Getting dogs to eat what they would otherwise never touch...

Getting dogs to eat what they would otherwise never touch...


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” and
       “Least Cost Mix” protocols

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.”

Misplaced faith...

Misplaced faith...


Recycling the Garbage...

“Least-cost resource mix”: the blend of energy sources and efficiency measures that produce the lowest total cost for delivering a product to consumers.

“Least-cost resource mix”: the blend of energy sources and efficiency measures that produce the lowest total cost for delivering a product to consumers.

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...




J. Cameron (pub.: Currier & Ives)

J. Cameron (pub.: Currier & Ives)


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.

poutry litter.jpg

what is
"poultry litter"?

Consumers are generally unaware that AAFCO defines as acceptable to be fed to cattle, dried “Poultry Litter,” or “a processed animal waste product composed of a processed combination of feces from commercial poultry together with litter that was present in the floor production of poultry…” 

Swept off floors of chicken cages and broiler houses, poultry litter is comprised of feces, feathers, and uneaten chicken feed, and additionally would contain pharmaceutical residues, heavy metals, pathogenic bacteria, and even dead rodents.

This is an environmentally sound choice, according to a report from the University of Missouri: “Large quantities of litter produced during modern poultry production are expensive to dispose of safely; moreover, protein is typically the most expensive ingredient in ruminant [cattle] diets. Feeding poultry litter is a means of disposing of a waste product while concurrently supplying a low-cost protein feed to beef cattle.”[4]

According to AAFCO “Standard Names and Definitions” animal waste in Poultry Litter must not contain “metal, glass (or) nails.”  “Hog hair,”as a similarly categorized by-product, is regarded the same way.

Unquestionably, these drugs, as well as the infectious or contagious pathogens that killed the food-source animals,[5] remain in their systems after slaughter.  When cattle die, regardless if from transmittable disease, there is typically no sterilization: tissues taken from corpses may carry anthrax, botulism, lockjaw, tuberculosis, salmonella, BSE (“mad cow disease”),[4] and other pathogens.

FDA allows these animal parts to be used in pet foods, assuming a “kill step” is undertaken (ordinarily through rendering) for regulatory non-compliance.  Rendering[1] is the process of boiling and separating fat that converts dead animals and animal parts that otherwise would be discarded into a variety of “value added” materials.  The rendering plants are “monitored” (not inspected) by USDA which requires them to add charcoal to ensure its segregation from the human food chain; henceforth labeled: “unfit for human consumption.”  And so we come to the pet food connection.


Rendering Plant Truck.jpg

"the goods"
at the

What does it take, to achieve the distinction of being categorized
with dis-honor as “by-product?”

The rubbish bin
of pet food “by-products”
(yes... rendered ingredients are
delivered to the factory in tanker
and dump trucks) represents the lowest
worth that can be assigned to an ingredient:
 nothing that has any minimal value will carry this
designation if it can be used elsewhere and yield more
profit.  In that circumstance, it would not end up as “by-product,”
but as something more specific: “chicken liver digest,” (hydrolyzed flavor
enhancer), “chicken broth,” etc.                                                                                  

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.

The leading dry food, Pedigree, has 5 separate grains, and its primary "meat" source is from unidentifiable animals ("meat and bone meal") reduced to a dry powder.

The leading dry food, Pedigree, has 5 separate grains, and its primary "meat" source is from unidentifiable animals ("meat and bone meal") reduced to a dry powder.

Commercialized "trencher feeding"

Commercialized "trencher feeding"

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.

Incestuous Relationships... 

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?

Supplies are delivered in dump trucks and tanker cars...

Supplies are delivered in dump trucks and tanker cars...

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. 


Manufactured "meat analogues"

colloidal suspension tools

Grinding and stabilizing agents

How to make a dog eat what he would otherwise never touch...

How to make a dog eat what he would otherwise never touch...

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.


maillard reaction products 

heterocyclic amines 

acrylamides  and mycotoxins 

Because recipes must anticipate aggressive vitamin losses from the extrusion process used in manufacture, and 50-80% antioxidant losses owing to temperature and pressure processes, two-dozen synthesized compounds may be sprayed on to redeem a “fully balanced” nutritional profile... based on poorly modeled (and outdated) industry-funded research. 

