 25%.

“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% (wet) 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” itself is open to manipulation.

“Flavor” Rule

Morgan Dennis, for the State Humane Office, Madison, WI

Morgan Dennis, for the State Humane Office, Madison, WI

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. “Flavor” as part of the name does not require any specific amounts of a product to be used, and “salmon flavor” can be made with broth or by-product meal.

As an explicit test method, using animals trained to prefer specific flavors, 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 characterizing flavor: such as grease, fish meal (likely, another less costly fish) or fish by-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 (fats: by-products and manufacturing waste) processed with heat (to stabilize rancidity), enzymes, and acids (thus: chemical and/or enzymatic hydrolys) to form concentrated “natural flavors.” Animal digest is used as a palatant, in order to camouflage other, less desirable flavors. Only a small amount of a “salmon (fish) digest” is needed to produce a “Salmon Flavored Dog Food,” even though no actual salmon (a costly ingredient) may be added to the food. Stocks (grease) or broths may be added. For example, 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 innumerable 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.

Bruce: emerging renewed, persevering, through life's blows...

Bruce: emerging renewed, persevering, through life's blows...



FDA regulations dictate the format, size and placement of the net quantity statement on the “principal display panel” of the package. This is important, since modern profit-driven manufacturing has caused many brands to creatively shrink packaging—or: reduce the fill line of cans or boxes—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. In parallel: many wet foods simply often seem to have so much water—as much as 87.5%—it’s become more than just the major ingredient, and in this instance seen here, the consumer is not ordinarily aware until the can is opened at home, and it’s fair to question this as “short weighting” (see: “Manufacturer’s Name and Address,” immediately below).

The moisture in this so-called “super premium” food (“Extraordinary Recipes… Exceptional Nutrition”) is so high, that the actual protein and nutrient profile may be less than cheaper products (also see, discussion below: “How to Properly Calculate and Compare Wet vs. Dry Foods”).

An example of short-weighting, likely a result of the co-packer canning the product at the “end of run,” by which it is flooded with water and “under filled,” if not by actual weight, at least according to what the consumer expected to purchase. Is this intentional, or not?

An example of short-weighting, likely a result of the co-packer canning the product at the “end of run,” by which it is flooded with water and “under filled,” if not by actual weight, at least according to what the consumer expected to purchase. Is this intentional, or not?



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).

Contract manufacturing:

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.

Co-packing allows the brand to achieve “cost effective agility” in its manufacturing, with “dedicated resources at every level of product development.” Co-packing arrangement as industry-standard business practice was not widely known by consumers until 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[12]—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, terminating its contract with American Nutrition Inc. (a sponsor of industry lobbyist Pet Food Institute), 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 ad hoc, or “at the moment,” based on continuously variable costs, with numerous opportunities for mischief, and beyond reach of US standards for oversight. Thus, 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 inadequate 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). Recalls in 2018 revealed co-packers had substituted horse tissues for cattle meat— which resulted in poisoning of dogs from pentobarbital used to euthanize the horses—while the “manufacturer,” (the brand) held seemingly little interest in incorporating oversight into their
contract arrangement.


so… what’s in
an address?

Troubled by the reality of substantially non-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 difficulty— if not impossibility—of appropriate oversight.

Consumers often misinterpret “bursts” on labels as applying to the product’s entirety: perhaps too trustingly, relying on one premium brand (highly Americanized name) labeled: “healthy & natural,” “grain free,” with “no gluten” and “no by-products”... not noticing that assurances of US-sourced ingredients are highlighted, this referring to certain meats only, while fish ingredients such as tuna may be sourced abroad, most commonly from China; and products themselves may be may be made outside of the US.

Troubled by the reality of substantially non-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 difficulty— if not impossibility—of appropriate oversight. Consumers often misinterpret “bursts” on labels as applying to the product’s entirety: perhaps too trustingly, relying on one premium brand (highly Americanized name) labeled: “healthy & natural,” “grain free,” with “no gluten” and “no by-products”... not noticing that assurances of US-sourced ingredients are highlighted, this referring to certain meats only, while fish ingredients such as tuna may be sourced abroad, most commonly from China; and products themselves may be may be made outside of the US.

