AAFCO Explains Human Grade Changes – Truth about Pet Food

The following is an update for pet owners on the changes AAFCO appears to be making to Human Grade Pet Food. The meeting continues today and tomorrow (August 3 and 4, 2021), after it is complete we will provide all the details discussed. However this issue is so important, I felt pet owners deserved to know what is going on as quickly as possible.

For background information, read this post: Is AAFCO About To Destroy Human Grade Pet Food?

During the AAFCO Pet Food Committee session held Monday August 2, 2021, the committee was planning on discussing the new Human Grade Guideline document we shared yesterday. We were able to post the following comment in the webinar chat:

For the Pet Food Committee: pet owners and pet owner advocates have not had opportunity to see, review or provide comment on the new Human Grade Guidelines document. The new guidelines require a human food facility to register as a feed facility. Why? I would like explanation (to provide to consumers) why AAFCO is requiring a food facility to register as a feed facility. I ask that the guideline be tabled (removed from Model Bills) until consumers have opportunity to understand and comment.

Because AAFCO ignored comments I posted during the last webinar meeting (January 2021), I posted my comment early – ten minutes prior to the meeting beginning, giving the committee plenty of advance notice. Five minutes into the meeting there was a brief discussion about the Human Grade Pet Food Guideline document, then the AAFCO representatives asked “Are there any questions?”

Questions are taken first from AAFCO members, and then questions are allowed by attendees (those posted in the webinar chat). No AAFCO member had a question. The AAFCO Committee asked “Are there any questions in chat?” They responded “No“. They ignored my comment posted 15 minutes prior.

After they ignored my question, a representative from Purina posted a question/comment in the webinar chat (just under my comment) agreeing that the registration of a food facility as a feed facility is perhaps a conflict. I responded in the webinar chat to the Purina representative – thanking him, and stating “Perhaps they will listen to you.”

And it turns out AAFCO did listen to Purina. Only AFTER a representative from Purina questioned the dual registration of a human grade food facility, AAFCO addressed my question.

AAFCO stated the requirement is basically a paperwork issue. The human food facility is required to register with FDA acknowledging they manufacture an “animal food“.

Do you trust AAFCO’s explanation?

It could be true. The FDA requires all pet food manufacturing facilities to register with the agency. This is required to allow FDA to monitor pet products sold and have current contact information should a problem occur. This AAFCO change to requirements for Human Grade pet foods could simply be a written requirement for manufacturers to register with FDA.

But…

Pet food manufacturers are already required to register with FDA. Such as: example human grade pet food ABC Pet Food is manufactured in a licensed human food facility. ABC Pet Food is manufactured at XYZ Foods, a human food facility that is regulated by USDA (not FDA). ABC Pet Food is registered with FDA as a pet food company, XYZ Foods is registered with USDA as a food facility. All involved are properly registered with the proper regulating body. So why is AAFCO suddenly requiring the human food manufacturing facility to register with FDA (when the pet food company is already registered)?

The new Human Grade guidance document AAFCO wrote specifically states “All facilities that process or package a final “human grade” pet food product…must be registered as both an FDA food facility and an FDA feed facility.” AAFCO is requiring the actual food manufacturing facility – not the pet food company – to register as a feed facility.

AAFCO’s response doesn’t make sense (at least to me).

From my knowledge of a human food facility that is regulated by USDA, they would not be allowed (by USDA) to register as a “feed facility“. USDA and FDA don’t work well together (even though they should) and it is highly unlikely USDA officials would allow a food facility to be registered anywhere as a feed facility.

But, even if the USDA agreed to allow the food facility to register as a feed facility, the facility itself (such as XYZ Foods exampled above) would probably not agree to the feed registration. It is no simple task to get a food facility to agree to manufacture a pet food. The human food clients of a food facility aren’t happy their food is made along side of a pet food – not quite understanding a human grade pet food is no different than human food. Because pet food has historically been feed – food manufacturing plants have a perspective of pet food as being inferior to food. Some plants are beginning to understand human grade pet food is no different than human food, but only a handful of food manufacturing facilities understand this and allow a pet food to be made in their plant.

The potential for food facilities to refuse to register as a feed facility is high, which will result in human grade pet foods losing their ability to label their products as human grade (resulting in consumers not being provided with pertinent information on the label).

In advance of this AAFCO edit to human grade standards, AAFCO removed all consumer advocates from participation in ANY working group preventing consumer advocates from understanding what is behind the change. Also – in advance of this AAFCO edit to human grade standards, AAFCO removed the trade association that represents the largest number of human grade manufacturers preventing the manufacturers themselves from commenting and understanding the change.

Is this a simple registration issue, or is it a complicated issue with potential to destroy human grade pet food? We are left with – do we trust AAFCO? Because AAFCO intentionally keeps us out, intentionally refuses to include consumers – in my opinion, it’s difficult to trust the organization. I personally remain very concerned at what is behind AAFCO’s changes. That opinion could change – if AAFCO would ever allow consumers a voice and an opportunity to provide input. Until then, I remain skeptical.

The final vote on the document will take place Wednesday 8/4/21. We will update pet owners to the outcome.

Wishing you and your pet(s) the best,

Susan Thixton
Pet Food Safety Advocate
Author Buyer Beware, Co-Author Dinner PAWsible
TruthaboutPetFood.com
Association for Truth in Pet Food

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