FDA refuses to provide pet food ingredient definitions to pet owners

The FDA has recently refused to provide pet owners the legal definitions of pet food ingredients. In other words, every single pet owner in the US is forced to buy pet products while being denied access to knowing what is in that product.

What does “Made with Real Chicken” mean when it is printed on a pet food label? Or what does “Beef” mean listed in the ingredient panel on your pet’s food label? Or what about those controversial pea ingredients “Pea Protein” or “Pea Starch” – what do they mean?

I can’t tell you what they mean – because pet food ingredient definitions are “confidential commercial information” per the FDA.

Just so you know…

Each and every ingredient in your pet’s food has a legal definition that is VERY different than the same food ingredient in your (a human’s) food. As example, Chicken in a human food means ONLY USDA inspected and passed chicken meat. But chicken in pet food means something VERY different.

When a pet food label ingredient list includes the word “chicken” – it could be USDA inspected and passed chicken meat (just like in human food) OR it could be condemned chicken meat, chicken bones with no meat, condemned chicken bones, chicken skin with no meat, condemned chicken skin or a long list of other possibilities.

The problem is that most pet owners don’t know that the ingredient chicken listed on a pet food label can mean so many different things – because – pet owners have no access to the legal definition of pet food chicken.

And it gets worse.

If you’d want to look up what the ingredient ‘beef’ means that listed on your pet’s food label…nope, you can’t look it up – Google doesn’t have the definition. If you’d want to look up the definition of the currently controversial pet food ingredients ‘pea protein’, ‘pea starch’, ‘pea fiber’…you can’t. Pet owners can find the definition of the human food processed pea ingredients – Google has that information. But Google has no information on the pet food ingredient definitions that are very different than the human food counterparts; pet owners are denied public access to ANY pet food ingredient definitions.

So…to the point of this post…

We asked FDA for those definitions, with the intention of sharing them with pet owners. FDA most certainly has the definitions, the definitions are part of law that FDA enforces. On December 1, 2017we filed a Freedom of Information Act request with FDA asking for:

Records requested are definitions of all feed/pet food ingredients, which includes the common ingredient name, description, and any appropriate limitations for its use. These records are published in the AAFCO 2017 Official Publication under a Memorandum of Understanding agreement between FDA and AAFCO. Should the 2018 AAFCO Official Publication definitions be currently available to FDA, the 2018 definitions are requested.”

Eighteen months later, the FDA finally decided to respond to our FOIA request telling us:

We are denying your entire request. Specifically, we are denying a copyrighted document. You can obtain the information you requested directly from AAFCO:
AAFCO Headquarters Office 
1800 S. Oak Street, Suite 100, 
Champaign, IL 61820-6974 
Phone: 217-356-4221 — Fax: 217-398-4119 
Email: aafco@aafco.org

Exemption (b)(4) Trade secret and confidential commercial information.

The following sections of the implementing regulations of FDA and reasons applicable to this denial contained in the Code of Federal Regulations (CFR), Title 21 are
• 20.61(b)(c) Trade secret and confidential commercial information, in general, and information, not previously publicly disclosed
.”

The FDA said “no” – pet owners will not be allowed to know what is in their pet’s food because it is “confidential commercial information“.

To read the full FDA response, Click Here.

Consider this…

The FDA is charged with enforcing the laws and pet food ingredient “confidential commercial information” (definitions).

How in the world can a federal agency legally enforce “confidential commercial information” onto the public when the public has no clue to what is being enforced?

Would you buy a car not knowing ANYTHING about it other than seeing the outer shell? You are not allowed to know what’s under the hood, denied the ability to see the interior, you have no information on the car other than seeing the shape and the color. Would you buy it?

Pet owners are put in this exact situation when buying pet food. They are provided ONLY minimal information – basically only the shape and color of the product they trust their pet’s life with. How in the world can this happen?

It happens because of a special ‘confidentiality agreement’ FDA has with AAFCO; they call this confidentiality agreement a “Memorandum of Understanding“. The FDA/AAFCO agreement states:

The FDA and AAFCO agree to the following:

A. AAFCO maintains definitions of various feed ingredients, which includes the common ingredient name, description, and any appropriate limitations for its use, and publishes the currently accepted feed ingredient definitions in the AAFCO Official Publication (OP).

The very first agreement item – AAFCO gets to “maintain” or own the legal definitions of pet food ingredients. Because of this special agreement between FDA and AAFCO – pet food ingredient definitions become “confidential commercial information“. Pet owners are denied the ability to understand what chicken or beef or pea protein or every other ingredient listed on their pet food label means.

Angry? You deserve to be.