Consumers are also victimized by use of vague and unspecific terms as “whitefish” (cod, hake, haddock and flounder),“ocean fish,” (Atlantic cod, whiting, haddock, mackerel, sardines), “redfish,” (snappers, slimeheads, roughies, and alfonsinos), and “Menhaden fish,” (mossbunker and bunker, herring); all of which are collectives for low cost bulk fillers.


Cost is a major factor in
“co-packing” Arrangements

Evangers Can IMG_1479 (2).JPG

as a
trade secret

It can be more cost-effective for a pet food company to “farm out” the production of its foods. This allows the brand to concentrate on it’s strengths: formulation and marketing. The identities and co-packing arrangements are ferociously guarded as industry “trade secrets,” by both parties. This is important to maintain “brand image,” including potential damage that might result from problem contracts with other manufacturers.

In 2018, subsequent to scandalous recalls, Markham, IL-based Evangers Dog and Cat Food Co., Inc. (that co-packs for other brands), changed it’s distinctive curved date stamp: because food safety advocates published essays describing it as a means to identify brands made by them. Among the issues, it became clear that while Evangers was making false “human-grade” claims about their own dog food, the company was in fact purchasing feed-grade ingredients, including from a dead livestock removal service that the company itself owned, and which may have been y the source of pentobarbital-laced horse meat that wound up in the dog food (see: “Animal Euthanizing Drugs in dog food,” here).

Co-packing shifts the costs of building, operating and maintaining a complicated pet food manufacturing facility to a third party, which holds the advantage of economies of scale (cost per unit of output decreasing with increasing scale of production). Quality control (QC) is assumed by the manufacturing facility according to brand specifications. QC can also include on-site visits from brand representatives, ongoing testing during stages of production and testing of the finished product.

Each brand remains responsible for the food produced by a co-packer: their name still goes on the bag even though they did not manufacture it. Pet food brands often use different co-packers for their dry and canned formulas, and, with proper instructions, oversight, and testing, this arrangement works well.

But often… it simply doesn’t. Complications may arise when, as dictated by “least cost mix” protocols, brands use multiple manufacturing plants for the same formula, or for dry or canned foods. Some of the larger pet food companies, as well as the larger co-packers, utilize multiple production plants, both domestically and overseas. This facilitates more efficient production and distribution in different regions of the US and globally.

Multiple production location facilities make date and batch codes even more significant. A recalled food produced in one plant may be removed; while the same formula, produced on the same day in a different location may be unaffected.

Teflon: anxiously awaiting a reunion…

Teflon: anxiously awaiting a reunion…


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 (pre-cooked). Water content is important when evaluating relative quantity claims, particularly comparing ingredients.

Why it’s important
to understand the importance of water…

Therefore, ingredients that appear at the top of an ingredient list —typically the main proteins, carbohydrates, and fat sources —are present in higher amounts by pre-cooked weight in the food than items at the bottom, such as vitamin and mineral supplements, flavoring agents, and preservatives for dry foods. Because water is included in the weight of the ingredients, ingredients with high water content (like meats and vegetables) are going to be listed higher than similar amounts of dry ingredients even though they may contribute fewer nutrients to the overall diet.

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 that the competitor's product has less animal-source protein than its own. This exploits research showing that consumers often shop by “the first ingredient rule,” and industry marketing departments likewise make it their “first rule” of advertising (see: “The Secret Practice of Ingredient Splitting”).

Fontaine des Innocents, place Joachim-du-Bellay, Paris

Fontaine des Innocents, place Joachim-du-Bellay, Paris

Chicken (or any listed meat) is the muscles. skin, and bones (and more) of chicken that have been ground together. The water content averages around 70%, and the product contains approximately 18% protein and 5% fat. If this same ground chicken is dried to a moisture level of 10% it is called “chicken meal.” The protein content is now 65% and the fat level is 12%. 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 that term. Understanding this, “first ingredient” claims should be ignored. In fact, “first ingredient” claims should fairly be regarded as intentionally misleading.

Thus, a consumer may favorably respond to a claim that their diet is better because it has chicken as the first ingredient and corn as the second; while a competing product lists corn as the first ingredient and “chicken meal” as the second ingredient. Chicken meal sounds processed (it is), but that does not necessarily discount its value as a protein source. Remember also that the word “fresh” carries no meaning.

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) seems to suggest otherwise.

Remember that “meat meal” “poultry meal” or “by-product (waste) meals” are not fresh, but dry rendered ingredients—dried powders—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.

