This year, it appears as if the mosquitos are finally taking over. At least down here in Florida, I thought initially. But with record sales of pesticides at the on-line store it looks like the problem is all over the country. Related to this, the American Heartworm Society continues to remind pet owners of heartworm risk. Here is an example of their official campaign letter:
“As temperatures grow warmer, the American Heartworm Society (AHS) wants every pet owner to be prepared for mosquito season and the heartworm disease risk it carries for pets.
Although the risk of heartworm disease is heightened in warmer months when the mosquito population increases, the AHS recommends year round prevention for both dogs and cats. By giving heartworm prevention every month, forgetful pet owners will have their pets protected when they need it most.
"Surveys show only about 75 percent of pets are given the full dosage recommended by a veterinarian," Sheldon Rubin, DVM, AHS president and Chicago practitioner, said. "With year-round prevention, if doses are accidentally skipped, the drug is still effective."
Recently, researchers discovered that respiratory signs in cats, which are often diagnosed as feline asthma or allergic bronchitis, may actually be caused by the presence of heartworms in either larval or adult stages. The acronym "HARD" is the term for this clinical presentation and stands for Heartworm Associated Respiratory Disease. Heartworm preventive medications are the only option for cats, as there is no approved treatment for feline heartworm disease.
Heartworm disease treatments are available for dogs, but treating for heartworms is much more costly and dangerous to the animal than simply preventing it. Yet another reason to use year-round prevention is that many heartworm preventives also have activity against other intestinal and common parasites, such as roundworms and fleas.
Options for preventing heartworm infection in both dogs and cats include daily and monthly tablets and chewables as well as monthly topicals. These methods are effective, easy to administer and inexpensive. These medications interrupt heartworm development before larvae and adult worms reach the lungs and cause disease. When administered properly and on a timely schedule, heartworm infection can be prevented.
The American Heartworm Societyis the global resource for the prevention, diagnosis and treatment of heartworm disease. It was formed during the Heartworm Symposium of 1974. The American Heartworm Society stimulates and financially supports research, which furthers knowledge and understanding of the disease. Its headquarters are located in Batavia, Ill.”
Heartworm disease is a serious and potentially fatal condition caused by parasitic worms living in the arteries of the lungs and occasionally in the right side of the heart of dogs, cats and other species of mammals, including wolves, foxes, ferrets, sea lions and (in rare instances) humans. Heartworms are classified as nematodes (roundworms) and are filarids, one of many species of roundworms. Dogs and cats of any age or breed are susceptible to infection.
The American Heartworm Society together with the American Association of Feline Practitioners and Pfizer Animal Health has made it one of its priorities to educate and alert cat owners of this serious problem.
“Countless cat owners throughout the United States are misinformed about feline heartworm disease, posing serious risk to their feline friends. Cats may be misdiagnosed with feline asthma, or test negative for heartworm antigens and antibodies but still have heartworms in their systems. Now, due to new research, veterinarians recognize this infectious agent is doing a whole lot more damage than previously thought.
The KNOW Heartworms campaign is a public awareness campaign sponsored by the American Heartworm Society (AHS) and the American Association of Feline Practitioners (AAFP), and funded by an educational grant from Pfizer Animal Health. The program stresses the importance of understanding the five myths and misunderstandings about feline heartworm disease:
1. Dogs vs. Cats: Heartworm is not just a canine disease, and it affects cats differently than dogs.
2. Indoor vs. Outdoor Cats: Heartworm disease is mosquito-borne and evidence has shown indoor cats are just as susceptible to it as outdoor animals. In a North Carolina study, 28 percent of the cats diagnosed with heartworm were inside-only cats.
3. It's a Heart Disease: “Heartworm disease” is a misnomer; it mostly affects the lungs, not just the heart. The disease frequently is mistaken for asthma and other respiratory diseases.
4. Adult Heartworms vs. Larvae: New research shows that heartworm larvae at all stages, not just adult worms, can cause serious health problems.
5. Diagnosis: Accurate diagnosis can be difficult, since negative antigen and antibody tests don’t automatically rule out the presence of heartworms.
Feline Heartworm Disease
Heartworm infection takes place when a mosquito carrying infective, microscopic-size heartworm larvae, bites into a cat for a blood meal. The larvae then actively migrate into the new host and develop further as they travel through the subcutaneous tissue in the cat's body. At about 3-4 months, they usually settle into the arteries and blood vessels of the lungs, where they continue to develop to sexual mature male and female worms (Dirofilaria immitis). The average time from when the microscopic parasites enter the host until the females develop into mature worms and produce offspring is approximately eight months and is referred to as the prepatent period. This is about one month longer than in dogs.
As adults, the heartworms can mate and the females can release offspring called microfilariae (pronounced: micro-fil-ar-ee-a) into the blood stream. The cycle begins again when a mosquito takes a blood meal from the newly infected cat and draws the microfilariae into its system.
Cats are resistant hosts of heartworms, and microfilaremia, (the presence of heartworm offspring in the blood of the host animal), is uncommon (usually less than 20% of cases). When present, microfilaremia is inconsistent and short-lived. Some cats appear to be able to rid themselves of the infection spontaneously. It is assumed that such cats may have developed a strong immune response to the heartworms, which causes the death of the parasites. These heartworms may die as a result of an inability to thrive within a given cat's body.
Cats typically have fewer and smaller worms than dogs and the life span of worms is shorter, approximately two to three years, compared to five to seven years in dogs. In experimental infections of heartworm larvae in cats, the percentage of worms developing into the adult stage is low (0% to 25%) compared to dogs (40% to 90%).
However, heartworms do not need to develop into adults to cause significant pulmonary damage in cats, and consequences can still be very serious when cats are infected by mosquitoes carrying heartworm larvae. Newly arriving worms and the subsequent death of most of these same worms can result in acute pulmonary inflammation response and lung injury. This initial phase is often misdiagnosed as asthma or allergic bronchitis but in actuality is part of a syndrome now known as Heartworm Associated Respiratory Disease (HARD).
Which Cats Are Susceptible?
Although outdoor cats are at greater risk of being infected, a relatively high percentage of cats considered by their owners to be totally indoor pets also become infected. Overall, the distribution of feline heartworm infection in the United States seems to parallel that of dogs but with lower total numbers. There is no predictable age in cats for becoming infected with heartworms. Cases have been reported in cats from nine months to 17 years of age, the average being four years at diagnosis or death.
Clinical Signs
The clinical signs of heartworm infection in cats can be very non-specific, and may mimic many other feline diseases. Diagnosis by clinical signs alone is nearly impossible, but a cat may exhibit generic signs of illness, such as vomiting intermittently (food or foam, usually unrelated to eating), lethargy, anorexia (lack of appetite), weight loss, coughing, asthma-like signs (intermittent difficulty in breathing, panting, open-mouthed breathing), gagging, difficulty breathing (dyspnea) or rapid breathing (tachypnea).
Signs associated the first stage of heartworm disease, when the heartworms enter a blood vessel and are carried to the pulmonary arteries, are often misdiagnosed as asthma or allergic bronchitis, when in fact they are actually due to a syndrome newly defined as Heartworm Associated Respiratory Disease (HARD).
Some cats exhibit acute clinical signs, with disease often related to the organs where the adult heartworms are thriving. Occasionally such infected cats die quickly without allowing sufficient time to make a diagnosis or offer appropriate treatment.
Diagnosis
Heartworm infection in cats is harder to diagnose than it is in dogs and it is easy to overlook. Diagnostic tests have limitations, so negative test results do not necessarily rule out an infection. Antigen tests, for example, only detect adult female or dying male worms. Immature or male-only worm infections are rarely detected.
The diagnostic plan for heartworm disease in cats can include, but is not limited to, a physical examination, radiography (X-ray), echocardiography (ultrasound readings of the heart), angiocardiography (X-ray of the heart with injected contrast fluid), CBC (complete blood count), serologic testing (antigen and antibody study), microfilaria testing, and necropsy (after death).
Physical Examination
The results of a physical examination may appear to be perfectly normal in cats infected with heartworms. Harsh lung sounds are a frequent abnormal finding and may be present in cats without any respiratory signs. The presence of a heart murmur or abnormal rhythm is uncommon. Only rarely, have there been reports of ascites (fluid in the abdomen), exercise intolerance and signs of right-sided heart failure. In cats, the primary response to the presence of heartworms occurs in the lungs.
Treatments
Currently, there are no products in the United States approved for the treatment of feline heartworm infection. Most cats with heartworm infection that are not demonstrating clinical signs are allowed the time for a spontaneous cure to occur. If there is evidence of disease in the lungs and their blood vessels consistent with feline heartworm infection, such cases (possibly in the early stage) can be monitored with chest X-rays every six to twelve months as needed. Supportive therapy with small, gradually decreasing doses of prednisone (a cortisone-like drug) is recommended for cats with radiographic or clinical evidence of lung disease.
Cats with severe manifestations of feline heartworm disease may require additional supportive therapy, and may benefit from intravenous fluids, oxygen therapy, cage confinement, bronchodilators (which expand the air passages of the lungs), cardiovascular drugs, antibiotics and nursing care.
Heartworm extraction with various surgical devices has been performed in cats in which the worms can be visualized with ultrasound at the tricuspid valve or in the right atrium (of the heart), and especially in those rare instances of caval syndrome (obstruction of blood flow affecting the heart and the liver.
Preventives
It is generally recommended that all cats be tested for both antigens and antibodies (serology) prior to administration of a heartworm preventive. There are four heartworm disease preventive products approved by the FDA for use in cats, (see your vet for details). All of these products are considered effective in preventing the development of adult heartworms when administered properly on a monthly basis relative to the period of transmission.”
Covering the same topic, however with emphasis on latest scientific research, Veterinary Practice News recently published an article on feline heartworms. In it, Gary D. Norsworthy, DVM, Dipl. ABVP (feline) who owns and practices at Alamo Feline Health Center in San Antonio, Texas and also frequently speaks about cat health at veterinary conferences and seminar, reports of a study performed at Auburn University which has shown a new side of feline heartworms. This study, performed with financial backing from Pfizer Animal Health in NY, came to the following conclusions:
“Life CycleWhen a mosquito bites a cat, larvae (L3 stage) are deposited on the cat’s skin. Within minutes they enter the subcutaneous tissue through the bite wound. The L3 molt within a couple of days to fourth stage larvae.
L4 migrate subcutaneously in fat and muscle for two months, then molt to become a juvenile or immature adult worm. Immature adult worms enter circulation via a peripheral vein. This occurs about 60 days after infection. An antibody response begins about this time; some cats test antibody positive.
Within the next 15 to 30 days, 75 to 90 days post infection, the immature adult worms arrive in the pulmonary arteries. The vast majority of the juvenile worms die, are carried by blood flow into the lungs and cause an intense inflammatory response affecting the pulmonary arterioles, bronchi and alveoli.
It is estimated that about 3 to 4 percent of the immature adults become 6 inch long adult heartworms and live for two to four years before dying spontaneously.
HARD
Heartworm associated respiratory disease, or HARD, is unique to the cat. It is defined as vascular, airway and interstitial lung lesions caused by the death of immature adult worms, and the inflammation may last up to eight months.
The study revealed: If 100 infective larvae are administered to a dog, 75 will mature to adults. If 100 infective larvae are administered to a cat, many will become immature adult heartworms; however, only three to four will mature to adults. A very large number of immature adult worms develop but never make it to adulthood due to the effects of the cat’s immune system. Severe lung lesions are present but:
No adult worms will be present on necropsy. The immature adult worms disintegrate within the lung tissue and are very difficult to find on necropsy. Antibodies disappear very quickly. Antigen tests will be negative because there have been no adults. Radiographically, these cats may look similar to cats with allergic bronchitis. Interstitial or bronchial patterns may be present, and the caudal pulmonary arteries may be enlarged and blunted. In some cats, apparent enlargement may be due to periarterial inflammation. Repeated exposure to immature adult heartworms results in severe interstitial and bronchial disease.”
It is no wonder that this disease has eluded detection until we learned of the results of this study.
Let’s recap, in summary the 3 important points are:
1. By about three months post infection, 2 inch long immature adult heartworms are in the pulmonary arteries. .
2. Most of these are killed by the immune system, never becoming adult heartworms. They are carried by blood flow into the lungs..
3. About 3 percent to 4 percent of the immature adults become 6 inch long adult heartworms.
Dr. Norsworthy continues:
“For every 10 heartworm-infected dogs in a given locale, one cat has adult heartworms. However, it is likely that only about 10 percent of heartworm-infected cats have an adult worm. That makes the exposure and infection rates of dogs and cats about the same.
Heartworm Testing
Antibody Tests: Antibodies are produced by the presence of immature adults, and they begin to wane as the immature adult worms die. If the immature adult worms mature to adults, the adult worms suppress the immune system, causing antibodies to dissipate. Most antibody tests turn negative about four months later as long as new infections do not occur. A positive antibody test means one or more of these possibilities: A current infection with late L4.; a current infection with immature adult heartworms, a current infection with adult heartworms; a previous heartworm infection. Antibody persists about four months.
Many cats with HARD are antibody positive and antigen negative. However, many test negative on both antigen and antibody tests, making differentiation from cats with allergic bronchitis virtually impossible.
Antigen Tests: A positive antigen test means (one or both): One or more adult female heartworms and/or one or more dying adult female heartworms.
Heartworm tests are inclusionary, not exclusionary. If they are positive, they are meaningful. If they are negative, they are not meaningful.
Antigen or antibody testing is not necessary to begin heartworm prevention because there is not a reaction between current heartworm prevention products and any stage of the heartworm.
Microfilaria Testing: In contrast to dogs, very few microfilaria circulate in cats. This test has very poor sensitivity in cats. This also explains why cats are very poor reservoirs for heartworm infections to other cats or to dogs.
Summary
Positive antibody test: This cat is or has been infected with heartworms that progressed at least to the immature adult stage. It is clearly at risk of future infections
Positive antigen test: This cat is infected with adult heartworms. It is clearly at risk of future infections.
Microfilaria testing: This test has a very poor diagnostic yield.
Most cats with HARD have mild coughing, but a severe respiratory crisis can occur when a large number of immature adult heartworms die at once. These cats should be placed on a heartworm preventive product to prevent new infections.”
I know, it all sounds very scientific and can be very confusing. However, this is a topic I really want every cat owner to become familiar with. You need to know about this, heartworm is a serious problem you don’t want your pet to suffer from and have to go through the lengthy, painful treatment. What kind of surprises me is that how seemingly little we know or knew about this problem related to felines. The best site to find more details and kind of easy to understand info including graphical illustrations is the one of the American Heartworm Society. Besides background info, the site features a lot of downloadable materials (for free) and even features an educational section “Just for Kids”.