Of the four group categories (protein, carbohydrates, fat, fiber), the reality is that most grocery store brands are based on simple (not complex) carbohydrates derived from grain (often rancid: see, discussion below), sucrose and corn syrup (sugar), discarded fats and bulking agents (for cost control), or indigestible fibers (cellulose) such as sawdust, peanut hulls, hair, newspapers and cotton; all colored with (untested) dyes and masked by texturing agents such as propylene glycol (C3H8O2, a humectant: also used as a solvent).  Available proteins are commonly derived from bagged “meat meals” (dried products that are easy to transport, store, and mix), and may be preserved with ethoxyquin[6] (a carcinogen), which, in the case of “fish meal,” is required by federal law.


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. 

The chemical reaction between amino acids and reducing sugars

The chemical reaction between amino acids and reducing sugars

Maillard Reaction Products


Acrylamide (C3H5NO) was recognized in the mid-2000s by the World Health Organization as a major concern: a genotoxic, neurotoxic, carcinogenic chemical, given its ability to induce cancers and heritable damage at gene and chromosomal level, causing mutations in laboratory animals.  Research had shown that when certain foods were cooked at temperatures above 248 degrees Fahrenheit, acrylamide (also found in cigarette smoke) can form. 

Typical pet food (and livestock) formulations are highly-processed cereal and potato-based “least cost mix” carbohydrate recipes.  To overcome bacterial contamination that is inevitable when by-products are part of these recipes, pet food and animal feed manufacturers must (by law) high heat process multiple times: the material is then known as “rework.”  These are the ideal conditions to create even higher levels of acrylamides.  When potatoes are overcooked acrylamide levels can rise up to 20 times higher. 

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.

Apparatus to grind poultry feathers for "feather meal"

Apparatus to grind poultry feathers for "feather meal"

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.


toxic accumulation: dying young


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?  


Were You
Looking For? 


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.

Sidney Paget: Strand Magazine, Nov. 1903

Sidney Paget: Strand Magazine, Nov. 1903


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.



What does “Glycemic Load” Mean?

Glycemic Index is a measurement of the impact on elevation of blood sugar that a food causes.

Glycemic Index is a measurement of the impact on elevation of blood sugar that a food causes.

By necessity, dry foods are carbohydrate based: since the process to form the food into “kibble” is based on 40-45% of starches both as a durable (long-lasting) and cost saving device for manufacturers (known as “least cost mix”) and for providing low-moisture structural integrity: starch[10] and “by-product” “meals” (non-fresh: rendered to dry-powder meat or poultry products) are used as binders to “cement” the components of the food so that it can be pushed through an extruder and cut into appealing (to humans) shapes.

When your dog eats a large amount of starch or carbohydrates, it gets broken down into sugar in the body and her pancreas releases insulin to move the sugar in the blood into the body’s cells so that it can be metabolized.

Carbohydrates are the only food that causes a quick rise in blood sugar.  Glycemic load details the amount of carbohydrates a food contains and its glycemic index (GI), a measurement of its impact (speed and length of sustained elevation) on blood sugar. 

Low quality or starchy carbohydrates advance blood sugar level for long periods.  Over time, the dog will become insulin resistant (less sensitive to insulin), and to compensate, her pancreas may become exhausted: as it works harder to produce more and more insulin.  Today, consumer reliance on convenience dry kibble rooted in high-glycemic load starches (that cause blood glucose to spike and fat storage to increase) have become important factors associated with the growing epidemics in canine pancreatitis, diabetes, thyroid disease, obesity and cancers.  Moreover, high GI carbohydrates raise blood sugar levels quickly and they fall correspondingly fast… but then below where it started: causing a “crash.”  That drop below can lead to mental lethargy/confusion, fatigue, and even depression.



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


generally speaking... no

Pet food manufacture is a substantially unregulated industry.  Many US pet food companies are subsidiaries of multinational corporations that produce human food and personal care products.  Pet food manufacturing is attractive to modern agribusiness conglomerates, since the economies of scale in supply-chain metrics achieved through this diversification support effective profit objectives.[9] 

The trade association of pet food manufacturers, The Pet Food Institute (PFI), has recognized the use of “by-products" in pet foods as additional income for farmers, processors, and other food industries that prepare food for human consumption.  PFI argues for permission to use broad collective terms (example: “protein products”) that support “least cost mix” protocols and satisfy the parallel goal of lack of specificity in labeling.  The Institute is the lobbying group that drives the interests of the pet food manufacturing industry in Washington DC, as an “advocate for a transparent, science-based regulatory environment for our members.”  Funded by 98% of US pet food manufacturers, PFI can outspend the FDA at any time, and works to ensure that federal or state legislation that would impose more concentrated supervision on the industry does not pass: providing for “consumer choice.”

