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Rebuttal to Pet Food Industry Response to Hearings Held April 12, 2007
Today, April
13, 2007, the pet food industry has issued
a broadly published statement and Q & A to counter
testimony and questioning that occurred yesterday
in Washington DC
before the Agriculture Appropriations Subcommittee
investigating the recent pet food contamination recalls.
Much of what has been published is incorrect
and the industry’s way of trying to do damage
control. The
following is the text of the industry’s message
and my rebuttals to that message: (pet food statements
are in italics, my rebuttal in bold):
The pet food industry remains a partner
in the investigation with the FDA and has cooperated
with state and federal regulators since evidence leading
to the recall first surfaced. The industry will continue
cooperate fully with any other official investigations
relating to this incident.
The FDA’s investigation is ongoing and has not
reached any conclusions about how any foreign substances
entered the process. I think it’s presumptuous
to additional regulatory measures at this time. Only
when we have this information can we make an accurate
and informed decision.
The industry representative insisted that the industry is cooperating
fully in this investigation, yet when asked how long
it had taken Menu Foods to report to the FDA about
the toxins in their food, he admitted that he did
not know. The
time to report, which is well documented at 3 weeks,
would have been something he would have known had
the industry been fully involved and cooperating with
this investigation.
The industry wants this to go away, not be
fully investigated so that better quality control
measures can be implemented.
How Pet Foods
Are Regulated
Pet foods are one of the most highly regulated food
products. They are required by law to provide on their
labels more information than most human foods. State
departments of agriculture provide standards and enforcement
policies for regulation of manufacture of pet foods
resulting in safe foods. Ingredients in pet food must
be acceptable to state authorities. In the March 23
press conference Sundlof
also stated that regulation of pet foods is the same
as human foods.
Pet foods are far from regulated as
human foods are. 4D meat (meat from dead, dying, diseased
or disabled animals) CANNOT be used for human food,
but it CAN be used in pet foods and is used routinely
by at least some manufacturers.
Further, human food health claims are very
difficult for human food makers to get. Virtually
ALL pet foods contain unsubstantiated claims for safety,
completeness and balance that NO HUMAN FOOD in the
world would ever be able to get.
While some pet foods are likely to be adequate
food for pets, many are not, yet there is no testing
done to differentiate the good from the bad in this
self-regulated industry. FDA has delegated the responsibility
of pet food regulation to an association known as
AAFCO. AAFCO itself ADMITS it has NO regulatory AUTHORITY
or enforcement capabilities, so although there are
several layers of APPARENT regulation, there is actually
no regulation of pet foods today.
Pet food manufacturers are responsible for producing
safe products. The U.S. Food and Drug Administration
and state governments provide the rules, guidance
and oversight under which safe pet food is produced.
FDA requires pet food to be wholesome, contain no
harmful or deleterious substances, and to be truthfully
labeled.
Yes, pet food companies are responsible
for producing safe products, and they have failed
many times in the past, at least 3 times in the past
18 months. To say they are responsible for doing something
is quite different from saying they are ACTUALLY doing
it. The facts speak for themselves on this
point. The
pet food industry has breached the FDA’s mandate
of them because they are self-regulated!
How Ingredients
and Finished Pet Foods Are Tested
Pet food ingredients undergo significant testing for
safety and quality assurance including screening for
mycotoxins (including aflatoxin),
bacteria (including Salmonella and E.Coli)
and nutrient content. Furthermore the finished product
is analyzed to ensure appropriate nutrient levels,
evaluating protein (including 11 amino acids), fat,
fiber, vitamins, minerals and antioxidants.
This is an untruth. Many if not most
pet food ingredients undergo no testing whatsoever.
If this statement were true, we would not have repeated
pet food aflatoxin toxicity
problems as we do.
We also would not have had a recent and very
serious toxicity problem in a major pet food from
excess Vitamin D supplementation. This statement merely describes what is
SUPPOSED to happen, not what really DOES happen. The facts speak for themselves.
A Consumer's Guide to Pet Food: Valuable Information
for Pet Owners
Veterinarians agree that pets are living longer, healthier
lives since the use of commercially prepared
pet foods became widespread. Decades of research have
gone into the development of pet food to make sure
the special nutrition needs of pet dogs and cats are
met.