Showing posts with label FDA. Show all posts
Showing posts with label FDA. Show all posts
Monday, June 29, 2009
Thursday, June 25, 2009
Pet Food Labels 101: Product Name
Pet food labeling is regulated at two levels. The Federal regulations, enforced by the FDA's Center for Veterinary Medicine (CVM), establish standards applicable for all animal feeds: proper identification of product, net quantity statement, manufacturer's address, and proper listing of ingredients. Some States also enforce their own labeling regulations. Many of these have adopted the model pet food regulations established by the Association of American Feed Control Officials (AAFCO). These regulations are more specific in nature, covering aspects of labeling such as the product name, the guaranteed analysis, the nutritional adequacy statement, feeding directions, and calorie statements.
The product name is the first part of the label noticed by the consumer, and can be a key factor in the consumer's decision to buy the product. For that reason, manufacturers often use fanciful names or other techniques to emphasize a particular aspect. Since many consumers purchase a product 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%" rule applies to products consisting primarily of meat, poultry or fish, such as some of the canned products. They have simple names, such as "Beef for Dogs" or "Tuna Cat Food." In these examples, at least 95% of the product must be the named ingredient (beef or tuna, respectively), not counting the water added for processing and "condiments." Counting the added water, the named ingredient still must comprise 70% of the product. Since ingredient lists must be declared in the proper order of predominance by weight, "beef" or "tuna" should be the first ingredient listed, followed often by water, and then other components such as vitamins and minerals. If the name includes a combination of ingredients, such as "Chicken 'n Liver Dog Food," the two together must comprise 95% of the total weight. The first ingredient named in the product name must be the one of higher predominance in the product. For example, the product could not be named "Lobster and Salmon for Cats" if there is more salmon than lobster in the product. 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. For example, a "Lamb and Rice Dog Food" would be misnamed unless the product was comprised of at least 95% lamb.
The "25%" or "dinner" rule applies to many canned and dry products. If the named ingredients comprise at least 25% of the product (not counting the water for processing), but less than 95%, the name must include a qualifying descriptive term, such as "Beef Dinner for Dogs." Many descriptors other than "dinner" are used, however. "Platter," "entree," "nuggets" and "formula" are just a few examples. Because, in this example, only one-quarter of the product must be beef, it would most likely be found third or fourth on the ingredient list. Since the primary ingredient is not always the named ingredient, and may in fact be an ingredient that is not desired, the ingredient list should always be checked before purchase. For example, a cat owner may have learned from his or her finicky feline to avoid buying products with fish in it, since the cat doesn't like fish. However, a "Chicken Formula Cat Food" may not always be the best choice, since some "chicken formulas" may indeed contain fish, and sometimes may contain even more fish than chicken. A quick check of the ingredient list would avert this mistake.
If more than one ingredient is included in a "dinner" name, they must total 25% and be listed in the same order as found on the ingredient list. Each named ingredient must be at least 3% of the total, too. Therefore, "Chicken n' Fish Dinner Cat Food" must have 25% chicken and fish combined, and at least 3% fish. Also, unlike the "95%" rule, this rule applies to all ingredients, whether of animal origin or not. For example, a "Lamb and Rice Formula for Cats" would be an acceptable name as long as the amounts of lamb and rice combined totaled 25%.
The "3%" or "with" rule was originally intended to apply only to ingredients highlighted on the principal display panel, but outside the product name, in order to allow manufacturers to point out the presence of minor ingredients that were not added in sufficient quantity to merit a "dinner" claim. For example, a "Cheese Dinner," with 25% cheese, would not be feasible or economical to produce, but either a "Beef Dinner for Dogs" or "Chicken Formula Cat Food" could include a side burst "with cheese" if at least 3% cheese is added. Recent amendments to the AAFCO model regulations now allow use of the term "with" as part of the product name, too, such as "Dog Food With Beef" or "Cat Food With Chicken." Now, even a minor change in the wording of the name has a dramatic impact on the minimum amount of the named ingredient required, e.g., a can of "Cat Food With Tuna" could be confused with a can of "Tuna Cat Food," but, whereas the latter example must contain at least 95% tuna, the first needs only 3%. Therefore, the consumer must read labels carefully before purchase to ensure that the desired product is obtained.
Under the "flavor" rule, a specific percentage is not required, but a product must contain an amount sufficient to be able to be detected. There are specific test methods, using animals trained to prefer specific flavors, that can be used to confirm this claim. In the example of "Beef Flavor Dog Food," the word "flavor" must appear on the label in the same size, style and color as the word "beef." The corresponding ingredient may be beef, but more often it is another substance that will give the characterizing flavor, such as beef meal or beef by-products.
With respect to flavors, pet foods often contain "digests," which are materials treated with heat, enzymes and/or acids to form concentrated natural flavors. Only a small amount of a "chicken digest" is needed to produce a "Chicken Flavored Cat Food," even though no actual chicken is added to the food. Stocks or broths are also occasionally added. Whey is often used to add a milk flavor. Often labels will bear a claim of "no artificial flavors." Actually, artificial flavors are rarely used in pet foods. The major exception to that would be artificial smoke or bacon flavors, which are added to some treats.
Pet owners and veterinary professionals have a right to know what they are feeding their animals. The pet food label contains a wealth of information, if one knows how to read it. Do not be swayed by the many marketing gimmicks or eye catching claims. If there is a question about the product, contact the manufacturer or ask an appropriate regulatory agency.
Source: FDA Animal & Veterinary Resources Pet Food Labels - General Consumer information provided by David A. Dzanis, DVM, Ph.D., DACVN.
The product name is the first part of the label noticed by the consumer, and can be a key factor in the consumer's decision to buy the product. For that reason, manufacturers often use fanciful names or other techniques to emphasize a particular aspect. Since many consumers purchase a product 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%" rule applies to products consisting primarily of meat, poultry or fish, such as some of the canned products. They have simple names, such as "Beef for Dogs" or "Tuna Cat Food." In these examples, at least 95% of the product must be the named ingredient (beef or tuna, respectively), not counting the water added for processing and "condiments." Counting the added water, the named ingredient still must comprise 70% of the product. Since ingredient lists must be declared in the proper order of predominance by weight, "beef" or "tuna" should be the first ingredient listed, followed often by water, and then other components such as vitamins and minerals. If the name includes a combination of ingredients, such as "Chicken 'n Liver Dog Food," the two together must comprise 95% of the total weight. The first ingredient named in the product name must be the one of higher predominance in the product. For example, the product could not be named "Lobster and Salmon for Cats" if there is more salmon than lobster in the product. 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. For example, a "Lamb and Rice Dog Food" would be misnamed unless the product was comprised of at least 95% lamb.
The "25%" or "dinner" rule applies to many canned and dry products. If the named ingredients comprise at least 25% of the product (not counting the water for processing), but less than 95%, the name must include a qualifying descriptive term, such as "Beef Dinner for Dogs." Many descriptors other than "dinner" are used, however. "Platter," "entree," "nuggets" and "formula" are just a few examples. Because, in this example, only one-quarter of the product must be beef, it would most likely be found third or fourth on the ingredient list. Since the primary ingredient is not always the named ingredient, and may in fact be an ingredient that is not desired, the ingredient list should always be checked before purchase. For example, a cat owner may have learned from his or her finicky feline to avoid buying products with fish in it, since the cat doesn't like fish. However, a "Chicken Formula Cat Food" may not always be the best choice, since some "chicken formulas" may indeed contain fish, and sometimes may contain even more fish than chicken. A quick check of the ingredient list would avert this mistake.
If more than one ingredient is included in a "dinner" name, they must total 25% and be listed in the same order as found on the ingredient list. Each named ingredient must be at least 3% of the total, too. Therefore, "Chicken n' Fish Dinner Cat Food" must have 25% chicken and fish combined, and at least 3% fish. Also, unlike the "95%" rule, this rule applies to all ingredients, whether of animal origin or not. For example, a "Lamb and Rice Formula for Cats" would be an acceptable name as long as the amounts of lamb and rice combined totaled 25%.
The "3%" or "with" rule was originally intended to apply only to ingredients highlighted on the principal display panel, but outside the product name, in order to allow manufacturers to point out the presence of minor ingredients that were not added in sufficient quantity to merit a "dinner" claim. For example, a "Cheese Dinner," with 25% cheese, would not be feasible or economical to produce, but either a "Beef Dinner for Dogs" or "Chicken Formula Cat Food" could include a side burst "with cheese" if at least 3% cheese is added. Recent amendments to the AAFCO model regulations now allow use of the term "with" as part of the product name, too, such as "Dog Food With Beef" or "Cat Food With Chicken." Now, even a minor change in the wording of the name has a dramatic impact on the minimum amount of the named ingredient required, e.g., a can of "Cat Food With Tuna" could be confused with a can of "Tuna Cat Food," but, whereas the latter example must contain at least 95% tuna, the first needs only 3%. Therefore, the consumer must read labels carefully before purchase to ensure that the desired product is obtained.
Under the "flavor" rule, a specific percentage is not required, but a product must contain an amount sufficient to be able to be detected. There are specific test methods, using animals trained to prefer specific flavors, that can be used to confirm this claim. In the example of "Beef Flavor Dog Food," the word "flavor" must appear on the label in the same size, style and color as the word "beef." The corresponding ingredient may be beef, but more often it is another substance that will give the characterizing flavor, such as beef meal or beef by-products.
With respect to flavors, pet foods often contain "digests," which are materials treated with heat, enzymes and/or acids to form concentrated natural flavors. Only a small amount of a "chicken digest" is needed to produce a "Chicken Flavored Cat Food," even though no actual chicken is added to the food. Stocks or broths are also occasionally added. Whey is often used to add a milk flavor. Often labels will bear a claim of "no artificial flavors." Actually, artificial flavors are rarely used in pet foods. The major exception to that would be artificial smoke or bacon flavors, which are added to some treats.
Pet owners and veterinary professionals have a right to know what they are feeding their animals. The pet food label contains a wealth of information, if one knows how to read it. Do not be swayed by the many marketing gimmicks or eye catching claims. If there is a question about the product, contact the manufacturer or ask an appropriate regulatory agency.
Source: FDA Animal & Veterinary Resources Pet Food Labels - General Consumer information provided by David A. Dzanis, DVM, Ph.D., DACVN.
Sunday, June 21, 2009
Natural irradiation?
Towards the end of last year there were reports about some problems Champion Pet Foods with its Orijen brand was having in Australia. I reported in great detail on this in various comments on this blog (Pet Food Recalls: Does the pet food industry require federal watch dogs? and Glowing pet food? Irradiation applied to pet food); we also mentioned the issue with a warning in our RECALL ALERT (though there was NO recall here in the States).
Since then not a day goes by without an inquiry from concerned pet owners about the issue of food irradiation.
In case you don’t recall, back then, the Orijen was found to be the only link between a strange illness that paralyzed cats with the unfortunate outcome that the animals had to be euthanized. To bring everybody up to speed, here is what (in Australia only) had transpired in a summary background provided by Orijen: “On November 20, 2008, Champion Pet Foods announced a voluntary recall of its Orijen Cat food brand sold in Australia. The recall is restricted to Australia ….. was issued in response to reports from the Australian veterinary community of cats showing symptoms of a neurological syndrome after consuming Orijen cat food. To prevent the risk of cats eating Orijen dog foods and becoming ill Champion ceased the sale of Orijen dog foods in Australia. The recall was unique to Australia and did not affect any of the other 50 countries to which Orijen is exported. Champion Pet Foods believes the Australian cases resulted from the high-level irradiation (exceeding 50kGY) applied to Orijen upon entering Australia. This high-level irradiation procedure for is unique to Australia and Orijen foods are not irradiated in any other market or country. Champion Pet Foods no longer exports or sells its Orijen pet foods in Australia.”Susan Thixton of the Truth About Pet Foods.com, back then when it all came to light, spoke with Orijen. On her website she shared the conversation she had with an Orijen representative:“The only reports of sick cats (or any pets) have been in Australia. All pet foods shipped into Australia must be irradiated, treated with radiation, before they are sold. Orijen has no control over this, this is a mandated issue from the government of Australia. Orijen has sent two samples of the irradiated food, along with non irradiated food from the same batch to two separate University testing laboratories. It is not sure if an answer for the illnesses will be found in these tests, however it should provide a wealth of information regarding effects of irradiation of foods.” Note: Those results were subsequently posted on Orijen’s website at www.championpetfoods.com. Susan then continued: “Orijen told me they feel the irradiation is the concern. Although this is frightening for already frightened pet owners, at this point I am in agreement that the irradiation is the concern. Food is irradiated, treated with radiation, to kill bacteria and molds. In the process, much more is destroyed. Not only is the nutrition destroyed, but far more research than the FDA lets on to, tells us much more damage can occur. Irradiation breaks chemical bonds, and it is suspect that broken chemical bonds within foods containing numerous ingredients (a pet food) can alter the entire ‘food’ in many ways. “
As a subsequent measure the Australian government went to work about the problem. Most recently on 06/01/09, Veterinary Practice News reported under “Australia Bans Pet Food Irradiation”:
“Australia has banned the government-mandated practice of irradiating imported pet food, the Sydney Morning Herald reported. The ban comes after a number of cats died or became ill after eating irradiated cat food manufactured by the Canadian company, Champion Petfoods Ltd.
The Australian Minister for Agriculture, Fisheries and Forestry, Tony Burke, has ordered the sterilization process to cease immediately after receiving international reports that some cats can suffer neurological damage from eating irradiated dry food, according to the Herald. Details on the reports were not immediately available. …"
Sorry, that the introduction to today’s comment became a little lengthy, however it was necessary to understand my thought process. I recently found an article in Pet Food Industry.com, a print and on-line publication for pet food professionals. Written by David A.Dzanis, DVM, PhD, DACVN, the title is “Is irradiation of petfoods natural? AAFCO definition fails to address whether an irradiated product is considered natural. A recent letter from FDA to the chair of the AAFCO Pet Food Committee opines it currently does not.” Her is what he had to say:
‘”In 2001, the US Food and Drug Administration (FDA) approved a petition broadening the use of irradiation of animal feeds to include petfoods, treats and chews. That same year, the Association of American Feed Control Officials (AAFCO) accepted the feed term "natural" and established guidelines concerning its use on petfood labels. Because these two independent matters were in development during the same period, the AAFCO definition fails to address whether an irradiated product is considered natural. A recent letter from FDA to the chair of the AAFCO Pet Food Committee opines it currently does not.”
Then, many of you will like his explanation of irradiation much better than my original, boring and lengthy rocket scientist approach (Glowing pet food? Irradiation applied to pet food). Mr. Dzanis explains: “What is irradiation?
Under FDA regulations, ionizing radiation can be from either of two origins:
X-rays generated from machine sources; or
Gamma rays emitted during radioactive decay of radionuclides.
The former are the result of energy shifts in orbiting electrons of molecules, while the latter come from energy shifts within the nuclei of atoms. Other than their origins, though, the two types of radiation are virtually indistinguishable from each other, as the range of wavelengths used to define one versus the other largely overlap.
In neither case does the food incorporate or come in direct contact with radioactive material, nor is there a chemically synthetic step to the process.
The approved purpose of irradiation of pet foods is for microbial disinfection, control or elimination. While not intended as a replacement for other appropriate sanitation measures, it gives the manufacturer another weapon in the arsenal against potential microbial contamination. Irradiation may be more suitable for some types of pet products compared to others, but considering the heightened concern regarding pet food safety today, all manufacturers should consider it a potential means to address safety issues.”