Denaturing can contribute to development of food intolerance, inflammatory bowel disease, and generalized immune system response that can become inappropriate (allergies) 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 carefully planned shapes familiar to consumers as “kibble,” and is subsequently dried; fats ares then sprayed on as a “palatant”).

even More pet food nomenclature

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 (created and owned by AAFCO) 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).[13] 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 protein in pet foods.

Definitions... or not? What's Meat?

W. P. Snyder, Washington Market the Day Before Thanksgiving, Harpers Weekly, 1874

W. P. Snyder, Washington Market the Day Before Thanksgiving, Harpers Weekly, 1874

“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 de-fatted low temperature fatty tissue.”[14]

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.

For consumers, FDA definitions are vague to the extent of becoming meaningless: when “chicken” is listed on a label ingredient panel, it can be USDA inspected and passed chicken, USDA inspected and condemned chicken, “whole” chicken, chicken bones (absent meat), chicken skin (absent meat) and more.

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.


It's Not Safe... Then it Is...

see speak hear2.jpg

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.[15] 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.

Shell Games

“The Transformation!”

“The Transformation!”

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.

The practice, known as “ingredient splitting,” is discussed on the first page of this essay; see: “The Secret Practice of Ingredient Splitting.”)

Likewise, consumers should 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.

MSG (monosodium glutamate: the sodium salt of glutamate) is ubiquitous in many prepared foods. But as common as the flavour enhancer is, MSG can cause troubles for humans and pets alike. It is used to make up for the lack of flavour (or camouflage unpleasant ones) in low-quality ingredients.

Aside from being nutritionally unnecessary, MSG has been identified as a common allergen in dogs, which may be related to secondary metabolites (carcinogenic residues) and excitotoxins (amino acids that overstimulate neuron receptors in the brain) that can be produced when it combines with raw materials or is synthesized through heat processing (necessary to kill pathogens in by-products).

MSG can be identified as a “natural flavor” merely if it has been extracted from a natural source as opposed to synthesized entirely in a laboratory from scratch. Manufacturers are permitted to consider these natural flavors proprietary, and are not required to disclose exactly what is used to make the flavoring nor how it is actually made (i.e., via a
chemical process).


msg and diacetyl:
the great

According to AAFCO, a “natural ingredient” is merely one that is derived from “plant, animal or mined sources… A feed ingredient can be subject to a number of commonly-used processes during the manufacturing process and still be deemed natural”; and “A feed or feed ingredient can contain trace amounts of chemically synthetic compounds and still be
considered natural.”

While MSG (or diacetyl) by law doesn't have to appear on pet food ingredient labels, you can often find it in these ambiguous ingredients: hydrolyzed protein, hydrolyzed protein, protein isolate, texturized protein, natural flavors (like “chicken flavor”), autolyzed yeast, hydrolyzed yeast, yeast extracts, soy extracts or concentrate, sodium caseinate, calcium caseinate, monopotassium glutamate, glutamate or glutanic acid, disodium inosinate or guaylate. Manufacturers contend that this vague terminology is necessary to protect proprietary tastes and smells.

Fiona: a luminating brightness in a fading late-afternoon sun…

Fiona: a luminating brightness in a fading late-afternoon sun…

“Guaranteed Analysis” 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.


Some nutrients are listed as percentages and some as milligrams per kilogram, dependent upon how much the nutrient itself weighs. Protein and fat are macronutrients, technically larger and heavier than micronutrients (minerals). Thus, they are listed as percentages: the protein and fat content are each a percentage of the total weight of the food. So, if the protein minimum is 23% and the fat minimum is 12%, it means the two together will make up 35% percent of the food’s weight. By contrast, minerals or vitamins weigh so little that the percentage of each would be well below 1 percent, and calculating by percentage would be difficult for manufacturers to ensure that they meet regulations. For that reason, they are given as milligrams (or International Units, a nutritional measure of certain vitamins and minerals) per kilogram of food.

Protein, fat, and fiber are measured as “crude.” This is allowed because determining the amount of protein directly would be an expensive, complicated assay due to the fact that protein is a mixture of long chain amino acids rather than just one thing (protein in human food is measured the same way).

“Crude” measurements, however, only indicate the amounts of nutrients present based on certain analytical (laboratory) 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 bio-availability (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, after combustion) 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.