What does a so-called Official AAFCO Endorsement Really Mean? 

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.” 

reverse chemistry2.jpg

chemical analysis
as a substitute for a
"real life"
feeding trial?

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.”

Where's the real science in AAFCO standards?

Where's the real science in AAFCO standards?

So while it may provide minimum standards for the pet food industry, AAFCO’s “complete and balanced” designation is nearly useless for consumers, because there is no accessible science supporting it, and it doesn’t address the quality or source of ingredients, or how well a dog may be able to utilize the nutrients.  Of its two standards, “nutrient profile” simply cannot distinguish between foods or ingredients for digestibility (the ability of a food or ingredient to deliver essential nutrients) or bioavailability (the availability of a protein for absorption and utilization in metabolic process
of the body).

Bioavailability includes gastrointestinal (GI) digestion, absorption, metabolism, tissue distribution, and bioactivity.   As a key term for evaluating nutritional effectiveness, bioavailability refers to the fraction of the nutrient that is stored or being available in physiological functions.  This concern is perhaps most dramatic when referencing protein quality, which is impacted by the concentration and composition of essential amino acids, non-amino acid nitrogen (nucleic acids, amines, amides), and its profile for digestibility and bioavailability.  In this, amino acids must be digested (metabolized) and absorbed prior to leaving the small intestine, and not measured by “total tract digestibility.”

Carbohydrate guarantees are no longer considered as necessary or meaningful
for purchaser information, therefore,
their use is discouraged.
— AAFCO Annual Publication (2003, pg. 178)

Despite the impact that carbohydrate-loaded foods hold on pet health, The Official Publication of the AAFCO specifically discourages the use of the word “carbohydrate” anywhere on a pet food label, doubtless in deference to the importance of starches in modern, profit-driven manufacturing.

Examining the paradigm of globalized pet food manufacture today, with thousands of pets sickened, permanently debilitated, or killed by adulterated foods (with recalls continuing to this day), and absent meaningful responsibility taken by the industry, it’s fair to question the usefulness of AAFCO endorsement to the consumer. 

As a fair example of these standards, the ingredients list of one of the most popular convenience foods available, Beneful®, carries the claim:  “Animal feeding tests using Association of American Feed Control Officials (AAFCO) procedures substantiate that Beneful® Original dog food provides complete and balanced
nutrition for all life stages.”



Ever looked at a label? 
“... We do trash into cash...”


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:

In 2016 Purina changed the formula, in response to negative publicity regarding class-action lawsuits concerning a moisture-preserving additive, propylene glycol

In 2016 Purina changed the formula, in response to negative publicity regarding class-action lawsuits concerning a moisture-preserving additive, propylene glycol


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.

Called the "Twinkie diet," because it is so bereft of wholesome nutrition: feeding your beloved dog this food is comparable to feeding a child Twinkies at 2 out of 3 meals a day...

Called the "Twinkie diet," because it is so bereft of wholesome nutrition: feeding your beloved dog this food is comparable to feeding a child Twinkies at 2 out of 3 meals a day...

Despite the (deceptive) packaging emphasising meat: this is
an example of a plant-based food.  



Pesticides and mold inhibitors are needed in this popular food because the high carbohydrate/low protein grains used in dry dog foods are rejected for other uses, and are commonly beset with mycotoxins (toxins produced as waste products by fungus; see below).  Pet food grade grains are the “by-products” from flour mills.

Most dry dog food contains mill run flour, coming from the bottom of the storage elevator, comprised of broken kernels and fines (grains that break and crush: see: “brewers rice,” below).  The fines separate and settle during processing, and accumulate in high-concentration pockets within the screened storage apparatus.  Designated as the lowest-profit grain, it accordingly receives the lowest priority for handling.  This extended “set time” allows molds to grow (to feed) in these pockets of fines— which stay warmer and wetter in storage— because these carbohydrates are a preferred nutrient source of many fungi (parasitic plants that lack chlorophyll; unlike green plants, which use CO2 and light as sources of carbon and energy, fungi assimilate organic matter as substitutes). 