Tell the FDA the current Memorandum of Understanding agreement is little more than a confidentiality agreement. We (Association for Truth in Pet Food) are waiting for a meeting date to be scheduled to meet with FDA on this very issue. In the meantime, please send the FDA your sentiments. Example email:

AskCVM@fda.hhs.gov 
I am contesting the current Memorandum of Understanding agreement between FDA and AAFCO and any future agreement that prevents my public access to pet food ingredient definitions. Currently the agreement is little more than a confidentiality agreement that denies my and other pet owners rights to understand what we are feeding our pets. Legal definitions of pet food ingredients and all applicable rules should be public information. I contest any agreement that prevents public access to this significantly important pet food information.

Also send an email to your elected officials in Washington DC. Example email:

I want to make you aware of an official agreement FDA currently has with the Association of American Feed Control Officials (AAFCO); Memoradum of Understanding MOU 225-07-7001. In essence, this agreement is a confidentiality agreement that denies the public access to any and all pet food ingredient definitions. Directly due to this FDA and AAFCO agreement, I am not allowed to know what is in my pet’s food. FDA has recently stated pet food ingredient definitions are considered “confidential commercial information” (FOIA request 2017-10123 provided June 27, 2019). This MOU agreement between FDA and AAFCO must be amended in order to provide all pet owners with full access to ingredient definitions.

Please tell the FDA on my behalf to properly amend MOU 225-07-7001 so that all of my pet’s food ingredient definitions are public information.

Don’t Give Up On Your Anxious Cat

Getting to know Link

My rescue cat, Link, has always been the most gentle and loving cat I have ever had the pleasure of knowing. He greets every person with a chirp and promptly jumps on their lap for pets. He will even gently grab your hand to let you know he really likes the pets you are giving him.

However, he has always been quite skittish since I adopted him. Loud noises and too much activity are just too much for him to handle. Needless to say, this type of behavior is usually due to stress and trauma, such as the two home changes he was forced to go through.

The other thing you should know about Link is that he is polydactyl. This means that he has an extra “toe” on each paw. This does not affect his ability to walk, jump, or climb just like any other cat. In fact, I actually think this improves it. However, because link doesn’t completely look like a “normal” cat, he is much less likely to be adopted.

Unfortunately, many polydactyl cats are also mistreated by people because of their differences, but there is no way for us to know exactly what Link has had to endure over the span of his life.

Owners declare their No. 1 pet food issue — Can you guess?

(This article is credited to Dr. Karen Shaw Becker )

 

A 2016 Nielsen survey asked French and U.S. pet owners to evaluate thousands of real-world product concepts for commercial dog and cat food. The survey results showed the most important feature for the vast majority of respondents was pet food containing no genetically modified (GM) ingredients.1

Among those who want to feed four-legged family members non-GM food, at least half believe GMOs (genetically modified organisms) are unnatural and have the potential for unknown long-term health effects, and many are willing to pay more for non-GMO products. This is a very good thing, because the so-called “science” on this subject has tried hard to convince us GM ingredients are entirely harmless in both human and pet food. Here’s a brief and disturbing description of the GMOs used in U.S. crops:

“In the United States, GMO crops processed into food include yellow corn, soybeans and cotton, in the form of cottonseed oil.

Companies such as Monsanto and DuPont engineer these plants to contain a pesticide derived from the Bacillus [thuringiensis] bacteria, to resist applications of herbicides (particularly glyphosate, known by the brand name [RoundUp]) and to have other characteristics.”2

Put another way, these are unnatural, human-engineered plants that are “born” containing pesticides and with the ability to withstand heavy exposure to glyphosate (RoundUp), a known cancer-causing agent.

Many consumers no longer trust science or scientists

Do we really want to risk eating this stuff or feed it to our dogs and cats? No, we don’t, according to a NUTRO™ survey of 1,500 U.S. dog owners. Two-thirds (65%) of those surveyed prefer non-GMO ingredients in their pet’s food.3 Consumers believe natural farming techniques are better for the environment and prefer pet food ingredients with minimal or no synthetic pesticides, herbicides and fertilizers.

Thankfully, it seems that when scientists talk up the supposed benefits of genetically modified food, more and more people are tuning them out. “Many consumers no longer trust science or scientists,” says Debbie Phillips-Donaldson of Petfood Industry, “at least not when it comes to their own food or pet food.”4

In response to scientists’ claims that GM products are safe, consumer watchdog groups argue that substances such as trans fats, BPA, red dye no. 2 and leaded gasoline were also once considered safe. There’s also the argument that much of the research done on GMOs and glyphosate has been funded by entities with something to gain.