How to Properly Calculate and Compare
Wet vs. Dry Foods:
(Easier than You Think)

Using dry matter (simply discounting the moisture) will allow you to compare protein, fiber and fat levels “on the same playing field.” To calculate is not difficult: you need to divide the protein by the total dry matter.

The dry matter percentage of the product is 100% minus the percentage of moisture captioned on the “guaranteed analysis” part of the label. Then, 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 (that is: 25% dry matter); while a dry food contains 27% crude protein and 10% moisture (or 90% dry matter).

Although it looks like the dry food has more “crude protein,” when the products are compared on equal footing (dry matter basis), the canned food actually has more (32% vs. 30% for the bagged food).

Although it looks like the dry food has more “crude protein,” when the products are compared on equal footing (dry matter basis), the canned food actually has more (32% vs. 30% for the bagged food).

At first glance, the dry food appears to have much more protein than the canned food. But when compared on “dry matter” basis, the bagged food has less protein (30% vs. 32% for the canned product).

At first glance, the dry food appears to have much more protein than the canned food. But when compared on “dry matter” basis, the bagged food has less protein (30% vs. 32% for the canned product).

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).

What’s the real source
of the protein?

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.

Baxter: catch-me-if-you-can!

Baxter: catch-me-if-you-can!


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.[16]

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 laboratory 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”; (See: “The Minimal Standards of an AAFCO Feeding Trial”).

The AAFCO nutrient level standard for “Complete and Balanced” dog foods are stipulated per 1,000 kcal (calories). That means: for each 1,000 kcal of dog food in your bag or can, AAFCO requires specific minimums of protein, fat, and certain vitamins and minerals. AAFCO regulations are the same for every adult dog, regardless if the dog is high activity (requiring more calories a day) or if the dog is low activity (requiring
less calories a day).


Feeding directions instruct the consumer on how much product should be offered to the dog. Minimally, 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.


Although 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 to compare products 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 recipes that are reconfigured to have higher levels of indigestible fiber substituting for calories in a given quantity of food. The fiber is often wood pulp (sawdust) but labeled “cellulose.” Cellulose is a cheap binder, emulsifier, anti-caking agent, and can be used in diet foods to resemble fats. Extending a food in this way would necessitate altering additives, so that the nutrient profile remained constant across the new, less calorie-dense recipe; 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.

1950s Ken-L-Ration advertising

1950s Ken-L-Ration advertising


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 on human food labels; while 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.

“Unqualified” Claims

AAFCO certification concerns nutrient claims. “Quality” as a descriptive term is not identified by AAFCO, and in its Official Publication, (AAFCO Regulation PF7 Nutritional Adequacy) pet food labels may include “an unqualified claim, either directly or indirectly,” without the need to be backed by any scientific data. These claims are “advertising puffery,” or: statements that consumers would know are not meant to be taken literally.

In fact, AAFCO rules would prohibit a manufacturer who used ingredients to the standard for humans (USDA inspected and approved: instead of feed grade meat that can include meat that’s expired, diseased or contaminated with drugs) to caption them as such in the ingredient list of a product: (AAFCO Regulation PF5 requiring that “[a] reference to quality or grade of the ingredient does not appear in the ingredient statement.” AAFCO thus makes it illegal for the highest-quality pet food manufacturers to differentiate their ingredients from those of poorer quality on the label. Clearly, this regulation protects the interests of companies that use lower-quality ingredients.

The FDA, in its regulatory role, works to ensure that a food is safe, free of contaminants, and truthfully labeled. 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 consumers should be especially vigilant when considering the true value 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.

“Structure-Function” Claims: UN-naturally “Natural”?

The term “natural” is often used on dog food labels as an especially potent marketing tool, although it has no official definition, and is substantially meaningless. AAFCO stipulates that “natural” only means an ingredient that is not subject to a chemically synthetic process.

According to the FDA: “From a food science perspective, it is difficult to define a food product that is ‘natural’ because the food has probably been processed and is no longer the product of the earth. That said, FDA has not developed a definition for use of the term natural or its derivatives. However, the agency has not objected to the use of the term if the food does not contain added color, artificial flavors, or synthetic substances.”