Grain weevil

Grain weevil

Consequently, the fines become an attractive food source and subsequent breeding environment for insects, particularly for those species which lack mouth parts for boring into whole grain kernels.  Being such, storage mites (arachnids) consume the molds/fungi that feed on low quality grain carbohydrates, and with a consistent food source, ultimately run their entire life cyle (and die) in the silo. 


Storage mites are comparatively resistent to cold, and can even survive freezing temperatures.  They can multiply quickly: among the species (red flour beetles, granary weevils, mice weevils, meal worms, flat grain beetles, Indian meal moths, and saw-tooth grain beetles as examples) a single female mite can lay between 400 and 1000 eggs. 

Studies estimate that 15% of the canine population suffers from atopic dermatitis (“allergies,” or inappropriate immune response, that manifest as skin disturbances), the most likely result from consumption of carcasses and excrement of storage mites in high-grain content dog foods.  Of those, the Acarus siro, Lepidoglyphus destructor, Blomia tropicalis, and Tyrophagus putrescentiae (mold mite) species are generally considered to present the biggest problem for “atopic dogs.”

Neiderlandish (ca. 1600): "Scratching Dog"

Neiderlandish (ca. 1600): "Scratching Dog"



“Brewers Rice”: an AAFCO-invented term
to deceive consumers

Consumers may be confused by terms which make grains sound better than they may in fact be.  Brewer's rice (used as a common protein source) sounds appealing to consumers, but is a by-product: simply broken or chipped rice; the small fragments of rice kernels that separate out from the larger kernels of milled rice.  As a final ingredient, it is a mixture of broken rice, rice bran, and rice germ.  Brewers rice and second heads are one of the many byproducts created by milling rice: second heads are milled rice kernels that are ½ - ¾ of the original kernel; while Brewers rice is a milled rice kernel that is ¼ - ½ the size of a full kernel. 

Second heads, if of acceptable quality, are used to make rice flour; but if the quality of the second heads are poor, they will be sold for pet food or dairy feed (Brewer's rice) as part of  “least cost mix” protocols.  It is a processed ingredient bereft of nutritional value that would be present in any rice.  The term Brewer's rice was created by the AAFCO (see: above), and it is sold exclusively for pet food and dairy feed.




To survive attack by stressors, fungi adapt to produce a wide range of toxins as protection from bacteria, viruses, or predators (such as storage mites).  Aflatoxins, ochratoxins, trichothecenes, zearalenone, fumonisins and fusaric acid have been found in the ingredients and final products of pet foods.  Mycotoxins (toxic secondary metabolites) are present in almost all grains (corn, wheat, rice, barley, oats, soybeans, peanuts, pearl millet, rice), and consumption of mycotoxins is essentially unavoidable if your dog eats grain-based food.   

More than acute (immediate) toxicity, mycotoxins suppress the entire canine immune system, and prolonged low-level exposure to these poisons contributes to  increased disease incidence, damage to vital body organs, interference with protein synthesis and reproductive capabilities, causes genotoxic mutations in DNA, anorexia, and ultimately, even cancer from (Tremorgenic) mycotoxicosis.  Exposure to a particular mycotoxin can be amplified by the synergistic activation that occurs when multiple mycotoxins are present, and aside from hepatoxicity (chemical driven liver damage) are carcinogenic (cancer causing).

Corn-based foods invariably contain fumonisins (Fusarium, Liseola section) leading to disturbed metabolism and cardiovascular dysfunction; and likely aflatoxins—mycotoxins produced by the Aspergillus flavus and Aspergillus paraciticus species of fungi that grow on certain crops—as peanuts are often used as protein in “diet” formulations and often contaminated with aflatoxins.  Wheat foods have vomitoxins (protein inhibitors which affect the central nervous system), also common in barley, oats, rye, maize, and sometimes, rice.  Repeated heat processing can form heterogenic amines[8] (carcinogens).

A 2003 survey (Lawrence Liverpool National Laboratory) found that virtually all commercial dry dog foods tested contained these substances; and hypothesized that there was a connection to cancer in animals consuming these foods (see: Kinze, Genetic Toxicology and Environmental Mutagenesis; 2003).

