Could Be Bad for the Future of Pet ‘Food’ – Truth about Pet Food
We have two government agencies with two VERY different perspectives on pet food. One agency – the FDA – regulates pet food as feed and openly allows the pet food industry to violate federal law. The other agency – the USDA – considers pet food as ‘food’ and holds products to the same quality and safety standards as food (for humans).
The problem for pet owners…pet food falls into the jurisdiction of FDA, the federal agency that allows pet food to violate federal law. But, at least for now, we have a voluntary certification program from the USDA for pet food, which requires pet food to be food, not feed. The devastating blow for pet owners is that USDA is considering eliminating this significantly important certification.
The USDA Food Safety Inspection Service (FSIS) recently announced they are “proposing to end the program under which FSIS inspectors provide fee-for-service certification that certain foods for dogs, cats and other carnivora (pet food) are produced under sanitary conditions and meet compositional and labeling requirements.”
Why does it matter if USDA ends their pet food certification program?
With the USDA pet food program, we (pet owners) have a federal agency that believes that pets deserve wholesome food, not leftover food waste. With the USDA pet food program, we have evidence within federal law that a federal agency holds pet foods to every aspect of law. With this USDA program we have hope. Click Here to read the requirements of the USDA certified pet food program.
With the USDA pet food program – at the very least pet owners have grounds to stand on. USDA doesn’t regulate pet food (pet food is not their jurisdiction), but we have a federal agency that would regulate pet food as food (not feed) should any company choose to go through the voluntary program. With the USDA pet food program, we have evidence that a federal agency CAN regulate pet food according to federal law.
To give pet owners an example of the dramatic differences between how FDA regulates pet food and how USDA regulates pet food…
| FDA definition of Poultry | USDA definition of Poultry |
| Poultry is the clean combination of flesh and skin with or without accompanying bone, derived from the parts or whole carcasses of slaughtered poultry, or a combination thereof, exclusive of feathers, heads, feet and viscera. It shall be suitable for use in animal food. |
Poultry means any domesticated bird slaughtered in accordance with the Poultry Products Inspection Act. |
The significant differences between the two definitions: the USDA requires pet food poultry ingredients (chicken, turkey) to be inspected and passed (the exact same requirement as human food). The FDA definition does not have any requirement to be inspected and passed, pet food chicken or turkey can be sourced from condemned animals. The same differences to quality are with every other ingredient too; USDA requires all ingredients to be food, the FDA allows any ingredient to be recycled waste.
Another example to the dramatic difference between how FDA regulates pet food and the high standards of USDA certified pet food is manufacturing requirements. The FDA did nothing about a Mars Petcare pet food plant that was infested with roaches. On the other hand, the USDA requires certified pet foods to be manufactured to human food safety standards (roach infestation would NOT be allowed).
Without the USDA pet food program, the ONLY thing we’ll have is FDA – who allows pet foods to violate federal law, allows pet food labels and websites to mislead pet owners, and partners with private organizations (AAFCO) to write pet food laws without opportunity for consumer input.
Why is USDA wanting to end their pet food certification program now?
The timing is a bit concerning to why the USDA is proposing to end their pet food certification program. With AAFCO recently proposing some concerning changes to human grade pet foods, it is possible that AAFCO and FDA needed the true human grade standards of USDA to be wiped from record. It’s not a stretch to believe AAFCO and FDA played a role to convince USDA to end their human grade pet food certification program, after all – we know AAFCO and FDA worked together to delete pet food safety laws that were promised to pet owners by Congress.
As well, the AAFCO and FDA human grade standards do NOT allow raw pet foods to make the human grade claim – even if they meet every requirement of the definition. The USDA pet food program doesn’t exclude any type/style of pet food as FDA does, if the product meets the requirement they are allowed to place the USDA inspected seal on the label.
The USDA announcement states they are wishing to end the pet food certification program because consumers are confused by two federal agencies regulating pet food (FDA and this voluntary USDA program). We find this claim hard to believe. Pet owners are well aware that FDA regulates pet food. We believe the confusion from pet owners is ‘how‘ FDA regulates pet food (such as allowing pet food to violate law).
The USDA also states they want to end their pet food certification program because of lack of interest from pet food manufacturers. And we believe we know why pet food manufacturers don’t have interest in the program…
The FDA and USDA have two different requirements for labels of pet foods. The FDA’s pet food labeling requirements are accepted by and enforced by each US state. The USDA pet food labeling requirements are NOT accepted by the states – which puts manufacturers that participate in the USDA program in between two different legal requirements. The simple fix is for the USDA program to work with FDA to make labeling requirements uniform between both agencies.
We are confident many pet food manufacturers – including raw pet food manufacturers that FDA does not allow to make a human grade claim – would utilize the USDA program if the labeling requirements could be uniform. Even more so, we are confident pet owners would benefit from pet foods displaying the USDA seal on labels – confirming the product is ‘food’ (not feed), and confirming the product meets every requirement of food law.
The USDA is accepting comments.
The USDA is accepting comments on their proposed elimination of the pet food certification program. Click Here to read what we submitted to the agency.
Pet owners are encouraged to provide comment to USDA by visiting the Regulations.gov website and clicking on the blue ‘Comment‘ button (upper left side of page). They need to hear from us, that we want and need the USDA program to continue. Pet owners can copy sections of our comment or simply tell the USDA you wish the agency to continue to regulate pet food – that we need a regulatory agency to regulate pet food as food, not feed.
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
Become a member of our pet food consumer Association. Association for Truth in Pet Food is a stakeholder organization representing the voice of pet food consumers at AAFCO and with FDA. Your membership helps representatives attend meetings and voice consumer concerns with regulatory authorities. Click Here to learn more.
What’s in Your Pet’s Food?
Is your dog or cat eating risk ingredients? Chinese imports? Petsumer Report tells the ‘rest of the story’ on over 5,000 cat foods, dog foods, and pet treats. 30 Day Satisfaction Guarantee. Click Here to preview Petsumer Report. www.PetsumerReport.com
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The 2021 List
Susan’s List of pet foods trusted to give her own pets. Click Here to learn more.