And here comes what really matters to me today: “Natural or not?
There are many different ways to interpret "natural," which led to wide misuse of the term on pet food labels in the past. To help provide consistency in meaning and a basis to uniformly interpret use of the term, AAFCO defined it to differentiate products and ingredients in terms of their sources and processing methods. For example, natural products or ingredients must be of animal, plant or mined sources but can be ground, cooked, dried, rendered, purified, extracted, hydrolyzed or even fermented.
The key factor in determining the applicability of the term is that anything that is manufactured by means of chemical synthesis or contains a chemically synthetic substance is not natural (at least not without further qualification, such as with a pet food containing synthetic vitamins but otherwise meeting the definition).
Of course, not all people would necessarily agree with this definition. For example, many consumers would not consider chicken meal, wheat middlings, sugar or salt to be natural, but those ingredients are natural under AAFCO. On the other hand, because the bulk of commercial ascorbic acid (vitamin C) used in pet foods is chemically synthesized, this source would not be natural, despite the fact that vitamin C occurs in nature as well.
Aside from these perceived discrepancies, the AAFCO definition as it exists today is the only basis by which the matter of irradiation can be rationally discussed.
Why is FDA concerned?
In its letter to AAFCO, FDA rightly notes that irradiation is not the same as heat processing, rendering or other processes allowed under the natural definition. It ponders whether purification could apply to irradiation, but frankly, I do not believe that was the intent when the definition was drafted.
Rather, the process most likely was not mentioned because irradiation was not approved for use in pet foods while the definition was being developed. Unfortunately, the list of processes is not preceded by "such as" or similar phraseology that would allow for tacit extension of the list when appropriate. Thus, FDA concludes that irradiation effectively nullifies characterization of a product with the term "natural" as currently defined.
While irradiation may not be expressly named among the allowed processes for natural products or ingredients, the intent of irradiation is the same as some of the processes that are allowed, which ultimately is to help ensure microbial safety of the finished product. Essentially, heat is another form of radiation (infrared).
Also, ionizing radiation cannot be characterized as, nor does it result in, chemical synthesis, the key part of the natural definition. In my opinion, then, irradiation should be included among the processes allowed.
Let consumers decide?
Under current FDA regulations, the labels of irradiated pet foods must bear a Radura symbol, accompanied by the words "treated by irradiation" or "treated with radiation." FDA notes in its letter that few consumers may think of irradiation as natural. That may be true, but the same could be said of other processes or ingredients currently allowed under the natural definition.
Regardless, as long as the label discloses that the product has been irradiated as required under the regulations, it should be up to consumers to decide whether use of the term natural to describe that same product is inconsistent. They can then make their purchasing decisions accordingly.
I would encourage amendment of the AAFCO definition for natural to include irradiation for sake of clarity. In the interim, I hope state feed control officials look at the spirit of the definition and opt not to enforce label changes that could, in fact, compromise the safety of pet foods.”
Here is my take: I am not quite as liberal as Mr. Dzanis. To me the irradiation process is not a natural one, period. To me natural means “as occurring in nature, without being touched and changed by humans”. Irradiation does not fall in that category. Therefore I am against its use, whether the consumer approves it or not. I also have the strong opinion that the consumer in most cases probably is not even able to make an educated decisions since not too much is known about not just the process but also its possible consequences. I think that the label itself is kind of misleading, the irradiation symbol has too much of a kind of “healthy, natural” appearance. I refer you to an interesting article by Susan Thixton on her Truth About Pet Food blog “Do you know what this symbol means?”. Some of her reader’s comments were: “I thought the flower meant it was a good thing; The symbol looks like it is promoting something "Organic". Now that I know it means food is treated with Radiation, I will watch for and avoid it at all cost in both my food and my dog's food and treats; I appreciate the information about the symbol. At first glance it looks like a label on a food that would be considered a natural food that would be free of artificial colors and preservatives. The best defense is an educated consumer.”
Sure, irradiation, there is no doubt, is a working instrument and does what it is supposed to do, which is protecting against bacterial contamination. But do we know what else does it do? Chemotherapy helps against cancer too, but it also makes your hair fall out, …. The cat food in Australia was safe from spoilage, but it also caused some animals to die… I think my dogs and cats are safer off eating some minor bacteria, at least that would be natural. That is of course unless you feed your pets during the middle of the dark night, there irradiated food may come in handy since it may glow.
Since then not a day goes by without an inquiry from concerned pet owners about the issue of food irradiation.
In case you don’t recall, back then, the Orijen was found to be the only link between a strange illness that paralyzed cats with the unfortunate outcome that the animals had to be euthanized. To bring everybody up to speed, here is what (in Australia only) had transpired in a summary background provided by Orijen: “On November 20, 2008, Champion Pet Foods announced a voluntary recall of its Orijen Cat food brand sold in Australia. The recall is restricted to Australia ….. was issued in response to reports from the Australian veterinary community of cats showing symptoms of a neurological syndrome after consuming Orijen cat food. To prevent the risk of cats eating Orijen dog foods and becoming ill Champion ceased the sale of Orijen dog foods in Australia. The recall was unique to Australia and did not affect any of the other 50 countries to which Orijen is exported. Champion Pet Foods believes the Australian cases resulted from the high-level irradiation (exceeding 50kGY) applied to Orijen upon entering Australia. This high-level irradiation procedure for is unique to Australia and Orijen foods are not irradiated in any other market or country. Champion Pet Foods no longer exports or sells its Orijen pet foods in Australia.”Susan Thixton of the Truth About Pet Foods.com, back then when it all came to light, spoke with Orijen. On her website she shared the conversation she had with an Orijen representative:“The only reports of sick cats (or any pets) have been in Australia. All pet foods shipped into Australia must be irradiated, treated with radiation, before they are sold. Orijen has no control over this, this is a mandated issue from the government of Australia. Orijen has sent two samples of the irradiated food, along with non irradiated food from the same batch to two separate University testing laboratories. It is not sure if an answer for the illnesses will be found in these tests, however it should provide a wealth of information regarding effects of irradiation of foods.” Note: Those results were subsequently posted on Orijen’s website at www.championpetfoods.com. Susan then continued: “Orijen told me they feel the irradiation is the concern. Although this is frightening for already frightened pet owners, at this point I am in agreement that the irradiation is the concern. Food is irradiated, treated with radiation, to kill bacteria and molds. In the process, much more is destroyed. Not only is the nutrition destroyed, but far more research than the FDA lets on to, tells us much more damage can occur. Irradiation breaks chemical bonds, and it is suspect that broken chemical bonds within foods containing numerous ingredients (a pet food) can alter the entire ‘food’ in many ways. “
As a subsequent measure the Australian government went to work about the problem. Most recently on 06/01/09, Veterinary Practice News reported under “Australia Bans Pet Food Irradiation”:
“Australia has banned the government-mandated practice of irradiating imported pet food, the Sydney Morning Herald reported. The ban comes after a number of cats died or became ill after eating irradiated cat food manufactured by the Canadian company, Champion Petfoods Ltd.
The Australian Minister for Agriculture, Fisheries and Forestry, Tony Burke, has ordered the sterilization process to cease immediately after receiving international reports that some cats can suffer neurological damage from eating irradiated dry food, according to the Herald. Details on the reports were not immediately available. …"
Sorry, that the introduction to today’s comment became a little lengthy, however it was necessary to understand my thought process. I recently found an article in Pet Food Industry.com, a print and on-line publication for pet food professionals. Written by David A.Dzanis, DVM, PhD, DACVN, the title is “Is irradiation of petfoods natural? AAFCO definition fails to address whether an irradiated product is considered natural. A recent letter from FDA to the chair of the AAFCO Pet Food Committee opines it currently does not.” Her is what he had to say:
‘”In 2001, the US Food and Drug Administration (FDA) approved a petition broadening the use of irradiation of animal feeds to include petfoods, treats and chews. That same year, the Association of American Feed Control Officials (AAFCO) accepted the feed term "natural" and established guidelines concerning its use on petfood labels. Because these two independent matters were in development during the same period, the AAFCO definition fails to address whether an irradiated product is considered natural. A recent letter from FDA to the chair of the AAFCO Pet Food Committee opines it currently does not.”
Then, many of you will like his explanation of irradiation much better than my original, boring and lengthy rocket scientist approach (Glowing pet food? Irradiation applied to pet food). Mr. Dzanis explains: “What is irradiation?
Under FDA regulations, ionizing radiation can be from either of two origins:
X-rays generated from machine sources; or
Gamma rays emitted during radioactive decay of radionuclides.
The former are the result of energy shifts in orbiting electrons of molecules, while the latter come from energy shifts within the nuclei of atoms. Other than their origins, though, the two types of radiation are virtually indistinguishable from each other, as the range of wavelengths used to define one versus the other largely overlap.
In neither case does the food incorporate or come in direct contact with radioactive material, nor is there a chemically synthetic step to the process.
The approved purpose of irradiation of pet foods is for microbial disinfection, control or elimination. While not intended as a replacement for other appropriate sanitation measures, it gives the manufacturer another weapon in the arsenal against potential microbial contamination. Irradiation may be more suitable for some types of pet products compared to others, but considering the heightened concern regarding pet food safety today, all manufacturers should consider it a potential means to address safety issues.”
And here comes what really matters to me today: “Natural or not?
There are many different ways to interpret "natural," which led to wide misuse of the term on pet food labels in the past. To help provide consistency in meaning and a basis to uniformly interpret use of the term, AAFCO defined it to differentiate products and ingredients in terms of their sources and processing methods. For example, natural products or ingredients must be of animal, plant or mined sources but can be ground, cooked, dried, rendered, purified, extracted, hydrolyzed or even fermented.
The key factor in determining the applicability of the term is that anything that is manufactured by means of chemical synthesis or contains a chemically synthetic substance is not natural (at least not without further qualification, such as with a pet food containing synthetic vitamins but otherwise meeting the definition).
Of course, not all people would necessarily agree with this definition. For example, many consumers would not consider chicken meal, wheat middlings, sugar or salt to be natural, but those ingredients are natural under AAFCO. On the other hand, because the bulk of commercial ascorbic acid (vitamin C) used in pet foods is chemically synthesized, this source would not be natural, despite the fact that vitamin C occurs in nature as well.
Aside from these perceived discrepancies, the AAFCO definition as it exists today is the only basis by which the matter of irradiation can be rationally discussed.
Why is FDA concerned?
In its letter to AAFCO, FDA rightly notes that irradiation is not the same as heat processing, rendering or other processes allowed under the natural definition. It ponders whether purification could apply to irradiation, but frankly, I do not believe that was the intent when the definition was drafted.
Rather, the process most likely was not mentioned because irradiation was not approved for use in pet foods while the definition was being developed. Unfortunately, the list of processes is not preceded by "such as" or similar phraseology that would allow for tacit extension of the list when appropriate. Thus, FDA concludes that irradiation effectively nullifies characterization of a product with the term "natural" as currently defined.
While irradiation may not be expressly named among the allowed processes for natural products or ingredients, the intent of irradiation is the same as some of the processes that are allowed, which ultimately is to help ensure microbial safety of the finished product. Essentially, heat is another form of radiation (infrared).
Also, ionizing radiation cannot be characterized as, nor does it result in, chemical synthesis, the key part of the natural definition. In my opinion, then, irradiation should be included among the processes allowed.
Let consumers decide?
Under current FDA regulations, the labels of irradiated pet foods must bear a Radura symbol, accompanied by the words "treated by irradiation" or "treated with radiation." FDA notes in its letter that few consumers may think of irradiation as natural. That may be true, but the same could be said of other processes or ingredients currently allowed under the natural definition.
Regardless, as long as the label discloses that the product has been irradiated as required under the regulations, it should be up to consumers to decide whether use of the term natural to describe that same product is inconsistent. They can then make their purchasing decisions accordingly.
I would encourage amendment of the AAFCO definition for natural to include irradiation for sake of clarity. In the interim, I hope state feed control officials look at the spirit of the definition and opt not to enforce label changes that could, in fact, compromise the safety of pet foods.”
Here is my take: I am not quite as liberal as Mr. Dzanis. To me the irradiation process is not a natural one, period. To me natural means “as occurring in nature, without being touched and changed by humans”. Irradiation does not fall in that category. Therefore I am against its use, whether the consumer approves it or not. I also have the strong opinion that the consumer in most cases probably is not even able to make an educated decisions since not too much is known about not just the process but also its possible consequences. I think that the label itself is kind of misleading, the irradiation symbol has too much of a kind of “healthy, natural” appearance. I refer you to an interesting article by Susan Thixton on her Truth About Pet Food blog “Do you know what this symbol means?”. Some of her reader’s comments were: “I thought the flower meant it was a good thing; The symbol looks like it is promoting something "Organic". Now that I know it means food is treated with Radiation, I will watch for and avoid it at all cost in both my food and my dog's food and treats; I appreciate the information about the symbol. At first glance it looks like a label on a food that would be considered a natural food that would be free of artificial colors and preservatives. The best defense is an educated consumer.”
Sure, irradiation, there is no doubt, is a working instrument and does what it is supposed to do, which is protecting against bacterial contamination. But do we know what else does it do? Chemotherapy helps against cancer too, but it also makes your hair fall out, …. The cat food in Australia was safe from spoilage, but it also caused some animals to die… I think my dogs and cats are safer off eating some minor bacteria, at least that would be natural. That is of course unless you feed your pets during the middle of the dark night, there irradiated food may come in handy since it may glow.
Thursday, June 18, 2009
Pet Food Labels 101: Net Quantity Statement
Pet food labeling is regulated at two levels. The Federal regulations, enforced by the FDA's Center for Veterinary Medicine (CVM), establish standards applicable for all animal feeds: proper identification of product, net quantity statement, manufacturer's address, and proper listing of ingredients. Some States also enforce their own labeling regulations. Many of these have adopted the model pet food regulations established by the Association of American Feed Control Officials (AAFCO). These regulations are more specific in nature, covering aspects of labeling such as the product name, the guaranteed analysis, the nutritional adequacy statement, feeding directions, and calorie statements.
The net quantity statement tells you how much product is in the container. There are many FDA regulations dictating the format, size and placement of the net quantity statement. None of these do any good if the consumer does not check the quantity statements, especially when comparing the cost of products. For example, a 14-ounce can of food may look identical to the one-pound can of food right next to it. Also, dry products may differ greatly in density, especially some of the "lite" products. Thus, a bag that may typically hold 40 pounds of food may only hold 35 pounds of a food that is "puffed up." A cost-per-ounce or per-pound comparison between products is always prudent. Manufacturer's Name and Address The "manufactured by..." statement identifies the party responsible for the quality and safety of the product and its location. If the label says "manufactured for..." or "distributed by...," the food was manufactured by an outside manufacturer, but the name on the label still designates the responsible party. Not all labels include a street address along with the city, State, and zip code, but by law, it should be listed in either a city directory or a telephone directory. Many manufacturers also include a toll-free number on the label for consumer inquiries. If a consumer has a question or complaint about the product, he or she should not hesitate to use this information to contact the responsible party. Ingredient List All ingredients are required to be listed in order of predominance by weight. The weights of ingredients are determined as they are added in the formulation, including their inherent water content. This latter fact is important when evaluating relative quantity claims, especially when ingredients of different moisture contents are compared.