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, amending the 1938 Federal Food, Drug, and Cosmetic 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.[17]

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.

artificial Monster soup commonly called Thames water, being a correct representation of that precious stuff doled out to us!circa 1828. Credit British Museum. (3).jpg

artificial ingredients

Of three kinds:

1) artificial
2) artificial
coloring, and
3) artificial

Artificial flavoring is rarely used to make dog food, because those words would be noticed by the alert consumer, and, regulatory loopholes offer alternatives to the necessity of using such terms.

Artificial colors are added to dog foods solely as a marketing decision: so that the food can mimic the appearance of “quality” ingredients so that they may appeal to consumer expectations. Most commonly, they are used to color and texture ingredients so that they have the appearance of meat; (see discussion: “Turning Trash into Cash…” on page 1 of this essay); the most common being textured vegetable protein (TVP).

Dog foods may need to sit on store shelves for months or even years. Preservatives can be either natural… or artificial. Natural preservatives are usually made from anti-oxidants… like vitamins C or E. Consumers 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 differ, adding a notable risk of toxicity to any dog food; but they destroy beneficial gut bacteria the dog may already have. Consumers should question the presence of these additives, and assume the choice is made owing to “least cost mix” protocols. An example: the humecant (moisture preservative) propylene glycol is a common (cost effective) preservative in dry foods; (see above: “It's Not Safe... Then it Is...”). 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). BHT can also be found in cosmetics, pharmaceuticals, jet fuels, rubber, petroleum products, electrical transformer oil and embalming fluid.

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. Sadly, many dog guardians serve up these chemicals at every meal over their dog’s lifetime.

It’s important to acknowledge synthetic vitamins present the same issues as “artificial” preservatives in that they are not bioavailable, and the dog must expend energy to digest them with no benefit.


“Animal Fat” is Just Another Commodity…

Edward Gorey

Edward Gorey

According to AAFCO: “Animal fat is obtained from the tissues of mammals and/or poultry in the commercial process of rendering…” (2012: § 9.3, 288). During the rendering process, fat is obtained by grinding and cooking by-products (waste from other agribusiness processes) and euthanized animals, including the bodies of dogs and cats retrieved from veterinary facilities, (in 2007, the advocacy group Last Chance For Animals posted a video taken at a Vernon, CA rendering facility documenting the corrupt practices of pet food renderers, described by researcher Keith Woods, a researcher with The San Francisco Chronicle, that had been published in 1990 in The Earth Island Journal after the Chronicle and subsequently the ABC Television network refused to publish the story).

Today, pet food manufacturers vigorously deny that euthanized dogs and cats are used in pet foods—essentially, cannibalism in the pet food industry—however, the two largest companies that pick up carcasses from shelters and clinics, D&D Disposal Inc. and Koefran, Inc., are both owned by rendering companies (the aforementioned West Coast Rendering [Vernon, CA] and Reno Rendering [Reno, NV], respectively). (To understand the process of rendering, see: What’s Really in Pet Food?, discussion, and, also in detail: footnote #1 on that page).

The fat that rises to the top of the rendered mix (“hot soup”) becomes “animal fat” (when there is an unidentified mix of species); or “beef fat” (when only cattle), or “chicken fat” (when only chicken). Animal fats, therefore, are by-products of processing by-products.

Subsequent to this process, when the fat is removed, the remains become meat and bone meal or beef/chicken meal pet food ingredients: ingredients identified by FDA as most commonly associated with euthanized animals, which would be how pentobarbital would enter the commodities market of pet food supply in 2018, becoming the focus of recalls of food co-packed by Evangers Dog & Cat Food Co. (See the pages: What’s Really in Pet Food; FDA (Non)Compliance Policies; and the first page of this essay, Dog Food Labels, Overview
and Concerns

Rendering companies describe the business as both financially and ecologically important: “We’re a large tissue sterilization plant. That’s the purpose we serve. Incineration of animals is cost-prohibitive, and constrained by air pollution regulations. You can’t bury this much decomposing animal matter. The cookers take in four to five tons of material. Over 4 hours we bring that material to 265 degrees Fahrenheit and hold it there for 30 minutes. The material is then deemed sterile, free from animal pathogens, and goes through several more steps until the product looks like dry coffee grinds. This is called dry rendered tankage. It’s very high in protein, 61-62%... this process completely dehydrates the original material, reducing its volume and mass.” [18]

The Conundrum of Carrageenan?