A 2007 report published in the International Journal of Food Microbiology suggests that chronic exposure to even low levels of these mycotoxins—such as would occur with daily feeding of grain-based dry foods—can cause serious health consequences to the dog.  Authors Boermans and Leung discuss that existing studies of mycotoxin contamination in pet food neglect the day-to-day consumption of small amounts of mycotoxins;  not “food poisoning” as we would expect, but resulting in “chronic diseases such as liver and kidney fibrosis, infections resulting from immuno-suppression and cancer.”[8]


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.

cellulose2 (2).jpg

Industrial waste
as dog food

Fiber in dog food is often cost-selected industrial waste, examples being beet pulp (a byproduct of sugar beet production (see: GMO production, immediately below); buckwheat and other grain hulls, flaxseed (rich in lignan precursors), fruit pectin, guar gum, oat bran, peanut shells, powdered cellulose (wood pulp, or: sawdust), psyllium (husks of the Plantago ovata plant’s seeds), and tomato pomace (leftover pulp from pressing tomatoes).

Processed commercial canine diets may well benefit from the addition of a small amount of appropriate fiber (example: from low glycemic vegetables), assuming it is a type that faithfully mimics the GI contents of small prey animals. However, modern dog foods often—if not generally—use industrial waste fiber as a part of “least cost mix” protocols as filler, which inhibits ordinary digestion (example: cellulose can deprive cells in the colon of butyrate, needed for energy production), and absorption of many vital nutrients.



GMOs and Hepatoxicity:


chemical driven liver damage


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 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.



Animal Euthanizing Drugs in dog food 



In 2018, 27 brands of canned dog foods were recalled due to contamination with pentobarbital, a drug used to euthanize animals.  This followed 2017 recalls that continued anew a lengthy Evanger's Pet Foods controversy after at least five dogs became sick and one died from eating pentobarbital-tainted canned foods.

Pentobarbital is a barbiturate, used to sedate and euthanize cats, dogs, and horses.  Because of the quantity (i.e.: cost) that would be needed, it is not used to euthanize cattle.

The 2018 recalls were scrambled after a Washington, DC-based newsroom submitted canned dog foods to an independent lab, which found that 60% tested positive for pentobarbitol.  The station forwarded the results to the FDA, along with a series of questions, including:  “Why is pentobarbital still a supply-chain issue? Its existence dates back at least to 1998 when veterinarians were reporting dogs and cats with resistance to the drug and the FDA found it in more than 53% of detectable samples.”  The FDA did not respond or acknowledge other questions regarding its compliance policies, which allow pet food manufacturers to violate federal law.

In the 1990s, veterinarians were unable to sedate animals  with serital as they had traditionally used for short term anesthesia.  Some speculated that dogs were getting enough pentobarbital through their food that they had become tolerant, which prompted the FDA to conduct  surveys of dry dog food brands in 1998 and 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.”

However, no enforcement actions were taken against the tainted brands, as the FDA described the amounts found to be below the threshold of causing immediate bodily effects.

To prevent condemned meat ingredients[1] from being rerouted and used for human consumption, FDA regulations require that the meat be “denatured” before it is removed from the slaughterhouse.  Denaturing can be done with carbolic acid (phenol, a potentially corrosive disinfectant) and/or creosote (used to preserve wood or as a disinfectant); and today, commonly charcoal.  According to federal meat inspection regulations, fuel oil, kerosene, crude carbolic acid, and citronella (an insect repellent made from lemon grass) are approved denaturing materials.  The denatured carcasses and other waste can then be transported to the rendering facility.

Even the FDA has acknowledged the presence of pentobarbital in modern pet foods, and “The (discussed testing) results indicated that the pentobarbital, or a closely related analogue, survived rendering without undergoing degradation” (Fate of sodium pentobarbital in rendered products (O’Connor, Stowe, and Robinson: American Journal of Veterinary Research, 1985 Aug;46(8):1721-4)).   


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).



George: eyes as a window... that reflect dreams...

George: eyes as a window... that reflect dreams...

[1]  Rendering is a process that converts waste animal tissue or by-products into stable, value-added materials.  It refers to processing of animal by-products into more useful substances, often the rendering of whole animal fatty tissue into purified fats (lard or tallow) or “tankage” that is used as a protein source in pet food (because “quality” for consumer identification is measured by protein level).  