For example, one pet food may list "meat" as its first ingredient, and "corn" as its second. The manufacturer doesn't hesitate to point out that its competitor lists "corn" first ("meat meal" is second), suggesting the competitor's product has less animal-source protein than its own. However, meat is very high in moisture (approximately 75% water). On the other hand, water and fat are removed from meat meal, so it is only 10% moisture (what's left is mostly protein and minerals). If we could compare both products on a dry matter basis (mathematically "remove" the water from both ingredients), one could see that the second product had more animal-source protein from meat meal than the first product had from meat, even though the ingredient list suggests otherwise.
That is not to say that the second product has more "meat" than the first, or in fact, any meat at all. Meat meal is not meat per se, since most of the fat and water have been removed by rendering. Ingredients must be listed by their "common or usual" name. Most ingredients on pet food labels have a corresponding definition in the AAFCO Official Publication. For example, "meat" is defined as the "clean flesh of slaughtered mammals and is limited to...the striate muscle...with or without the accompanying and overlying fat and the portions of the skin, sinew, nerve and blood vessels which normally accompany the flesh." On the other hand, "meat meal" is "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 processing, it could also contain parts of animals one would not think of as "meat." Meat meal may not be very pleasing to think about eating yourself, even though it's probably more nutritious. Animals do not share in people's aesthetic concerns about the source and composition of their food. Regardless, the distinction must be made in the ingredient list (and in the product name). For this reason, a product containing "lamb meal" cannot be named a "Lamb Dinner."
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. Other possible ingredients may include artificial colors, stabilizers, and preservatives. All should be either "Generally Recognized As Safe (GRAS)" or approved food additives for their intended uses.
If scientific data are presented that show a health risk to animals of an ingredient or additive, CVM can act to prohibit or modify its use in pet food. For example, propylene glycol was used as a humectant in soft-moist pet foods, which helps retain water and gives these products their unique texture and taste. It was affirmed Generally Recognized As Safe (GRAS) for use in human and animal food before the advent of soft-moist foods. It was known for some time that propylene glycol caused Heinz Body formation in the red blood cells of cats (small clumps of proteins seen in the cells when viewed under the microscope), but it could not be shown to cause overt anemia or other clinical effects. However, recent reports in the veterinary literature of scientifically sound studies have shown that propylene glycol reduces the red blood cell survival time, renders red blood cells more susceptible to oxidative damage, and has other adverse effects in cats consuming the substance at levels found in soft-moist food. In light of this new data, CVM amended the regulations to expressly prohibit the use of propylene glycol in cat foods.
Another pet food additive of some controversy is ethoxyquin, which was approved as a food additive over thirty-five years ago for use as an antioxidant chemical preservative in animal feeds. Approximately ten years ago, CVM began receiving reports from dog owners attributing the presence of ethoxyquin in the dog food with a myriad of adverse effects, such as allergic reactions, skin problems, major organ failure, behavior problems, and cancer. However, there was a paucity of available scientific data to support these contentions, or to show other adverse effects in dogs at levels approved for use in dog foods. More recent studies by the manufacturer of ethoxyquin showed a dose-dependent accumulation of a hemoglobin-related pigment in the liver, as well as increases in the levels of liver-related enzymes in the blood. Although these changes are due to ethoxyquin in the diet, the pigment is not made from ethoxyquin itself, and the health significance of these findings is unknown. More information on the utility of ethoxyquin is still needed in order for CVM to amend the maximum allowable level to below that which would cause these effects, but which still would be useful in preserving the food. While studies are being conducted to ascertain a more accurate minimum effective level of ethoxyquin in dog foods, CVM has asked the pet food industry to voluntarily lower the maximum level of use of ethoxyquin in dog foods from 150 ppm (0.015%) to 75 ppm. Regardless, most pet foods that contained ethoxyquin never exceeded the lower amount, even before this recommended change.
Pet owners and veterinary professionals have a right to know what they are feeding their animals. The pet food label contains a wealth of information, if one knows how to read it. Do not be swayed by the many marketing gimmicks or eye catching claims. If there is a question about the product, contact the manufacturer or ask an appropriate regulatory agency.
Source: FDA Animal & Veterinary Resources Pet Food Labels - General Consumer information provided by David A. Dzanis, DVM, Ph.D., DACVN.
The net quantity statement tells you how much product is in the container. There are many FDA regulations dictating the format, size and placement of the net quantity statement. None of these do any good if the consumer does not check the quantity statements, especially when comparing the cost of products. For example, a 14-ounce can of food may look identical to the one-pound can of food right next to it. Also, dry products may differ greatly in density, especially some of the "lite" products. Thus, a bag that may typically hold 40 pounds of food may only hold 35 pounds of a food that is "puffed up." A cost-per-ounce or per-pound comparison between products is always prudent. Manufacturer's Name and Address The "manufactured by..." statement identifies the party responsible for the quality and safety of the product and its location. If the label says "manufactured for..." or "distributed by...," the food was manufactured by an outside manufacturer, but the name on the label still designates the responsible party. Not all labels include a street address along with the city, State, and zip code, but by law, it should be listed in either a city directory or a telephone directory. Many manufacturers also include a toll-free number on the label for consumer inquiries. If a consumer has a question or complaint about the product, he or she should not hesitate to use this information to contact the responsible party. Ingredient List All ingredients are required to be listed in order of predominance by weight. The weights of ingredients are determined as they are added in the formulation, including their inherent water content. This latter fact is important when evaluating relative quantity claims, especially when ingredients of different moisture contents are compared.
For example, one pet food may list "meat" as its first ingredient, and "corn" as its second. The manufacturer doesn't hesitate to point out that its competitor lists "corn" first ("meat meal" is second), suggesting the competitor's product has less animal-source protein than its own. However, meat is very high in moisture (approximately 75% water). On the other hand, water and fat are removed from meat meal, so it is only 10% moisture (what's left is mostly protein and minerals). If we could compare both products on a dry matter basis (mathematically "remove" the water from both ingredients), one could see that the second product had more animal-source protein from meat meal than the first product had from meat, even though the ingredient list suggests otherwise.
That is not to say that the second product has more "meat" than the first, or in fact, any meat at all. Meat meal is not meat per se, since most of the fat and water have been removed by rendering. Ingredients must be listed by their "common or usual" name. Most ingredients on pet food labels have a corresponding definition in the AAFCO Official Publication. For example, "meat" is defined as the "clean flesh of slaughtered mammals and is limited to...the striate muscle...with or without the accompanying and overlying fat and the portions of the skin, sinew, nerve and blood vessels which normally accompany the flesh." On the other hand, "meat meal" is "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 processing, it could also contain parts of animals one would not think of as "meat." Meat meal may not be very pleasing to think about eating yourself, even though it's probably more nutritious. Animals do not share in people's aesthetic concerns about the source and composition of their food. Regardless, the distinction must be made in the ingredient list (and in the product name). For this reason, a product containing "lamb meal" cannot be named a "Lamb Dinner."
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. Other possible ingredients may include artificial colors, stabilizers, and preservatives. All should be either "Generally Recognized As Safe (GRAS)" or approved food additives for their intended uses.
If scientific data are presented that show a health risk to animals of an ingredient or additive, CVM can act to prohibit or modify its use in pet food. For example, propylene glycol was used as a humectant in soft-moist pet foods, which helps retain water and gives these products their unique texture and taste. It was affirmed Generally Recognized As Safe (GRAS) for use in human and animal food before the advent of soft-moist foods. It was known for some time that propylene glycol caused Heinz Body formation in the red blood cells of cats (small clumps of proteins seen in the cells when viewed under the microscope), but it could not be shown to cause overt anemia or other clinical effects. However, recent reports in the veterinary literature of scientifically sound studies have shown that propylene glycol reduces the red blood cell survival time, renders red blood cells more susceptible to oxidative damage, and has other adverse effects in cats consuming the substance at levels found in soft-moist food. In light of this new data, CVM amended the regulations to expressly prohibit the use of propylene glycol in cat foods.
Another pet food additive of some controversy is ethoxyquin, which was approved as a food additive over thirty-five years ago for use as an antioxidant chemical preservative in animal feeds. Approximately ten years ago, CVM began receiving reports from dog owners attributing the presence of ethoxyquin in the dog food with a myriad of adverse effects, such as allergic reactions, skin problems, major organ failure, behavior problems, and cancer. However, there was a paucity of available scientific data to support these contentions, or to show other adverse effects in dogs at levels approved for use in dog foods. More recent studies by the manufacturer of ethoxyquin showed a dose-dependent accumulation of a hemoglobin-related pigment in the liver, as well as increases in the levels of liver-related enzymes in the blood. Although these changes are due to ethoxyquin in the diet, the pigment is not made from ethoxyquin itself, and the health significance of these findings is unknown. More information on the utility of ethoxyquin is still needed in order for CVM to amend the maximum allowable level to below that which would cause these effects, but which still would be useful in preserving the food. While studies are being conducted to ascertain a more accurate minimum effective level of ethoxyquin in dog foods, CVM has asked the pet food industry to voluntarily lower the maximum level of use of ethoxyquin in dog foods from 150 ppm (0.015%) to 75 ppm. Regardless, most pet foods that contained ethoxyquin never exceeded the lower amount, even before this recommended change.
Pet owners and veterinary professionals have a right to know what they are feeding their animals. The pet food label contains a wealth of information, if one knows how to read it. Do not be swayed by the many marketing gimmicks or eye catching claims. If there is a question about the product, contact the manufacturer or ask an appropriate regulatory agency.
Source: FDA Animal & Veterinary Resources Pet Food Labels - General Consumer information provided by David A. Dzanis, DVM, Ph.D., DACVN.
Monday, June 15, 2009
FDA 101: Animal Feed
The Food and Drug Administration (FDA) on 06/10/09 published its FDA 101 on Animal Feed. Sounds interesting I thought when I found the announcement in my inbox. However, knowing what we all know I was skeptical of what it really means and if it is going to change anything for us pet owners. Here’s the wording, note that because of our specific interest as pet owners I rearranged the paragraphs a little:
Introduction
As long as the Food and Drug Administration (FDA) has been regulating food for people, it has also regulated food for animals, including animal feed for millions of chickens, turkeys, cows, pigs, sheep, and fish. In addition, FDA regulates pet food for America’s more than 177 million dogs, cats, and horses.
The Federal Food, Drug, and Cosmetic Act requires animal feed, like human foods, to
-be pure and wholesome
-be produced under sanitary conditions
-contain no harmful substances
-be truthfully labeled
As is also the case for human foods, the act does not give FDA the authority to require approval of animal feed, including pet food, before it is marketed. But the agency has the authority to take action against feed products that are in violation of the law. And FDA approves the additives or drugs that are used in feed products.
Animal feed manufacturers are responsible for ensuring that
-feed is truthfully labeled
-feed does not contain unsafe additives or contaminants
-if the feed contains drugs, the drugs are approved by FDA for use in animal feeds
Federal and state regulatory agencies work cooperatively to provide the rules, guidance, and oversight to assist industry in producing and distributing safe animal feed and feed ingredients.
Pet Food
Pet food, including dry and canned food and pet treats, is considered to be animal feed. Like other animal feed, FDA regulates pet food and establishes standards for labeling.
Pet food labeling is regulated at two levels: federal and state. The federal regulations, enforced by FDA’s Center for Veterinary Medicine, establish standards that apply to all animal feeds:
-proper identification of the product
-net quantity statement
-manufacturer’s address
-proper listing of ingredients
Some states also enforce their own labeling regulations. Many of these follow the model pet food regulations of the Association of American Feed Control Officials (AAFCO), a non-government advisory body with representative regulatory officials from all the states. These model regulations are more specific than federal regulations, covering aspects of labeling such as product name, nutritional adequacy statement, feeding directions, and calorie statements.
FDA carries out its animal feed regulatory responsibilities in cooperation with state and local partners, and works together with AAFCO on uniform feed ingredient definitions and proper labeling.”
These paragraphs deal with what we as pet owners are interested in: Pet food. However, as it states, “Pet food, including dry and canned food and pet treats, is considered to be animal feed”, I figured, I also share with you the paragraphs dealing more with other animals, like for example chicken or beef, i.e. the stuff what is being used in our pet foods. My desire of sharing the following paragraphs comes especially since it makes very clear what we may be faced with when we buy a bag or can of chicken formula for our cats and dogs, and what these chicken may have been fed before they found their final destination.
“Medicated Feed
Drugs may be added to some animal feeds to prevent or treat diseases, or to improve animal growth and productivity.
“The use of drugs in the food of animals is essential to keep animals healthy,” says Steven D. Vaughn, D.V.M., director of the Office of New Animal Drug Evaluation in FDA’s Center for Veterinary Medicine. “Administering drugs to animals takes into consideration the best methods for providing the needed medicine while minimizing the stress to the animals.”
For example, coccidiosis is a disease that commonly infects chickens and can cause death if untreated. The parasites responsible, coccidia, are passed in the droppings and can infect other chickens housed near the sick chickens.
“It’s not practical for the poultry farmer to isolate and individually dose chickens within a flock,” says Vaughn. “Catching, restraining, and handling chickens can be stressful and potentially harmful to the animals, particularly if they are already stressed due to disease. Providing medication through the feed or drinking water eliminates the stress to the animals. Medicated feed to treat all the chickens is necessary for good animal health, and ultimately to the health of humans who consume the chicken products.”
The types of drugs that may be used in feed include
-antimicrobials (such as antibacterial drugs) to fight infections
-anticoccidials to fight coccidial parasites
-hormonals to suppress estrus (the female “heat” cycle) in cattle
-anthelmintics to fight parasitic worms
-sulfonamidics to fight certain types of infections
-beta agonists to promote leanness in animals raised for meat
-anti-bloating drugs to prevent swelling of the stomach compartments or intestinal tract of cows caused by excessive gas.
Residues and Resistance
FDA is responsible for assuring that animal drugs and medicated feeds are not only safe and effective for animals, but that food products from treated animals are safe for humans to consume. This safety responsibility includes making sure that drugs used in medicated feed
do not leave hazardous residues in human foods, such as milk, meat, and eggs do not contribute to antimicrobial resistance—the ability of bacteria and other microbes to grow in the presence of a drug that would normally kill them or limit their growth Before a drug can be approved for a food-producing animal, FDA requires the drug sponsors to provide data to show how much drug remaining in the animal’s system (residue) would be safe for people to consume that the concentration of actual residue in the edible part of the animal would not result in a person consuming more than the safe level the potential for the drug, if it’s an antimicrobial drug, to contribute to antimicrobial resistance FDA has produced guidance to help drug makers provide these data. For example, FDA provides a scientific process for determining the likelihood that an antimicrobial drug used to treat an animal may cause an antimicrobial resistance problem in humans consuming products from that animal. This process can help prevent drugs with a high risk of causing such problems from being improperly used in food-producing animals, potentially leading to antimicrobial resistance in humans.