For an example of how scientists have manipulated the facts about GMOs to suit their own purposes, I recommend reading “The UK’s Royal Society: a Case Study in How the Health Risks of GMOs Have Been Systematically Misrepresented.”

Studies show GM foods have toxic effects in animals

The results of a study 10 years ago showed that genetically modified corn causes significant kidney and liver disease in rats after only a 90-day feeding trial and has a negative effect on other organs as well, including the heart and spleen.5

A republished 2012 lifetime study of rats fed a diet containing GM corn shows they not only died earlier than rats on a standard diet but developed mammary tumors and severe kidney and liver damage as well. Half the male rats and 70% of females died prematurely, compared with 30% of males and 20% of females in the control group.6

The lead researcher, Gilles-Eric Seralini of the University of Caen, believes his results, which are based on the full lifespan of rats, give a more comprehensive and realistic view of the risks of GM corn than 90-day feeding trials. A rat at 3 months is still a young adult.

In a more recent study, rats fed GM corn for 90 days suffered serious damage to the surface mucous membranes of the jejunum, which is part of the small intestine.7 The damage included the villi, which are the finger-like structures in the intestine that absorb dietary nutrients.

The villi were misshapen and flattened, with some cells joined together. The mucosal glands (called crypts) were abnormal and blood vessels were congested. Inflammation was present around the damaged areas. The cells of the intestinal lining were abnormal in structure as well. In a 2009 report on GM foods that appeared in the journal Critical Reviews in Food Science and Nutrition, the authors write:

“Animal toxicity studies with certain GM foods have shown that they may toxically affect several organs and systems. The review of these studies should not be conducted separately for each GM food, but according to the effects exerted on certain organs it may help us create a better picture of the possible health effects on human beings.

The results of most studies with GM foods indicate that they may cause some common toxic effects such as hepatic, pancreatic, renal, or reproductive effects and may alter the hematological, biochemical, and immunologic parameters.

Small amounts of ingested DNA may not be broken down under digestive processes and there is a possibility that this DNA may either enter the bloodstream or be excreted, especially in individuals with abnormal digestion as a result of chronic gastrointestinal disease or with immunodeficiency.”8

Some veterinarians are speaking out against GM ingredients in pet food

Holistic and integrative veterinarians are increasingly convinced that many of the diseases we see in today’s pets could be, in part, related to GM foods. Though there is no objective evidence of this yet, according to my colleague Dr. Rob Silver, all veterinarians agree there has been an uptick in diseases such as allergies, gastrointestinal (GI) problems, cancer and neurodegenerative conditions in the past 10 to 20 years.9 The advent of GM foods in the 1990s “fits into this timing of disease increases,” he says.

According to Silver, genetic modification introduces foreign proteins that may encourage allergies, and the widely planted Bt corn, which makes its own insecticide, “could possibly cause leaky gut, the gateway to chronic disease.” Corn is a major component of most commercial pet foods.

“The big problem with commercial foods is that they are manufactured at high temperatures and pressures,” says Silver, which alters them and makes them “potentially more allergenic.” And commercial foods contain industrial ingredients that are “more likely to contain GM and herbicide contaminants.” GM foods may be causing heightened sensitivity to dietary ingredients, which may in turn be driving the increase in GI problems in pets.

To hear what other veterinarians, bioethicists and pet parents are saying about GM pet food, watch the following video created by leading GMO expert and consumer advocate Jeffrey Smith, founder of the Institute for Responsible Technology:

For more information, Smith’s organization has created a campaign at PetsandGMOs.com to protect pets from the health dangers of GMOs, RoundUp and other pesticides. There you can find out if the pet food you’re feeding your animal companion contains GM ingredients or other toxic chemicals.

More information for pet parents

Veterinarian Dr. Michael W. Fox, who also appears in the above video, has compiled an extensive list of the potential risks of genetically modified foods, including:

  • The toxic insecticidal agent Bacillus thuringiensis is present in most GM crops in the U.S. that wind up in animal feed and pet food.
  • The herbicides glufosinate and glyphosate are applied to millions of acres of genetically modified crops across the U.S. and other countries. These poisons are absorbed by the crops — which are engineered to be herbicide resistant — while decimating everything else growing in the area and much of the aquatic life in nearby bodies of water.

These herbicides cause kidney damage in animals, endocrine disruption and birth defects in frogs and are lethal to many amphibians. Glyphosate has also been linked to miscarriages, premature births and Non-Hodgkin lymphoma in humans.

  • Nutritionists and other health experts increasingly are connecting the rise in human allergies, including skin conditions and inflammatory GI disorders to broader consumption of GM foods and food additives — in particular, GM soy products containing novel proteins.