Most tissue comes from slaughterhouses, but also includes expired meat from grocery stores (including the packaging, which would be too expensive to remove); road kill, the carcasses of euthanized and dead animals from animal shelters, zoos and veterinarians (the tissue further tainted with pentobarbital, the barbiturate used to kill the animal); distiller fermentation waste, rancid restaurant grease and butcher shop trimmings.  This material can include the fatty tissue, bones, and offal, or entire carcasses of animals condemned at slaughterhouses, and those that have died on farms, or collapsed in transit, etc., and their unborn fetuses.  


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.

Lucky: Surveying the skirmishes... the sherriff is back in town...

Lucky: Surveying the skirmishes... the sherriff is back in town...


[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.”


[3]  Factory farming refers to industrial farming processes of raising livestock in confinement at high stocking density, where a farm operates as a factory.  Confinement at high stocking density is one part of a systematic effort to produce the highest output at the lowest cost by relying on economies of scale, modern machinery, biotechnologies, and global supply trade metrics.  By nature, the crowded living conditions result in the spread of disease and pestilence, and necessitate mitigation through continuous administration of antibiotics and pesticides—which then become part of the food chain.  Selective breeding and administration of growth hormones are additionally used to stimulate swift livestock growth.  Food is supplied to livestock in place, and physical restraints are used to control movement or actions regarded as “undesirable”: typically within stalls too small for them to move or lie down for their entire lives.
Because of the lack of space and psychological stress of the environment, animals living in these conditions are often mutilated to prevent them from harming each other or becoming canibalistic, (among other events: chickens are de-beaked; pigs are castrated and cows tails are docked—without anesthesia—the latter of which furthers their daily misery as it prevents them from swatting away flies).  So common that it draws no notice, the animals often perform stereotypies, and display behavioral manifestations of insanity.

Documented film footage confirms that from birth to the day they are violently killed, these animals suffer lives filled with misery, deprivation, and abuse.

On the factory farm, mother cows are separated from calves shortly after they are born, so that the calves don’t drink their mothers’ milk.  In October of 2013, Newberry, MA police issued a statement to residents to quiet complaints about “strange noises” coming from a local dairy farm: the mother cows were mournfully crying out for their separated calves.  The police were informed by the farm operators that the cows were “not in distress” and that the events were a “normal function of a working dairy farm.”
Defenders of factory farming cynically use the animals themselves as “evidence” to deflect criticism of the brutality of “animal husbandry” techniques: that most appear to gain weight “proves” that they are not as stressed as critics claim, and that the meat should therefore be “healthy.”  However, being under stress is different from starving.  Even under these conditions or when openly abused by workers: the vast majority will still eat and will still grow and gain weight, since the feed is not one of their natural diet of grass, but grain with protein (melamine is known as a familiar source), vitamins and growth hormones designed to cause weight gain.
Stress to the animals is not an issue on the factory farm: profits are.  Carefully researched paradigms dictate the optimal point where the farm is crowded enough to be efficient, but not so much so that too many animals are dying from fighting, stress and disease.  That a factory farm is able to get livestock to eat and gain weight doesn’t impart that it is a humane place of business.  The large concentration of animals, animal waste, and the potential for dead animals in a small space poses ethical issues, and these techniques to sustain intense profit objectives are, while often culturally accepted as “necessary,” also recognized as inherently cruel.  Pollution and destruction of biodiversity are also cited as environmental concerns of these modern agribusiness practices.

Over the past decade, the animal-agriculture industry has been behind the introduction of “ag-gag” bills in more than half of all state legislatures across the country. These bills are designed to silence whistleblowers revealing animal abuses on industrial farms, by making photography or filming activity in these environments without owner consent illegal.  The 2018 version (2018 Farm Bill) of the Agricultural Act of 2014 (P.L. 113-79; 2014 farm bill) has been criticized as undermining a broad range of animal welfare protections, supporting industry efforts to invalidate individual state laws that seek to curb animal abuse and undermine consumer protection law, such as California's “Proposition 2.”

The National Pork Producers Council contributed: “NPPC opposes all forms of regulation... Livestock production practices should be left to those who are most informed about animal care: farmers... Additionally, changes in housing systems... should be driven by consumer purchasing decisions...” The National Assn. of Egg Farmers challenged the decision by McDonalds to seek “cage free” eggs, writing an “open letter” contesting the restaraunt's understanding that it would be humane to give chickens more room; and that giving the birds access to floors (instead of stacked wire “battery cages”) would be unsanitary.