While recognizing that drugs in animal feed are essential, FDA encourages food-animal producers and veterinarians to apply good judgment and common sense in using animal drugs.
“The judicious use of all drugs in animals, particularly food-producing animals, is very important,” says Vaughn. “The use of medicated feeds in food-producing animals is evaluated and regulated to prevent harmful effects on both animal and human health.”
Manufacturers can do their part in providing safe and effective feed products by properly mixing the feed and complying with regulations that require current good manufacturing processes (cGMP) for medicated feeds. In addition to guidance, FDA provides brochures, videos, and other products on its Web site to encourage judicious drug use in animals.
The law requires feed manufacturers to be licensed if they use certain types of medication in manufacturing their feeds. FDA and the state inspect these licensed facilities routinely to make sure they are complying with cGMPs. During FY 2008 (Oct. 1, 2007, through Sept. 30, 2008), FDA conducted 453 inspections of licensed medicated feed manufacturers throughout the United States.”
I think at this point you may agree with me, it sure makes me think twice not just about what I feed my companion animals, but also what I feed my family and myself. And makes me also to reconsider possibly other food types like for example organic, or with ingredients from free range and pasture fed animals.
To me the bottom line is this: This all sounds good in theory. But unfortunately we also know that it still leaves a lot of lead way for pet food manufacturers. They still can stretch pretty far what they are doing with regards to manufacturing processes and ingredient composition and legally get away with it.
But, as always there is hope: The FDA also provides an outlook for the future and promises quite a few changes, which possibly could improve things in general:
“Improvements to Feed Safety
FDA is improving its Animal Feed Safety System, a program first established in 2003 to protect human and animal health by ensuring safe feeds. The system covers a broad range of agency activities from pre-approving additives for use in feed, to establishing limits on feed contaminants, providing education and training to federal and state feed regulatory personnel, conducting inspections, and taking enforcement actions to ensure compliance with agency regulations.
FDA is also taking action to improve the safety of pet food and ingredients used to make pet food, such as
-establishing ingredient standards and definitions, processing standards, and labeling standards for pet food
-establishing an early warning system to identify pet food in violation of regulations, to identify illness outbreaks, and to notify veterinarians and others of pet food recalls
-establishing a searchable database of recalled human and pet foods to ensure effective communications during a recall
-establishing a “reportable food registry” for animal feed as well as human food. Reportable food -is any food that carries a reasonable probability that its use or exposure to it will cause serious health consequences or death to humans or animals
-collaborating with state regulators and academic partners to set up a network for reporting and investigating unexpected and undesirable signs (adverse events) in pets”
It all sounds promising. My only questions are, how long will it take and how severe will the impact be on future pet food safety. As always I would like to say, let’s be optimistic. On the other side, I have been around long enough to already know today, the differences are not going to be revolutionary. Let’s keep chipping away, one little piece at a time. And keep in mind, not everything finding the FDA’s blessing is always in the best interest of our pets. Stay tuned for more on this hot topic.
Note: Visit the FDA site to read the article in its entirety.
Introduction
As long as the Food and Drug Administration (FDA) has been regulating food for people, it has also regulated food for animals, including animal feed for millions of chickens, turkeys, cows, pigs, sheep, and fish. In addition, FDA regulates pet food for America’s more than 177 million dogs, cats, and horses.
The Federal Food, Drug, and Cosmetic Act requires animal feed, like human foods, to
-be pure and wholesome
-be produced under sanitary conditions
-contain no harmful substances
-be truthfully labeled
As is also the case for human foods, the act does not give FDA the authority to require approval of animal feed, including pet food, before it is marketed. But the agency has the authority to take action against feed products that are in violation of the law. And FDA approves the additives or drugs that are used in feed products.
Animal feed manufacturers are responsible for ensuring that
-feed is truthfully labeled
-feed does not contain unsafe additives or contaminants
-if the feed contains drugs, the drugs are approved by FDA for use in animal feeds
Federal and state regulatory agencies work cooperatively to provide the rules, guidance, and oversight to assist industry in producing and distributing safe animal feed and feed ingredients.
Pet Food
Pet food, including dry and canned food and pet treats, is considered to be animal feed. Like other animal feed, FDA regulates pet food and establishes standards for labeling.
Pet food labeling is regulated at two levels: federal and state. The federal regulations, enforced by FDA’s Center for Veterinary Medicine, establish standards that apply to all animal feeds:
-proper identification of the product
-net quantity statement
-manufacturer’s address
-proper listing of ingredients
Some states also enforce their own labeling regulations. Many of these follow the model pet food regulations of the Association of American Feed Control Officials (AAFCO), a non-government advisory body with representative regulatory officials from all the states. These model regulations are more specific than federal regulations, covering aspects of labeling such as product name, nutritional adequacy statement, feeding directions, and calorie statements.
FDA carries out its animal feed regulatory responsibilities in cooperation with state and local partners, and works together with AAFCO on uniform feed ingredient definitions and proper labeling.”
These paragraphs deal with what we as pet owners are interested in: Pet food. However, as it states, “Pet food, including dry and canned food and pet treats, is considered to be animal feed”, I figured, I also share with you the paragraphs dealing more with other animals, like for example chicken or beef, i.e. the stuff what is being used in our pet foods. My desire of sharing the following paragraphs comes especially since it makes very clear what we may be faced with when we buy a bag or can of chicken formula for our cats and dogs, and what these chicken may have been fed before they found their final destination.
“Medicated Feed
Drugs may be added to some animal feeds to prevent or treat diseases, or to improve animal growth and productivity.
“The use of drugs in the food of animals is essential to keep animals healthy,” says Steven D. Vaughn, D.V.M., director of the Office of New Animal Drug Evaluation in FDA’s Center for Veterinary Medicine. “Administering drugs to animals takes into consideration the best methods for providing the needed medicine while minimizing the stress to the animals.”
For example, coccidiosis is a disease that commonly infects chickens and can cause death if untreated. The parasites responsible, coccidia, are passed in the droppings and can infect other chickens housed near the sick chickens.
“It’s not practical for the poultry farmer to isolate and individually dose chickens within a flock,” says Vaughn. “Catching, restraining, and handling chickens can be stressful and potentially harmful to the animals, particularly if they are already stressed due to disease. Providing medication through the feed or drinking water eliminates the stress to the animals. Medicated feed to treat all the chickens is necessary for good animal health, and ultimately to the health of humans who consume the chicken products.”
The types of drugs that may be used in feed include
-antimicrobials (such as antibacterial drugs) to fight infections
-anticoccidials to fight coccidial parasites
-hormonals to suppress estrus (the female “heat” cycle) in cattle
-anthelmintics to fight parasitic worms
-sulfonamidics to fight certain types of infections
-beta agonists to promote leanness in animals raised for meat
-anti-bloating drugs to prevent swelling of the stomach compartments or intestinal tract of cows caused by excessive gas.
Residues and Resistance
FDA is responsible for assuring that animal drugs and medicated feeds are not only safe and effective for animals, but that food products from treated animals are safe for humans to consume. This safety responsibility includes making sure that drugs used in medicated feed
do not leave hazardous residues in human foods, such as milk, meat, and eggs do not contribute to antimicrobial resistance—the ability of bacteria and other microbes to grow in the presence of a drug that would normally kill them or limit their growth Before a drug can be approved for a food-producing animal, FDA requires the drug sponsors to provide data to show how much drug remaining in the animal’s system (residue) would be safe for people to consume that the concentration of actual residue in the edible part of the animal would not result in a person consuming more than the safe level the potential for the drug, if it’s an antimicrobial drug, to contribute to antimicrobial resistance FDA has produced guidance to help drug makers provide these data. For example, FDA provides a scientific process for determining the likelihood that an antimicrobial drug used to treat an animal may cause an antimicrobial resistance problem in humans consuming products from that animal. This process can help prevent drugs with a high risk of causing such problems from being improperly used in food-producing animals, potentially leading to antimicrobial resistance in humans.
While recognizing that drugs in animal feed are essential, FDA encourages food-animal producers and veterinarians to apply good judgment and common sense in using animal drugs.
“The judicious use of all drugs in animals, particularly food-producing animals, is very important,” says Vaughn. “The use of medicated feeds in food-producing animals is evaluated and regulated to prevent harmful effects on both animal and human health.”
Manufacturers can do their part in providing safe and effective feed products by properly mixing the feed and complying with regulations that require current good manufacturing processes (cGMP) for medicated feeds. In addition to guidance, FDA provides brochures, videos, and other products on its Web site to encourage judicious drug use in animals.
The law requires feed manufacturers to be licensed if they use certain types of medication in manufacturing their feeds. FDA and the state inspect these licensed facilities routinely to make sure they are complying with cGMPs. During FY 2008 (Oct. 1, 2007, through Sept. 30, 2008), FDA conducted 453 inspections of licensed medicated feed manufacturers throughout the United States.”
I think at this point you may agree with me, it sure makes me think twice not just about what I feed my companion animals, but also what I feed my family and myself. And makes me also to reconsider possibly other food types like for example organic, or with ingredients from free range and pasture fed animals.
To me the bottom line is this: This all sounds good in theory. But unfortunately we also know that it still leaves a lot of lead way for pet food manufacturers. They still can stretch pretty far what they are doing with regards to manufacturing processes and ingredient composition and legally get away with it.
But, as always there is hope: The FDA also provides an outlook for the future and promises quite a few changes, which possibly could improve things in general:
“Improvements to Feed Safety
FDA is improving its Animal Feed Safety System, a program first established in 2003 to protect human and animal health by ensuring safe feeds. The system covers a broad range of agency activities from pre-approving additives for use in feed, to establishing limits on feed contaminants, providing education and training to federal and state feed regulatory personnel, conducting inspections, and taking enforcement actions to ensure compliance with agency regulations.
FDA is also taking action to improve the safety of pet food and ingredients used to make pet food, such as
-establishing ingredient standards and definitions, processing standards, and labeling standards for pet food
-establishing an early warning system to identify pet food in violation of regulations, to identify illness outbreaks, and to notify veterinarians and others of pet food recalls
-establishing a searchable database of recalled human and pet foods to ensure effective communications during a recall
-establishing a “reportable food registry” for animal feed as well as human food. Reportable food -is any food that carries a reasonable probability that its use or exposure to it will cause serious health consequences or death to humans or animals
-collaborating with state regulators and academic partners to set up a network for reporting and investigating unexpected and undesirable signs (adverse events) in pets”
It all sounds promising. My only questions are, how long will it take and how severe will the impact be on future pet food safety. As always I would like to say, let’s be optimistic. On the other side, I have been around long enough to already know today, the differences are not going to be revolutionary. Let’s keep chipping away, one little piece at a time. And keep in mind, not everything finding the FDA’s blessing is always in the best interest of our pets. Stay tuned for more on this hot topic.
Note: Visit the FDA site to read the article in its entirety.
Sunday, June 14, 2009
FDA approved pet food
A statement made by a pet food company caught my eye the other day: “FDA Approved” it said – and made me wonder: I wasn’t aware there was such an approval, neither as a requirement nor as an option. But I have been wrong before in my life and so I decided to further investigate the matter. Here is what I found, related to pet food right at the place where people should know best: The Food & Drug Administration or FDA. Here I came to find out that they were confronted with that same issue before I came around. So much indeed that they figured it would be even worth for them to publish and dedicate an entire brochure on the subject matter. Like I said, I only want to address pet food related statements, for the entire article including a link to the publication visit “Is it really FDA approved?” In a narrative it looks like this:
“FDA approved": Maybe you saw the words on a company's Web site or in a commercial promoting a new product or treatment. Some marketers may say their products are "FDA approved," but how can you know for sure?
FDA is responsible for protecting the public health by regulating human and animal drugs, biologics (e.g. vaccines and cellular and gene therapies), medical devices, food and animal feed, cosmetics, and products that emit radiation.
But not all of these products undergo premarket approval—a review of safety and effectiveness by FDA experts and agency approval before a product can be marketed. In some cases, FDA's enforcement efforts focus on products after they are already on the market. This is determined by law.
The following facts can shed light on when the term "FDA approved" is appropriate after such a determination is made by the agency.
FDA does not approve companies.
FDA does not "approve" health care facilities, laboratories, or manufacturers. FDA does inspect product manufacturers to verify that they comply with good manufacturing practices.
Owners and operators of domestic or foreign food, drug, …facilities are required to register with FDA.
FDA approves new drugs and biologics.
New drugs and biologics must be proven safe and effective to FDA's satisfaction before companies can market them. FDA does not develop or test products; FDA experts review the results of laboratory, animal, and human clinical testing done by manufacturers.
If FDA grants an approval, it means the agency has determined that the benefits of the product outweigh the risks for the intended use.
FDA approves drugs and additives in food for animals.
FDA is responsible for approving drugs and food additives given to, or used on, over one hundred million pets, plus millions of poultry, cattle, swine, and minor animal species. (Minor animal species include animals other than cattle, swine, chickens, turkeys, horses, dogs, and cats.)
FDA does not approve pet food, but rather approves the food additives that are used in pet food. FDA has the authority to take action against pet food products that are in violation of the law.
FDA approves color additives used in FDA-regulated products.
This includes those used in food, dietary supplements, drugs, cosmetics, and some medical devices. These color additives (except coal-tar hair dyes) are subject by law to approval by the agency, and each must be used only in compliance with its approved uses, specifications, and restrictions.
In the approval process, FDA evaluates safety data to ensure that a color additive is safe for its intended purposes.”
Up to here, this is pretty much what the FDA guys have to say related to an approval process. In one word: Negative.
I also think the following statements, though related to human applications, make further clear that the FDA does not have too much of an involvement related to any mysterious food approval:
“FDA does not approve medical foods.
A medical food is used for the dietary management of a disease or health condition that requires special nutrient needs. An example of a medical food is a food for use by persons with phenylketonuria, a genetic disorder. A person with this disorder may need medical foods that are formulated to be free of the amino acid phenylalanine. A medical food is intended for use under the supervision of a physician.
Medical foods do not have to undergo premarket approval by FDA. But medical food firms must comply with other requirements, such as good manufacturing practices and registration of food facilities. Medical foods do not have to include nutrition information on their labels, and any claims in their labeling must be truthful and non-misleading.
FDA does not approve infant formula.
FDA does not approve infant formulas before they can be marketed. However, manufacturers of infant formula are subject to FDA's regulatory oversight.
Manufacturers must ensure that infant formula complies with federal nutrient requirements. Manufacturers are required to register with FDA and provide the agency with a notification before marketing a new formula.
FDA does not approve dietary supplements.
Unlike new drugs, dietary supplements are not reviewed and approved by FDA based on their safety and effectiveness. Most dietary supplements that contain a new dietary ingredient (a dietary ingredient not marketed in the United States before October 15, 1994) require a notification to FDA 75 days before marketing.