Carrageenan is an additive used as a thickener and emulsifier (a stabilizer: as a gelling agent, preventing moist processed ingredient components from separating, as they bind to food proteins), in nearly three quarters of canned dog and cat foods. It is extracted with alkali from a combination of red seaweed (Rhodophyceae, Chondrus crispus) and red algal species. Essentially, carraggeenan is used as a substitute for fat.


Carrageenans are highly sulfated polysaccharides: non-nutritive carbohydrates such as starch, cellulose, or glycogen, whose molecules themselves consist of bonded sugar molecules with different molecular structures. There are differing types, which vary in solubility and ability to bind and form gels under different conditions; and are generally classified by weight, with “food grade” carrageenans being “high molecular weight.” Food-grade carrageenan is classified by viscosity, but the inflammatory, “low molecular weight” type poligeenan is still present in varying percentages, and exposure to the processes of digestion (heat, acid, digestive enzymes, and bacteria) increases the detectable amount of poligeenan (it can be absorbed).

One review also suggests that there may be no substantial difference between “food-grade” (undegraded) and degraded carrageenan, since the latter is present in the former, perhaps
as much as 25%.

A 2013 report from The Cornucopia Institute described that “Degraded carrageenan [poligeenan] is such a potent inflammatory agent that scientists routinely use it to induce inflammation and other disease in laboratory animals, to test anti-inflammation drugs and other pharmaceuticals.”

The report, further updated in 2016, discusses that, for decades, peer-reviewed research (including publicly funded scientific literature) has demonstrated that carrageenan increases presence of free radicals, (toxic byproducts of oxygen metabolism that can cause significant damage to living cells and tissues in a process known as oxidative stress), disrupts insulin metabolism, and, because they are recognized as invaders, trigger an immune response that induces inflammation, a precursor to degenerative joint diseases, and cancers.

In particular: provoking changes in the gut microbiome—where 70% of the dog’s immune system resides—contributing to development of inflammatory bowel disease (IBD), ulcerations, bloating, glucose intolerance, and development of food allergies (inappropriate immune response). Carrageenan interrupts a homeostatic signaling pathway that contributes to colon carcinogenesis. Because of the potential of chronic inflammation as a root cause of many serious diseases, and because it could easily be replaced by safer alternatives (such as guar gum, locust bean gum and xanthan gum), consumers should question its presence in the
ingredients list of a dog food.

Upon its five-year review in 2012, Cornucopia supported a 2008 citizen petition by Dr. Joanne Tobacman, which requested the removal of carrageenan from the FDA’s list of approved organic food additives. A Chicago Tribune investigative reporter, writing about the coordinated industry effort to discredit public research, challenged the FDA to offer a single scientific study not funded by the carrageenan industry to support its denial of the petition. However, the FDA did not respond, and rejected the petition.

In 2016, The National Organic Standards Board (NOSB), which advises the U.S. Department of Agriculture (USDA) on rules for the organic industry, voted to ban carrageenan from “organic” food. Corporate agribusiness lobbyists (representing carrageenan manufacturers and food processors), continue to pressure the FDA, and the NOSB evidence is disputed by its funded scientists, who claim that they could not replicate the 2008 laboratory results. The FDA, as well as the European Commission and the World Health Organization (WHO), continue to maintain that carrageenan is safe.


The Food Safety Modernization Act of 2011

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. FSMA aims to ensure the U.S. food supply is safe by shifting the focus of federal regulators from responding to contamination to preventing it.

Expected to influence the general environment is the growing criticism 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 the Denver, CO plant of Kasel Associated Industries, 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. This may be subsequent to a Prehearing Order to Cease Distribution and Give Notice, or a “423(a),” the “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.

Hazard Analysis Critical Control Point

Part of the bill is the requirement for Hazard Analysis and Critical Control Point (HACCP), which is discussed in an industry website,, as creating “apprehension” among manufacturers concerned about the economic impact of implementing HACCP in their plants. Its seems fair to criticize that even despite the 2007 recalls, the pet food industry does not have such a plan already in place, as part of ordinary business practice.

Its also worth noting the contradiction: while the Pet Food Institute—the industry’s aggressive lobbying arm with the US Congress—claims that “Pet food products are among the most highly regulated products in grocery stores,” those in the business acknowledge otherwise, and finally: in print. In the October, 2010 pet food industry publication EXtru-Technician (a publication focused on extrusion form manufacturing of pet food pellet/kibble), an article provides manufacturers details for establishing their HACCP plans: “it is important to remember that currently there is no legislation for safety in the petfood processing industry. FDA simply states now that petfood suppliers must produce Salmonella-free products.”