Dr. Fox suspects the high number of skin and food allergies, and other allergies associated with GI disorders are caused or aggravated by these novel proteins and other contaminants in genetically modified crops.

  • Independent animal feeding safety studies show adverse or unexplained effects of GM foods, including inflammation and abnormal cell growth in the GI tract, as well as in the liver, kidney, testicles, heart, pancreas and brain.
  • GM crops have proven to be unstable and prone to unplanned mutations — which means we don’t really know whether the food being grown from these plants is safe or nutritious.

Fox’s advice to pet parents is to buy only food with USDA Organic certification. He also advises to avoid all prepared foods, including cooking oils that contain corn and soy products, since these are the products most likely to originate from GM crops. In addition, I recommend omitting grains entirely from your carnivorous pet’s diet. Corn and soy ingredients are not biologically appropriate ingredients in dog and cat food, even if they are conventionally grown.

Both these ingredients are linked to a wide variety of health problems in companion animals, including allergies, skin disorders, oral disease, inflammatory bowel disease and cystitis.

Leash Training

Many people think that dogs just innately know how to walk politely on a leash, but this skill is something that needs to be trained. Fortunately, it’s one of the easier skills to teach a puppy. Dog-training expert and AKC Family Dog Training & Behavior columnist Kathy Santooffers the following tips:

puppy walking on a leash

Step 1: Training Your Dog to Walk on a Leash

Introduce him to the collar or harness and leash. Start out by letting him get used to wearing a collar or harness and a leash. Let him wear them for short periods of time, in the house, during which you are playing with him and giving him treats. The puppy should love “collar and leash time” because it represents food and fun.

Teach a cue. Introduce your puppy to a sound cue that means “food is coming.” Some people like to click and treat, some people use a word like “Yes,” and some people cluck their tongue. Whichever you use, the method is the same: In a quiet, distraction free area, with the puppy on a leash and collar, make the sound. The second your puppy turns toward you and/or looks at you, reward him with a treat. After a few repetitions, you’ll notice your puppy not only looking at you, but also coming over to you for the treat.

Make him come to you. While he’s on his way to you, still wearing the leash and collar, back up a few paces and then reward when he gets to you. Continue the progression until your puppy, upon hearing the cue noise, comes to you and walks with you a few paces. Remember that puppies have short attention spans, so keep your sessions short, and end them when your puppy is still eager to do more, not when he’s mentally exhausted.

Practice inside. Now that your puppy understands how to come to you, practice walking a few steps in a room with little distraction. Feeling and seeing the leash around him will be enough of a challenge. Offer treats and praise as your puppy gets used to coming to you, as described above, with a leash on.

Take it outside. Finally, you’re ready to test your puppy’s skills in the Great Outdoors. There will be new challenges with this step as all the sounds, smells, and sights your puppy encounters will be both intriguing and new to him. Be patient; keep the first walks short. While you’re on a walk, if your puppy looks as if he’s about to lunge towards something or is about to get distracted (you’ll notice this because you will keep your eyes on him at all times!), make your cue sound, and move a few steps away and reward his following you with a treat.

beagle walking on a leash

Step 2: Leash-Training Troubleshooting

As perfect as you want to pretend your puppy is, you’re likely going to run into some issues as he learns to walk on a leash. (And eventually, you’ll want to teach him loose-leash walkingso that he can pass his Canine Good Citizen test!) Here are a few tips on what to do if you’re having trouble, courtesy of the AKC GoodDog! Helpline.

If he pulls: If your dog starts pulling in the other direction, turn yourself into “a tree.” Stand very still and refuse to move until your dog comes back to you. Do not yank or jerk the leash, and do not drag your dog along with you. Alternative harnesses, like front-hook harnesses, and head halters are designed for dogs that tend to pull.

If he lunges: If your dog is going after something while on a walk — another dog, a car, or skateboarder, for example, try to redirect his attention with a treat before he has a chance to lunge and create space between you and the target. Be proactive. Get prepared before the target of his frustration gets too close. This type of behavior is more common in herding breeds, who like to chase.

If he barks: Some dogs have the habit of barking at other dogs while on a walk. Oftentimes, this behavior comes as a result of lack of exercise. Make sure your dog gets the proper amount of mental and physical stimulation for his breed. If this is still a problem, use the same process as you would if your dog is lunging at a ca r— create distance and offer treats before he starts to bark.

Gradually you’ll reduce the amount of treats and troubleshooting that your puppy needs during a walk, but you’ll always have some on hand to randomly reinforce good leash walking behavior!