The notification must include the information that was the manufacturer or distributor's basis for concluding that the dietary supplement will reasonably be expected to be safe. After dietary supplements are on the market, FDA evaluates their safety through research and adverse event monitoring.
FDA does not approve the food label, including Nutrition Facts.
FDA does not approve individual food labels before food products can be marketed. But FDA regulations require nutrition information to appear on most foods, including dietary supplements. Also, any claims on food products must be truthful and non-misleading, and must comply with any special requirements for the type of claim.
Manufacturers are required to provide the serving size of the food and information about the nutrient content of each serving on the "Nutrition Facts" panel of the food label (or on the "Supplement Facts" panel for dietary supplements.)
FDA does not approve structure-function claims on dietary supplements and other foods.
Structure-function claims describe the role of a food or food component (such as a nutrient) that is intended to affect the structure or function of the human body. One example is "calcium builds strong bones”.
Dietary supplement firms that make structure-function claims on labels or in labeling must submit a notification to FDA. This notification must be submitted no later than 30 days after marketing the dietary supplement with the structure/function claim. Additionally, the notification must include the text of the claim, as well as other information, such as the name and address of the notifier. FDA does not require conventional food manufacturers to notify FDA about their structure-function claims.
Structure-function claims on dietary supplements carry a disclaimer stating that the claim has not been reviewed by FDA, and that the product is not intended to diagnose, treat, cure, or prevent any disease. Conventional foods are not required to carry such a disclaimer.”
This lets me conclude that they don’t approve any animal prescription food, puppy or kitten food or dietary supplements for pets either.
Therefore my advice to you is this: The next time you see any pet food manufacturer making such a claim, think again. They may have some marketing gurus who are in a very bold fashion testing how long they can cash in on not better knowing consumers before they get caught. They also may be extremely profit driven and simply greedy if they are willing to take such a risk. But what risk am I talking about? The FDA states on this very same page only that “Misuse of FDA's logo may violate federal law. FDA's logo should not be used to misrepresent the agency nor to suggest that FDA endorses any private organization, product, or service.” So, it looks to me, making such bold statements doesn’t bear too much of a risk of prison time or heavy penalties.
As usual, it is all up to you, the educated consumer, to make the right decision. The pet owner who is smart enough to look beyond such misleading statements in order to figure out what else may be wrong with the actual product. Manufacturers offering quality products don’t need to rely on distracting the consumer with wrongful information. Their product, even in an overcrowded market as the pet food playing field, speaks for itself.
“FDA approved": Maybe you saw the words on a company's Web site or in a commercial promoting a new product or treatment. Some marketers may say their products are "FDA approved," but how can you know for sure?
FDA is responsible for protecting the public health by regulating human and animal drugs, biologics (e.g. vaccines and cellular and gene therapies), medical devices, food and animal feed, cosmetics, and products that emit radiation.
But not all of these products undergo premarket approval—a review of safety and effectiveness by FDA experts and agency approval before a product can be marketed. In some cases, FDA's enforcement efforts focus on products after they are already on the market. This is determined by law.
The following facts can shed light on when the term "FDA approved" is appropriate after such a determination is made by the agency.
FDA does not approve companies.
FDA does not "approve" health care facilities, laboratories, or manufacturers. FDA does inspect product manufacturers to verify that they comply with good manufacturing practices.
Owners and operators of domestic or foreign food, drug, …facilities are required to register with FDA.
FDA approves new drugs and biologics.
New drugs and biologics must be proven safe and effective to FDA's satisfaction before companies can market them. FDA does not develop or test products; FDA experts review the results of laboratory, animal, and human clinical testing done by manufacturers.
If FDA grants an approval, it means the agency has determined that the benefits of the product outweigh the risks for the intended use.
FDA approves drugs and additives in food for animals.
FDA is responsible for approving drugs and food additives given to, or used on, over one hundred million pets, plus millions of poultry, cattle, swine, and minor animal species. (Minor animal species include animals other than cattle, swine, chickens, turkeys, horses, dogs, and cats.)
FDA does not approve pet food, but rather approves the food additives that are used in pet food. FDA has the authority to take action against pet food products that are in violation of the law.
FDA approves color additives used in FDA-regulated products.
This includes those used in food, dietary supplements, drugs, cosmetics, and some medical devices. These color additives (except coal-tar hair dyes) are subject by law to approval by the agency, and each must be used only in compliance with its approved uses, specifications, and restrictions.
In the approval process, FDA evaluates safety data to ensure that a color additive is safe for its intended purposes.”
Up to here, this is pretty much what the FDA guys have to say related to an approval process. In one word: Negative.
I also think the following statements, though related to human applications, make further clear that the FDA does not have too much of an involvement related to any mysterious food approval:
“FDA does not approve medical foods.
A medical food is used for the dietary management of a disease or health condition that requires special nutrient needs. An example of a medical food is a food for use by persons with phenylketonuria, a genetic disorder. A person with this disorder may need medical foods that are formulated to be free of the amino acid phenylalanine. A medical food is intended for use under the supervision of a physician.
Medical foods do not have to undergo premarket approval by FDA. But medical food firms must comply with other requirements, such as good manufacturing practices and registration of food facilities. Medical foods do not have to include nutrition information on their labels, and any claims in their labeling must be truthful and non-misleading.
FDA does not approve infant formula.
FDA does not approve infant formulas before they can be marketed. However, manufacturers of infant formula are subject to FDA's regulatory oversight.
Manufacturers must ensure that infant formula complies with federal nutrient requirements. Manufacturers are required to register with FDA and provide the agency with a notification before marketing a new formula.
FDA does not approve dietary supplements.
Unlike new drugs, dietary supplements are not reviewed and approved by FDA based on their safety and effectiveness. Most dietary supplements that contain a new dietary ingredient (a dietary ingredient not marketed in the United States before October 15, 1994) require a notification to FDA 75 days before marketing.
The notification must include the information that was the manufacturer or distributor's basis for concluding that the dietary supplement will reasonably be expected to be safe. After dietary supplements are on the market, FDA evaluates their safety through research and adverse event monitoring.
FDA does not approve the food label, including Nutrition Facts.
FDA does not approve individual food labels before food products can be marketed. But FDA regulations require nutrition information to appear on most foods, including dietary supplements. Also, any claims on food products must be truthful and non-misleading, and must comply with any special requirements for the type of claim.
Manufacturers are required to provide the serving size of the food and information about the nutrient content of each serving on the "Nutrition Facts" panel of the food label (or on the "Supplement Facts" panel for dietary supplements.)
FDA does not approve structure-function claims on dietary supplements and other foods.
Structure-function claims describe the role of a food or food component (such as a nutrient) that is intended to affect the structure or function of the human body. One example is "calcium builds strong bones”.
Dietary supplement firms that make structure-function claims on labels or in labeling must submit a notification to FDA. This notification must be submitted no later than 30 days after marketing the dietary supplement with the structure/function claim. Additionally, the notification must include the text of the claim, as well as other information, such as the name and address of the notifier. FDA does not require conventional food manufacturers to notify FDA about their structure-function claims.
Structure-function claims on dietary supplements carry a disclaimer stating that the claim has not been reviewed by FDA, and that the product is not intended to diagnose, treat, cure, or prevent any disease. Conventional foods are not required to carry such a disclaimer.”
This lets me conclude that they don’t approve any animal prescription food, puppy or kitten food or dietary supplements for pets either.
Therefore my advice to you is this: The next time you see any pet food manufacturer making such a claim, think again. They may have some marketing gurus who are in a very bold fashion testing how long they can cash in on not better knowing consumers before they get caught. They also may be extremely profit driven and simply greedy if they are willing to take such a risk. But what risk am I talking about? The FDA states on this very same page only that “Misuse of FDA's logo may violate federal law. FDA's logo should not be used to misrepresent the agency nor to suggest that FDA endorses any private organization, product, or service.” So, it looks to me, making such bold statements doesn’t bear too much of a risk of prison time or heavy penalties.
As usual, it is all up to you, the educated consumer, to make the right decision. The pet owner who is smart enough to look beyond such misleading statements in order to figure out what else may be wrong with the actual product. Manufacturers offering quality products don’t need to rely on distracting the consumer with wrongful information. Their product, even in an overcrowded market as the pet food playing field, speaks for itself.
Tuesday, June 9, 2009
Pet Food Safety - Making a difference? Yes, we can!
My friend Susan Thixton of TruthAboutPetFood.com is going for it again: Susan, self declared “Caped crusader for Safe Pet Food”, just like all of us in this community, is on a mission to make a difference in this world with its overwhelming jungle of pet nutrition products and to separate the good and healthy from the bad and sickening.
She is the publisher of the PetsumerReport.com, which is an on-line pet food evaluation and rating service. As of today she has developed and compiled an extremely informative database of over 1,000 pet food products, for each of those products providing a great number of details. Her evaluations include listings of proteins, health promoting ingredients, controversial ingredients, comments about by-products and chemicals, positives and negatives, information about the manufacturers and more. Also included, if necessary, are so called “Red Flags”, which are warnings about unfavorable circumstances. All this information she collects and then works it into a simple rating system based on quality ingredients with the result of each product being rated on a scale from 1 to 5 “Paws”. To make the information collected most objective, Susan contacts the manufacturers asking questions without giving away her “true” identity, just as any pet owner would and can do. The service is available to any interested party on a subscription basis at a very affordable price. I personally use her database all the time as a basis and part of my daily work in evaluating and comparing pet foods for our clients.
But that is not enough for Susan. She also publishes her blog TruthAboutPetFood.com, I guess I don’t have to further explain what it is all about, its name gives it away. Some of you may have noticed that I list her blog as one of the ones I follow very closely for obvious reasons. Just a few months ago I came with Susan to an agreement that allows me to use some of her comments either partially or in full on this blog as I see fit. In return I am supposed to write a comment here and there for hers (and yes, Susan, I promise I will. Right now there are just not enough hours in a day).
After all this preliminary intro info you rightfully ask, “,so what is she involved with now?” Just a couple days ago, in her blog comment “Will New Legislation Actually Improve Pet Food Safety?” Susan asked the question “Food safety advocates believe The Food Safety Enhancement Act will be the much needed answer to a series of nationwide recalls and lack of consumer confidence with food safety. Will this new legislation do anything to protect the safety of pet food?”
For those of you who haven’t followed her blog, it has to be said that Susan has made it her mission and priority to fight for improvements of pet nutrition. If she feels that requires her getting involved at the legislation level of that segment of problems, then she doesn’t mind that either. And when I say “fight”, I can tell you Susan means it. If she believes a letter to a congress man/woman is necessary she will just do that. Or getting the President involved? She will try that too without even thinking twice. And she never gets tired, even if after many attempts she does not too often find an open ear. She just remains persistent. She is realistic enough to not expect too much coming from the latest change in government. Like she puts it: “Knowing that the FDA has allied itself with pet food industries in the past (and currently), I have my doubts that benefits within The Food Safety Enhancement Act will actually reach pet food; dog food and cat food safety is last on a long list of ‘things’ to do. When you consider that presently the FDA, in defiance of Federal law, allows pet food to include diseased and/or dying livestock animals (and the diseases and chemicals in their bodies) as pet food ‘meat’ ingredients, when you consider that past laws required the FDA to complete pet food safety measures that they were ignored (http://www.truthaboutpetfood.com/articles/127/1/FDA-Ignores-Pet-Food-Safety-Deadline/Page1.html), I have little hope that The Food Safety Enhancement Act will do anything to ensure the safety of pet food for our furry family members for a long, long time.”
So what’s her plan? “We cannot get discouraged (believe me I understand if you are), we must continue to write our law makers and decision makers. We must become a constant reminder in their email boxes that our pets are important; although they can’t vote, we can!”
And just a couple days later she showed what she meant. Under “Pet Food Warning Labels” she reported:
“The Obama Administration has pledged to create an unprecedented level of openness and public participation in government. The FDA, in an attempt to abide by the Administration, has formed a ‘FDA Transparency Task Force.’ The following is an initial transparency guideline recommendation to the FDA regarding pet food. Please add your signature.Barely two months into his presidency, President Obama sent a memorandum to the Heads of Executive Departments and Agencies of U.S. government. Dated January 21, 2009, the memorandum titled ‘Transparency and Open Government’, stated “Transparency promotes accountability and provides information for citizens about what their Government is doing. (http://www.whitehouse.gov/the_press_office/Transparency_and_Open_Government/).
Although the President’s memorandum required that “executive departments and agencies to take specific actions implementing the principles set forth” within 120 days, as typical fashion, the FDA stretched the deadline a few weeks to announce (on June 2, 2009 – exactly 131 days) to announce they have developed a task force seeking recommendations for “enhancing the transparency of the agency’s operations and decision-making process.” (http://www.fda.gov/NewsEvents/Newsroom/PressAnnouncements/ucm163899.htm)”
Susan has composed a letter to the FDA Transparency Task Force and needs our help. I figured the least I can do is pass on her pledge: Click here to access Susan’s article and letter and to add your name to the FDA letter.
Susan asks: “PLEASE forward this article and signature request to every pet owner you know. There are 74 million homes in the United States that own a pet. My goal is to collect One Million Signatures to send to the FDA. There is Power in numbers. To gain the signature of one in 74 pet owners seems to be a very conservative goal. One million signatures on the other hand will be an extremely powerful message to the FDA. “
Assuming that most of you are on the same page with Susan and myself I am sure we can drum up quite a few supporters. While we (the people of this blog) may not be able to come up with the expected One Million signatures, I say every single one counts and brings us closer.
All I have left to say is a “Thank you” to Susan. All of us truly appreciate your time and energy in this so very important matter. Following your relentless efforts is a great pleasure and for people like myself devoted to the health of our companion animals it is comforting to know that there are others too fighting for the “unwritten” rights of our beloved pets.
cc: Susan Thixton
She is the publisher of the PetsumerReport.com, which is an on-line pet food evaluation and rating service. As of today she has developed and compiled an extremely informative database of over 1,000 pet food products, for each of those products providing a great number of details. Her evaluations include listings of proteins, health promoting ingredients, controversial ingredients, comments about by-products and chemicals, positives and negatives, information about the manufacturers and more. Also included, if necessary, are so called “Red Flags”, which are warnings about unfavorable circumstances. All this information she collects and then works it into a simple rating system based on quality ingredients with the result of each product being rated on a scale from 1 to 5 “Paws”. To make the information collected most objective, Susan contacts the manufacturers asking questions without giving away her “true” identity, just as any pet owner would and can do. The service is available to any interested party on a subscription basis at a very affordable price. I personally use her database all the time as a basis and part of my daily work in evaluating and comparing pet foods for our clients.
But that is not enough for Susan. She also publishes her blog TruthAboutPetFood.com, I guess I don’t have to further explain what it is all about, its name gives it away. Some of you may have noticed that I list her blog as one of the ones I follow very closely for obvious reasons. Just a few months ago I came with Susan to an agreement that allows me to use some of her comments either partially or in full on this blog as I see fit. In return I am supposed to write a comment here and there for hers (and yes, Susan, I promise I will. Right now there are just not enough hours in a day).