This seminar will help you prepare for ... and survive... an FDA inspection...
— Pet Food Industry Magazine press release, 2011

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 US$1,700 paid attendees), stating that: “they” (the manufacturers, ingredient suppliers, and importers) “are very protected.” So while consumers support the industry (US$29.88B in 2017, in the US), the industry is reluctant to reveal to consumers what goes on inside, where exhibitors at the Forum speak about what buyers of their products are feeding their animals.

Miranda: a coy and serene presence

Miranda: a coy and serene presence


(These numbers continue from the previous page of this essay):

[12] 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 accumulating 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 Veterinary Information Network estimated that 30,000 to 50,000 animals were affected. Based on reports received by the FDA (with acknowledged underreporting), the US Attorney’s Office identified deaths of 1,950 cats and 2,200 dogs.

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 intentionally delaying notification to consumers for months. 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.

[13] 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.

[14] 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.” Despite this, in 2015, Mars Inc. had to defend its Pedigree dry food, admitting that the “wires” consumers were complaining about were actually pig hair, and arguing that they were nutritious and that dogs liked eating them; (in 2018, consumers complained about metal shards in the same product).

[15] 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.

[16] In October of 2018, the US District Court in St. Louis sentenced two companies, the Feed Division of Wilbur-Ellis Co. (San Francisco) and Diversified Ingredients (Ballwin, MO), to pay combined fine of $7 million for shipping adulterated and misbranded pet food ingredients to pet food manufacturers. In April, Wilbur-Ellis pleaded guilty to one misdemeanor count of introducing adulterated food into interstate commerce. Diversified Ingredients, Inc., a commodities broker, merchandiser, and distributor, pleaded guilty in July to one misdemeanor count of introducing adulterated food into interstate commerce and one misdemeanor count of introducing misbranded food into interstate commerce.

“Chicken meal” and “turkey meal” dog food ingredients shipped from a Wilbur-Ellis facility in Rosser, TX were adulterated and misbranded through the use of cheaper substitute ingredients, such as feather meal and feed grade chicken bone by-product meal, and adulterated and misbranded by omitting premium ingredients, such as turkey meal, from products identified as turkey meal.

The complaints arose from the 2014 suit filed by Nestlé Purina against Blue Buffalo Co., Ltd. for false and misleading advertising: “Through Blue Buffalo’s advertising and promotional efforts in which it advocates its products as made with “only the finest natural ingredients” and free from “less than desirable” ingredients such as chicken/poultry by-product meals, corn, and preservatives, Blue Buffalo has become a pet food brand that consumers have come to associate—falsely—with very high, “ultra-premium healthy” pet food,” (4:14-cv-00859).

Within days, Blue Buffalo counter-sued Purina with a false and misleading advertising lawsuit. The dispute evolved into multiple lawsuits including a consumer class action lawsuit that resulted in a $32 million dollar settlement, and eventually, the criminal charges with fines and penalties.

While it may appear that the FDA recognized the importance of preserving the integrity of the food supply for animals, the reality is that it is not illegal to feed dogs pets feathers and bones (waste of human food industry)…the companies were disciplined only only they did not disclose feathers and bones were in the ingredients. As such, the ingredients were not properly labeled, and are termed “misbranded” thereby, and “misbranded” pet foods are, by definition, “adulterated.” The interests of consumers—being denied reasonable access to definitions of dog food products (they are owned by AAFCO)—were not a concern of the court.

[17] Marion Nestle, Pet Food Politics (The Chihuahua in the Coal Mine), 163, Univ. of CA Press, 2008.

[18] Ted Kerasote, Pukka’s Promise, “Should Wolves Eat Corn?” 199, Houghton Mifflin Harcourt, 2013; also (among others), National Renderers Association, Disposal (Rendering) of Deceased Animals from Los Angeles Country Animal Shelters, Fact Sheet, April 8, 2004.

N.B.: This essay is written for informational purposes. We are not medically trained, nor legal experts. 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 or sourcing 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.

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...
Lily: ever calm and patient, content to wait in turn…

Lily: ever calm and patient, content to wait in turn…

“… 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)

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