[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.

Tonya: the "Princess"

Tonya: the "Princess"


[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.”


[6]  Ethoxyquin is a quinoline-based antioxidant used as a food preservative in certain countries and a pesticide or post-harvest fungicide for pears.  The FDA has approved the use of ethyoxyquin in animal feed and pet foods as a preservative in pet foods to prevent the rancidification of fats.  The US Coast Guard requires it to be used as a preservative during transport of fish meal, because it is so highly susceptible to oxidation that the volatile fatty acids may heat and spontaneously combust: perhaps setting ships on fire. 

Application level depends on the fat content: 400 parts per million (ppm) if the fish meal contains less than 12% fat, and 1,000 ppm if it contains more.  Naturally preserved meat meals cost more and are not as shelf-stable as artificially preserved meat meals, so absent specific declaration, a dog food containing fish meal would likely contain traces of ethoxyquin, even if that antioxidant does not appear on the ingredients list: as an undisclosed “secondary ingredient.”

[7]  Heat processing of commercial dog foods improves shelf life and kills pathogens.  However, heat treatment causes a reaction between the amino acids in proteins and sugars, known as the Maillard reaction (nonenzymatic browning reaction/color change, and a creation of new flavor compounds) which creates both beneficial and toxic Maillard reaction products (MRPs).  Among those MRPs are advanced glycation end-products or AGEs.  MRP-generated AGEs accumulate and contribute to the AGE pool in the body.  Studies have linked elevated levels of AGEs in tissues are associated with age-related diseases including diabetes, cataracts, osteoarthritis, atherosclerosis (fatty plaque deposits), renal disease, cardiovascular diseases and cancer.

See: O’Brien, Morrissey, & Ames: Nutritional and toxicological aspects of the Maillard browning reaction in foods, Critical Reviews in Food Science and Nutrition, Vol. 28, Issue 3, 1989; also: Van Nguyen: Toxicity of the AGEs generated from the Maillard reaction: on the relationship of food-AGEs and biological-AGEs, Molecular Nutrition & Food Research, Vol. 50, Issue 12, 2006; also:  Jägerstad M, Skog K. 2005. Genotoxicity of heat-processed foods. Mutation Research 574(1–2):156–172.

[8]  Acrylamides: (chemistry: noun) a colorless, odorless, toxic crystalline compound, C3H5NO, soluble in water, alcohol, and acetone: used in the synthesis of polyacrylamide and other organic materials, as textile fibers, in the processing of ore, and in the treatment of sewage.

Endotoxins are a lipopolysaccharide (LPS) complex found in the outer membrane of the cell wall of Gram-negative bacteria such as Escherichia coli and Salmonella.

Acute or chronic long-term exposure to endotoxins (particularly when the same brand or type of food is used continuously) can precipitate a cascade of adverse health consequences and may contribute to development of chronic degenerative diseases.  Endotoxins elicit strong immune response in dogs, triggering the release of histamine and inflammatory cytokines, change white blood cell numbers, affect blood coagulation, and lead to hypertension, arthritis, respiratory disease and organ failure.  Endotoxins are expected to damage cell DNA with carcinogenic consequences.  Carcinogenic heterocyclic amines and polycyclic aromatic hydrocarbons are formed when meat by-products from “4-D” animals is rendered, in order to destroy bacteria, so that it can be used in dog food.

[9]  Other significant producers include private label factories (making food for “house” brands such as Wal-Mart) and co-packers (large-scale manufacturers who procure ingredients and produce food pursuant to contract for pet food companies); the most notable are Doane Pet Care, Diamond, and Menu Foods; (all involved in pet food recalls that sickened, injured or killed thousands of domestic pets; see: Marion Nestle, Pet Food Politics).  Consumers have no information about these co-packers since they are not generally divulged on product labels.  Futher discussion on the important issue of co-packing in dog food manufacture is on page 2 of our essay on Dog Food Labeling. 


[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

Georgia: spider woman...

Georgia: spider woman...

I talk to him when I’m lonesome like, and I’m sure he understands. When he looks at me so attentively, and gently licks my hands; then he rubs his nose on my tailored clothes, but I never say naught thereat. For the Good Lord knows I can buy more clothes... but never a friend like that.
— W. Dayton Wedgeforth

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