After all this preliminary intro info you rightfully ask, “,so what is she involved with now?” Just a couple days ago, in her blog comment “Will New Legislation Actually Improve Pet Food Safety?” Susan asked the question “Food safety advocates believe The Food Safety Enhancement Act will be the much needed answer to a series of nationwide recalls and lack of consumer confidence with food safety. Will this new legislation do anything to protect the safety of pet food?”
For those of you who haven’t followed her blog, it has to be said that Susan has made it her mission and priority to fight for improvements of pet nutrition. If she feels that requires her getting involved at the legislation level of that segment of problems, then she doesn’t mind that either. And when I say “fight”, I can tell you Susan means it. If she believes a letter to a congress man/woman is necessary she will just do that. Or getting the President involved? She will try that too without even thinking twice. And she never gets tired, even if after many attempts she does not too often find an open ear. She just remains persistent. She is realistic enough to not expect too much coming from the latest change in government. Like she puts it: “Knowing that the FDA has allied itself with pet food industries in the past (and currently), I have my doubts that benefits within The Food Safety Enhancement Act will actually reach pet food; dog food and cat food safety is last on a long list of ‘things’ to do. When you consider that presently the FDA, in defiance of Federal law, allows pet food to include diseased and/or dying livestock animals (and the diseases and chemicals in their bodies) as pet food ‘meat’ ingredients, when you consider that past laws required the FDA to complete pet food safety measures that they were ignored (http://www.truthaboutpetfood.com/articles/127/1/FDA-Ignores-Pet-Food-Safety-Deadline/Page1.html), I have little hope that The Food Safety Enhancement Act will do anything to ensure the safety of pet food for our furry family members for a long, long time.”
So what’s her plan? “We cannot get discouraged (believe me I understand if you are), we must continue to write our law makers and decision makers. We must become a constant reminder in their email boxes that our pets are important; although they can’t vote, we can!”
And just a couple days later she showed what she meant. Under “Pet Food Warning Labels” she reported:
“The Obama Administration has pledged to create an unprecedented level of openness and public participation in government. The FDA, in an attempt to abide by the Administration, has formed a ‘FDA Transparency Task Force.’ The following is an initial transparency guideline recommendation to the FDA regarding pet food. Please add your signature.Barely two months into his presidency, President Obama sent a memorandum to the Heads of Executive Departments and Agencies of U.S. government. Dated January 21, 2009, the memorandum titled ‘Transparency and Open Government’, stated “Transparency promotes accountability and provides information for citizens about what their Government is doing. (http://www.whitehouse.gov/the_press_office/Transparency_and_Open_Government/).
Although the President’s memorandum required that “executive departments and agencies to take specific actions implementing the principles set forth” within 120 days, as typical fashion, the FDA stretched the deadline a few weeks to announce (on June 2, 2009 – exactly 131 days) to announce they have developed a task force seeking recommendations for “enhancing the transparency of the agency’s operations and decision-making process.” (http://www.fda.gov/NewsEvents/Newsroom/PressAnnouncements/ucm163899.htm)”
Susan has composed a letter to the FDA Transparency Task Force and needs our help. I figured the least I can do is pass on her pledge: Click here to access Susan’s article and letter and to add your name to the FDA letter.
Susan asks: “PLEASE forward this article and signature request to every pet owner you know. There are 74 million homes in the United States that own a pet. My goal is to collect One Million Signatures to send to the FDA. There is Power in numbers. To gain the signature of one in 74 pet owners seems to be a very conservative goal. One million signatures on the other hand will be an extremely powerful message to the FDA. “
Assuming that most of you are on the same page with Susan and myself I am sure we can drum up quite a few supporters. While we (the people of this blog) may not be able to come up with the expected One Million signatures, I say every single one counts and brings us closer.
All I have left to say is a “Thank you” to Susan. All of us truly appreciate your time and energy in this so very important matter. Following your relentless efforts is a great pleasure and for people like myself devoted to the health of our companion animals it is comforting to know that there are others too fighting for the “unwritten” rights of our beloved pets.
cc: Susan Thixton
Saturday, February 21, 2009
Dog Food: FDA tags on ingredients? Growers don’t have separate fields for dogs and people.
One of the tasks I like the most about my job at the store is talking to pet food manufacturers. Especially when I can talk to the owners. See, since the companies I trust when it comes to pet food are usually small to at the best medium sized businesses, they give you their honest, untainted opinion about the issues on hand. And because most of them are also the founders of their companies, they typically are very passionate about their product and you find out the real reason why they got involved in this business. Typically they are pet owners themselves and have had their fair share of bad experiences with commercially produced and mass marketed pet food. While all of them are in business to make money, their main objective, unlike presidents and CEO’s of companies traded on Wallstreet, is still their product and less market shares and profits.
Recently I had a chance to once again catch up with Mark Hayward, founder and owner of Timberwolf Organics. We discussed the subject of myths and misconceptions of dog foods. I (PFE) asked: “Mark, many pet food manufacturers make certain claims about their pet food. These include phrases such as human grade, antibiotic and hormone free and meat based, to name just a couple of them. What’s your take on this? Are these just true facts or just misleading marketing claims, or should I better say, false statements? I knew I am going to get him going again on this subject. Here is what he (MH) told me:
“We all know about these manufacturer claims about pet food. It got to a point where a pet owner does not know what to believe anymore. Let me say this up front: Many are really half true and that could be construed as being misleading.
It is a fact that federal labeling law precludes pet food manufacturers from including "misleading" statements on their bag. For example: Some say that they use only antibiotic and hormone free chicken, lamb etc. That is not exactly true. It is against federal law for chicken to be labeled as hormone free. That's because growers may not use hormones on chickens. To label your chicken as hormone free would imply that your chickens are the only ones that are hormone free when in fact they all are! What happens with other animals used for human consumption is that they must test free of hormones, antibiotics or pesticides before slaughter. It usually takes three to five days to clear their systems of any chemicals. Those animals that are earmarked for slaughter are kept free of chemicals for several days and then butchered. When I think of "antibiotic and hormone free" I think of an animal that has been raised chemical free, not just for a few days. A play on words perhaps but it borderlines on fraud. What the consumer needs to do is ask if it is Certified Organic, "pasture grazed only" or imported from a country that restricts the use of chemicals if that is what he wants. Of course he will pay a lot more.
Another one is: "Our meat comes from USDA inspected plants".
All slaughter houses that process for human consumption must be USDA inspected.
One natural dog food company claims: "Digest is the full guts including the manure".
Not true. It is made from whatever it is named for (chicken digest, liver digest etc.) and is digested by enzymatic activity and then dried. We do not use digest in our formulas but there is nothing wrong with it.
A natural food supplement maker that lists molasses as the second ingredient claims: "We use molasses because it is a nutrient not a sugar.
Molasses contains many nutrients and is technically not a sugar but it contains 60% sugars by weight and 20% water. Maybe it is not thought of as a sugar in Fufu Land but most of the world uses it as a sweetener. Dogs love sugar and it’s added mostly for palatability. If sugar must be used to help preserve a product, then molasses would of course be better than sucrose or dextrose, but only if it’s necessary.
The same supplement maker also claims: "Our product contains natural enzymes and probiotics that are naturally present in food".
Even if that were true, because you are only adding 1 teaspoon of supplement, it would only contain enough enzymes to assist in digesting that one teaspoon. If you ask them what the enzyme levels are they will not tell you. That is because they are so low they cannot be measured. If you want to replace the enzymes lost in the food due to processing you must add enough to assist in digesting the full amount of food you are feeding. However, this is expensive to do.
My favorite is "Made with only 100% human grade ingredients."
One quick way to determine if this is not true, other than cost, is if the food contains any "meals". Guess what? There is no such thing as human grade chicken meal or lamb meal. I don’t know of any restaurant where you can say, "Waiter, may I have some beef meal to go with my baked potato?" Or "May I have my chicken meal on a bun please?" The meat starts out as human grade because remember it’s from an inspected plant, but does not receive an inspection sticker because it’s not intended for human consumption so cannot be labeled as human grade. There are different grades (classifications) of meals however and are graded or classified by protein content, ash content and price. Some are of very high quality. For example, our lamb meal is imported from New Zealand and is a special low ash, only 8% and high protein, 70% lamb meal that we have classified and most of the bone is filtered out. All lamb, chicken, beef meals contain a lot of bone because it’s made from what is left over from cutting away steaks or boneless chicken breast for example. It’s the most expensive and probably the best lamb meal in the country as it’s made from the organs and contains a lot of blood, which gives it a very complete amino acid profile. Most lamb meals are high in ash and are low (50%) in protein. We searched six different suppliers before finding the current suppliers for chicken meal and for lamb meal. Is it human grade? Come on, man, I'm listening?”
PFE: “No, you just said that there is no such thing as a human grade meal. Already then. But how about foods that list meat?"
MH: “Good question, pretty clever! Let me tell you: First, only a handful of mills have the equipment to add meat. Some companies may list meat but actually use meal. Of those that actually can add meat it’s not quite what you would expect. It’s usually mechanically deboned and mixed with water to make a slurry that is pumped into the extruder. The most you can use in a formula is limited to about 30% but can be as little as 3%. What starts out as chicken with 78% moisture is now perhaps 90% moisture cooked down to 10%. That 30% you started out with is now about 3.3% or less dry matter. To get the protein up you must now add corn gluten meal or another protein source. Corn gluten meal is a good protein source, it’s high in the sulfur containing amino acids, but a lot of people, myself included prefer an animal based protein which means you must add animal meals which means it is not 100% human grade.”
PFE: "What about the other ingredients?"
MH: “The brown rice I get in looks just like the brown rice on your supermarket shelf, it’s clean and looks indistinguishable. The only difference is that it doesn’t have a FDA tag on it. Our oats are of exceptional quality. Higher in linoleic and alpha linoleic acid than locally grown oats because of the cold, probably grown organically as well and they’re the same oats that are supplied to food processors. Growers don’t have separate fields for dogs and people. The point I’m trying to make is that I have trouble believing that a company would pay five times as much for the same ingredient just to get that FDA sticker. Let me give you an example: I buy a chicken fat from a company that supplies soup manufacturers etc. If I buy a tanker of fat it doesn’t have to have an FDA tag and my price is $.11 per pound. If I buy less it must have an FDA tag and the price goes to $.58 per pound. Same product. That chicken fat is apparently human grade but I cannot call it that. A lot of my ingredients are human grade, some even certified organic but at the end of the day I cannot make the claim 100% human grade because it ‘s not, but neither can any other company unless maybe they are charging $2 to $5 per pound.
Another example is that if a truck load, that’s 40,000 lbs of frozen whole broilers were purchased for half a buck per pound, and if a custom chicken meal were produced, it would be exorbitant in cost. Chicken meal is made from chicken meat, usually mechanically de boned, that is put into a vat and is brought to the proper temperature and pH and then enzymes are added. The meat is broken down into a liquid and either spray dried or roller dried into a fine powder. Now go back to the truck load of chickens at half a buck per pound. It takes several pounds of chickens to make one pound of chicken meal. So let us say 7 pounds times .50 equals $3.50 plus the rendering charge. Let’s assume $4.00 per pound okay? I am using about 50% chicken meal so $4.00/2 is $2.00+ per pound of dog food my cost. Just for ingredients. Not including herbs, oils, probiotics etc. Does any of this make sense to you?
One natural dog food company uses poultry meal but lists on their ingredient label chicken meal, turkey meal. AAFCO allows listing animal meals by particular animal if you know what animal was used in making it. If the meal is made from more than one animal or a composite you may list all the animals used in making it. What they mean however is "chicken/turkey" meal for poultry or if you know the exact percentages than you may list them where they should appear in order of weight on the label but not chicken meal, turkey meal as the first two ingredients. Chicken meal and turkey meal gives the impression that the food is meat based when in fact it is not.
One question you can ask a dog food company to determine if it’s meat based or grain based is "what percentage of your formula is animal meals?" or "what’s the percentage of protein that is animal based?" or "how many pounds of animal meals are used per ton of your formula?" They probably will not tell you or say, "That is proprietary." We use 48 to 52% chicken, lamb or fish meals by weight or 900 to 1100 pounds per ton! Put another way, 91% of our protein is animal based. That is meal not meat. If someone tells you they use 1000 pounds of meat per ton that is equal to only 200 pounds of chicken meal or ten percent. Another way is to look at the calcium content. Chicken, lamb and meat meals are usually 4 to 5% calcium, special graded low ash meals with lower levels of calcium can be used but are up to 3 times as expensive, so if a company claims to be using 50% animal meals by weight and their calcium is only 1.2% then you know something somewhere does not add up. Or maybe they are using new math. The only reason we disclose this is that it’s very expensive and not many other companies will do this and those that do will have to raise their prices. Of course someone may tell you they use a high amount but if so the kibble should be very dark. Our Lamb, Barley and Apples kibble is almost black.
Now that you have listened to me, at least you'll know what is in the food. If I decide to put in goat's eyes, tongue of wren and pickled fish pan fried in roasted sesame oil you'll know it. None of my formulas contain 4D animals, simple or white carbohydrates, dextrose or other sugars for palatability enhancement, soy, BHT, BHA or Ethoxyquin. I personally have sold and used a lot of specialty and super premium foods and have seen more positive results and heard more positive feedback with this food than any other. I invite you to go to my testimonials page and read some of the testimonials.”
PFE: “Thank you Mark, this was quite interesting. As always, when talking to you, I have learned a lot”
MH: “I hope I have answered some of your questions, but don't take my word. Call the FDA or AAFCO or some feed ingredient suppliers and see what they say.”
If you want to find out more about Mark’s line of pet food go to Timberwolf Organics.
Recently I had a chance to once again catch up with Mark Hayward, founder and owner of Timberwolf Organics. We discussed the subject of myths and misconceptions of dog foods. I (PFE) asked: “Mark, many pet food manufacturers make certain claims about their pet food. These include phrases such as human grade, antibiotic and hormone free and meat based, to name just a couple of them. What’s your take on this? Are these just true facts or just misleading marketing claims, or should I better say, false statements? I knew I am going to get him going again on this subject. Here is what he (MH) told me:
“We all know about these manufacturer claims about pet food. It got to a point where a pet owner does not know what to believe anymore. Let me say this up front: Many are really half true and that could be construed as being misleading.
It is a fact that federal labeling law precludes pet food manufacturers from including "misleading" statements on their bag. For example: Some say that they use only antibiotic and hormone free chicken, lamb etc. That is not exactly true. It is against federal law for chicken to be labeled as hormone free. That's because growers may not use hormones on chickens. To label your chicken as hormone free would imply that your chickens are the only ones that are hormone free when in fact they all are! What happens with other animals used for human consumption is that they must test free of hormones, antibiotics or pesticides before slaughter. It usually takes three to five days to clear their systems of any chemicals. Those animals that are earmarked for slaughter are kept free of chemicals for several days and then butchered. When I think of "antibiotic and hormone free" I think of an animal that has been raised chemical free, not just for a few days. A play on words perhaps but it borderlines on fraud. What the consumer needs to do is ask if it is Certified Organic, "pasture grazed only" or imported from a country that restricts the use of chemicals if that is what he wants. Of course he will pay a lot more.
Another one is: "Our meat comes from USDA inspected plants".
All slaughter houses that process for human consumption must be USDA inspected.
One natural dog food company claims: "Digest is the full guts including the manure".
Not true. It is made from whatever it is named for (chicken digest, liver digest etc.) and is digested by enzymatic activity and then dried. We do not use digest in our formulas but there is nothing wrong with it.
A natural food supplement maker that lists molasses as the second ingredient claims: "We use molasses because it is a nutrient not a sugar.
Molasses contains many nutrients and is technically not a sugar but it contains 60% sugars by weight and 20% water. Maybe it is not thought of as a sugar in Fufu Land but most of the world uses it as a sweetener. Dogs love sugar and it’s added mostly for palatability. If sugar must be used to help preserve a product, then molasses would of course be better than sucrose or dextrose, but only if it’s necessary.
The same supplement maker also claims: "Our product contains natural enzymes and probiotics that are naturally present in food".
Even if that were true, because you are only adding 1 teaspoon of supplement, it would only contain enough enzymes to assist in digesting that one teaspoon. If you ask them what the enzyme levels are they will not tell you. That is because they are so low they cannot be measured. If you want to replace the enzymes lost in the food due to processing you must add enough to assist in digesting the full amount of food you are feeding. However, this is expensive to do.
My favorite is "Made with only 100% human grade ingredients."
One quick way to determine if this is not true, other than cost, is if the food contains any "meals". Guess what? There is no such thing as human grade chicken meal or lamb meal. I don’t know of any restaurant where you can say, "Waiter, may I have some beef meal to go with my baked potato?" Or "May I have my chicken meal on a bun please?" The meat starts out as human grade because remember it’s from an inspected plant, but does not receive an inspection sticker because it’s not intended for human consumption so cannot be labeled as human grade. There are different grades (classifications) of meals however and are graded or classified by protein content, ash content and price. Some are of very high quality. For example, our lamb meal is imported from New Zealand and is a special low ash, only 8% and high protein, 70% lamb meal that we have classified and most of the bone is filtered out. All lamb, chicken, beef meals contain a lot of bone because it’s made from what is left over from cutting away steaks or boneless chicken breast for example. It’s the most expensive and probably the best lamb meal in the country as it’s made from the organs and contains a lot of blood, which gives it a very complete amino acid profile. Most lamb meals are high in ash and are low (50%) in protein. We searched six different suppliers before finding the current suppliers for chicken meal and for lamb meal. Is it human grade? Come on, man, I'm listening?”
PFE: “No, you just said that there is no such thing as a human grade meal. Already then. But how about foods that list meat?"
MH: “Good question, pretty clever! Let me tell you: First, only a handful of mills have the equipment to add meat. Some companies may list meat but actually use meal. Of those that actually can add meat it’s not quite what you would expect. It’s usually mechanically deboned and mixed with water to make a slurry that is pumped into the extruder. The most you can use in a formula is limited to about 30% but can be as little as 3%. What starts out as chicken with 78% moisture is now perhaps 90% moisture cooked down to 10%. That 30% you started out with is now about 3.3% or less dry matter. To get the protein up you must now add corn gluten meal or another protein source. Corn gluten meal is a good protein source, it’s high in the sulfur containing amino acids, but a lot of people, myself included prefer an animal based protein which means you must add animal meals which means it is not 100% human grade.”
PFE: "What about the other ingredients?"
MH: “The brown rice I get in looks just like the brown rice on your supermarket shelf, it’s clean and looks indistinguishable. The only difference is that it doesn’t have a FDA tag on it. Our oats are of exceptional quality. Higher in linoleic and alpha linoleic acid than locally grown oats because of the cold, probably grown organically as well and they’re the same oats that are supplied to food processors. Growers don’t have separate fields for dogs and people. The point I’m trying to make is that I have trouble believing that a company would pay five times as much for the same ingredient just to get that FDA sticker. Let me give you an example: I buy a chicken fat from a company that supplies soup manufacturers etc. If I buy a tanker of fat it doesn’t have to have an FDA tag and my price is $.11 per pound. If I buy less it must have an FDA tag and the price goes to $.58 per pound. Same product. That chicken fat is apparently human grade but I cannot call it that. A lot of my ingredients are human grade, some even certified organic but at the end of the day I cannot make the claim 100% human grade because it ‘s not, but neither can any other company unless maybe they are charging $2 to $5 per pound.
Another example is that if a truck load, that’s 40,000 lbs of frozen whole broilers were purchased for half a buck per pound, and if a custom chicken meal were produced, it would be exorbitant in cost. Chicken meal is made from chicken meat, usually mechanically de boned, that is put into a vat and is brought to the proper temperature and pH and then enzymes are added. The meat is broken down into a liquid and either spray dried or roller dried into a fine powder. Now go back to the truck load of chickens at half a buck per pound. It takes several pounds of chickens to make one pound of chicken meal. So let us say 7 pounds times .50 equals $3.50 plus the rendering charge. Let’s assume $4.00 per pound okay? I am using about 50% chicken meal so $4.00/2 is $2.00+ per pound of dog food my cost. Just for ingredients. Not including herbs, oils, probiotics etc. Does any of this make sense to you?
One natural dog food company uses poultry meal but lists on their ingredient label chicken meal, turkey meal. AAFCO allows listing animal meals by particular animal if you know what animal was used in making it. If the meal is made from more than one animal or a composite you may list all the animals used in making it. What they mean however is "chicken/turkey" meal for poultry or if you know the exact percentages than you may list them where they should appear in order of weight on the label but not chicken meal, turkey meal as the first two ingredients. Chicken meal and turkey meal gives the impression that the food is meat based when in fact it is not.
One question you can ask a dog food company to determine if it’s meat based or grain based is "what percentage of your formula is animal meals?" or "what’s the percentage of protein that is animal based?" or "how many pounds of animal meals are used per ton of your formula?" They probably will not tell you or say, "That is proprietary." We use 48 to 52% chicken, lamb or fish meals by weight or 900 to 1100 pounds per ton! Put another way, 91% of our protein is animal based. That is meal not meat. If someone tells you they use 1000 pounds of meat per ton that is equal to only 200 pounds of chicken meal or ten percent. Another way is to look at the calcium content. Chicken, lamb and meat meals are usually 4 to 5% calcium, special graded low ash meals with lower levels of calcium can be used but are up to 3 times as expensive, so if a company claims to be using 50% animal meals by weight and their calcium is only 1.2% then you know something somewhere does not add up. Or maybe they are using new math. The only reason we disclose this is that it’s very expensive and not many other companies will do this and those that do will have to raise their prices. Of course someone may tell you they use a high amount but if so the kibble should be very dark. Our Lamb, Barley and Apples kibble is almost black.
Now that you have listened to me, at least you'll know what is in the food. If I decide to put in goat's eyes, tongue of wren and pickled fish pan fried in roasted sesame oil you'll know it. None of my formulas contain 4D animals, simple or white carbohydrates, dextrose or other sugars for palatability enhancement, soy, BHT, BHA or Ethoxyquin. I personally have sold and used a lot of specialty and super premium foods and have seen more positive results and heard more positive feedback with this food than any other. I invite you to go to my testimonials page and read some of the testimonials.”
PFE: “Thank you Mark, this was quite interesting. As always, when talking to you, I have learned a lot”
MH: “I hope I have answered some of your questions, but don't take my word. Call the FDA or AAFCO or some feed ingredient suppliers and see what they say.”
If you want to find out more about Mark’s line of pet food go to Timberwolf Organics.
Thursday, January 22, 2009
Salmonella infected Peanut Butter: Risk to animals minimal, more likely to affect people
Just as I clicked the “Publish” button on my comment about the PetSmart treat recall related to the peanut butter problem, I came across this report published by CNN. According to the article, the apparent risk to animals is minimal, but it could affect people who handle treats. Outbreak of salmonella has sickened at least 486 people and killed six. Here is the complete article:
“Pet treats recalled in salmonella outbreak
(CNN) -- PetSmart is recalling seven of its Grreat Choice dog biscuit products because they contain peanut products made by a company that has been linked to a salmonella outbreak in 43 states and Canada, the Food and Drug Administration said Wednesday.
Dr. Stephen Sundlof, a veterinarian who is the director of the FDA's Center for Food Safety and Applied Nutrition, said that the risk to animals is minimal but that people who handle contaminated treats could come in contact with the salmonella bacteria.
"It's especially important that children wash their hands after feeding treats to pets" because the bacteria could be on the surface, Sundlof said.
Sundlof said dogs aren't immune to salmonella and in some cases could get sick. They may be lethargic or get bloody diarrhea. On the other hand, they may never show symptoms at all but could still carry the bacteria.
The outbreak of salmonella typhimurium has sickened at least 486 people, killing six, and has been linked to products manufactured by the Peanut Corp. of America in its Blakely, Georgia, plant.
PetSmart said it "is not aware of any reported cases of illness related to these products" but has removed the products from the shelves as a precautionary measure.
Centers for Disease Control and Prevention officials say that of the nearly 500 people sickened, 107 have been hospitalized. The most recent death was recorded Saturday.
The first illnesses were reported September 8, and the most recent illness was reported January 8. The CDC still considers it an ongoing outbreak.
The CDC does not consider salmonella typhimurium any more virulent than any other strain. The strain "is not more or less than we would expect in a normal outbreak," said Dr. Robert Tauxe, deputy director of the CDC Division of Foodborne, Bacterial and Mycotic Diseases.
The FDA had reported that some of the samples from the Georgia plant tested positive for salmonella. On Wednesday, it said one sample was found in a crack of a floorboard near a bathroom and another was found on the floor near pallets in another room. Neither sample tested positive for the specific strain found in the sickened people, however.
Sundlof said the lack of a match makes no difference from a regulatory point of view.
"Those salmonella are not supposed to be there. Having salmonella in the plant is not supposed to happen, regardless if it's the same strain or not," he said.
Peanut butter produced by Peanut Corp. in Georgia is not sold in individual jars in grocery stores, health officials say. However, it is sold to institutions such as nursing homes, schools and cafeterias. Peanut Corp. also produces peanut paste, which is commonly used in cookies, crackers, cake, ice cream and other products, including the Grreat Choice dog biscuits.
Peanut Corp. released a statement Wednesday stating that the company is cooperating with federal and state officials and that it "will address the agency's findings when they are shared with us."
"To date, we have nothing in writing from the agency that documents its findings that result from its ongoing investigation and testing onsite at our facility. We trust that at some point they will share this with us, and PCA will respond accordingly."
Minnesota health officials were the first to link the specific strain of salmonella that made three people ill in one nursing home to an open 5-pound container of peanut butter. Then Connecticut health officials found the same strain in an unopened tub of Peanut Corp.-produced peanut butter.
After interviewing 57 sick people and 399 healthy people, CDC officials found "an association of illness and prepackaged peanut butter crackers in general." These people had consumed specific brands of products, particularly the Austin and Keebler brands, which are manufactured by the Kellogg Co. and have been recalled.
CDC officials recommend that consumers who are uncertain about a product throw out all recalled products. They also suggest avoiding any other products they think could contain ingredients manufactured by Peanut Corp. until they are certain they aren't being recalled.
About 125 products have been recalled. The FDA maintains a regularly updated list at its Web site.
The Consumers Union, publisher of Consumer Reports, issued a news release calling for "President Obama to appoint a new FDA commissioner as soon as possible to address peanut butter contamination and a growing list of other food safety problems." “
“Pet treats recalled in salmonella outbreak
(CNN) -- PetSmart is recalling seven of its Grreat Choice dog biscuit products because they contain peanut products made by a company that has been linked to a salmonella outbreak in 43 states and Canada, the Food and Drug Administration said Wednesday.
Dr. Stephen Sundlof, a veterinarian who is the director of the FDA's Center for Food Safety and Applied Nutrition, said that the risk to animals is minimal but that people who handle contaminated treats could come in contact with the salmonella bacteria.
"It's especially important that children wash their hands after feeding treats to pets" because the bacteria could be on the surface, Sundlof said.
Sundlof said dogs aren't immune to salmonella and in some cases could get sick. They may be lethargic or get bloody diarrhea. On the other hand, they may never show symptoms at all but could still carry the bacteria.
The outbreak of salmonella typhimurium has sickened at least 486 people, killing six, and has been linked to products manufactured by the Peanut Corp. of America in its Blakely, Georgia, plant.
PetSmart said it "is not aware of any reported cases of illness related to these products" but has removed the products from the shelves as a precautionary measure.
Centers for Disease Control and Prevention officials say that of the nearly 500 people sickened, 107 have been hospitalized. The most recent death was recorded Saturday.
The first illnesses were reported September 8, and the most recent illness was reported January 8. The CDC still considers it an ongoing outbreak.
The CDC does not consider salmonella typhimurium any more virulent than any other strain. The strain "is not more or less than we would expect in a normal outbreak," said Dr. Robert Tauxe, deputy director of the CDC Division of Foodborne, Bacterial and Mycotic Diseases.
The FDA had reported that some of the samples from the Georgia plant tested positive for salmonella. On Wednesday, it said one sample was found in a crack of a floorboard near a bathroom and another was found on the floor near pallets in another room. Neither sample tested positive for the specific strain found in the sickened people, however.
Sundlof said the lack of a match makes no difference from a regulatory point of view.
"Those salmonella are not supposed to be there. Having salmonella in the plant is not supposed to happen, regardless if it's the same strain or not," he said.
Peanut butter produced by Peanut Corp. in Georgia is not sold in individual jars in grocery stores, health officials say. However, it is sold to institutions such as nursing homes, schools and cafeterias. Peanut Corp. also produces peanut paste, which is commonly used in cookies, crackers, cake, ice cream and other products, including the Grreat Choice dog biscuits.
Peanut Corp. released a statement Wednesday stating that the company is cooperating with federal and state officials and that it "will address the agency's findings when they are shared with us."
"To date, we have nothing in writing from the agency that documents its findings that result from its ongoing investigation and testing onsite at our facility. We trust that at some point they will share this with us, and PCA will respond accordingly."
Minnesota health officials were the first to link the specific strain of salmonella that made three people ill in one nursing home to an open 5-pound container of peanut butter. Then Connecticut health officials found the same strain in an unopened tub of Peanut Corp.-produced peanut butter.
After interviewing 57 sick people and 399 healthy people, CDC officials found "an association of illness and prepackaged peanut butter crackers in general." These people had consumed specific brands of products, particularly the Austin and Keebler brands, which are manufactured by the Kellogg Co. and have been recalled.
CDC officials recommend that consumers who are uncertain about a product throw out all recalled products. They also suggest avoiding any other products they think could contain ingredients manufactured by Peanut Corp. until they are certain they aren't being recalled.
About 125 products have been recalled. The FDA maintains a regularly updated list at its Web site.
The Consumers Union, publisher of Consumer Reports, issued a news release calling for "President Obama to appoint a new FDA commissioner as soon as possible to address peanut butter contamination and a growing list of other food safety problems." “
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