Veterinarians DO NOT
agree about this, they can’t, it is totally
unproven. Evidence about changes in the life span
of pets over the past several decades is sparse, and
no scientist would dare draw the conclusion that pets
today live longer on average than pets 30-40 years
ago, for example.
What does seem clear is that today’s
indoor pets
live much longer than those that live outdoors. The evidence for this conclusion is strong.
Those who would give
commercial pet food even partial credit for this increase
in life expectancy in the indoor pet, however, have
absolutely no evidence to back up this conclusion.
There are many factors that affect the life
span of pet animals under indoor and outdoor circumstances.
Indoor pets are more protected from death due
to automobiles and predators, they are more protected
from exposure to infectious disease and often receive
more medial care than outdoor pets, to name just a
few of the important differences between these two
groups. It
is easy to sweep commercial food consumption right
along with all of these other factors as contributing
to longer life in today’s pets. Unfortunately for this particular factor,
there is no reason to believe it has anything to do
with the longer life of house pets.
Let’s look at an analogy to understand
how this might be so.
Humans in the US enjoy
longer life expectancy today than they did fifty years
ago. During those decades of improving average
life span, those same people have consumed ever-increasing
amounts of fat-laden, sugary, carbohydrate-rich “fast”
food and other types of over-processed “convenience”
foods. We are far more obese today than in decades
past, and human nutritionists nag us endlessly about
changing our diets to include better quality, fresh
whole foods. Imagine anyone believing that this increasing
consumption of highly processed “fast”
foods and increasing obesity is the reason, or even
makes a positive contribution to our increasing life
spans! We
are living longer in
spite of our diets, not because of them.
Many other factors, such as less tobacco smoking,
the use of seatbelts, better prenatal and postnatal
care, and astonishing high-tech medical advancements
for defeating disease and injury account for our increasing
life spans. Our convenience-oriented diets are actually
working against longer life, but cannot defeat all
of these other strong protective factors in our lives.
So it is with our pets. When they live indoors, they live longer
than if they lived outdoors, but commercial foods
likely have no part in adding those extra years.
Like our own “overprocessed”
diets, they may even be depriving our pets of even
greater health and longevity. If you hear anyone make the flat statement
that pet are living longer BECAUSE of commercial foods,
demand to see the scientific data for that statement!
Question
What does "complete
and balanced" mean?
Answer
Unlike most foods for people,
many pet food products are designed to be the sole
source of nutrition for a pet dog or cat. Products
that are labeled "complete and balanced,"
as defined by the Association of American Feed Control
Officials (AAFCO), have been tested to make sure they
meet the complex nutritional requirements of a healthy
dog or cat.
No, they have NOT been tested to make
sure they meet the requirements of healthy pets! Only
a very few “sample” diets have even been
tested on any animals for even 6 months.
Considering that cats have a natural lifespan
of 20 years or more, and dogs can live 10-20 years
depending on breed, 6 months is NOT long enough and
6 animals is not anywhere close to a statistically
valid number to even prove a 6 month claim. This is one of the most serious and most
misleading of the untruths that pet food companies
make about their foods.
Question
What does it mean on a pet
food label that a product has been tested using animal
feeding trials?
Answer
There are two ways a pet food company can test
the nutrition of its products. One method is the use
of standardized animal feeding trials, designed by
the Association of American Feed Control Officials
(AAFCO), to make sure their products meet the complex
nutritional requirements of dogs and cats. The animals
in these tests are fed the food for six months and
are closely monitored to make sure they stay healthy.
A product using this test will have language similar
to the following on the label - "Animal feeding
tests using AAFCO procedures substantiate that Nancy's
Food for Dogs provides complete and balanced nutrition
for all life stages."
This is almost a completely truthful
answer, because it admits that this “study”
only last six months.
This answer omits two important factors: there
are only a handful of animals tested, and only a few
sample diets are even tested on those few animals
for those few months.
Question
Are fillers used in pet food?
Answer
Every ingredient used in
pet food is there for a reason. Decades of research
have gone into making pet foods that meet the nutritional
needs of dogs and cats. The makers of pet food do
not put in anything that's not needed.
There is almost no research on any
pet food anywhere that can be considered scientific
by any genuine scientist.
Whether reused vegetable oil and rendered animal
scraps and wood cellulose is
“needed” by any dog or cat is very highly
questionable by intelligent and well trained experts.
The cat has absolutely no need for carbohydrates,
for example, yet all dry cat food has PLENTY of this
cheap ingredient that is
required for dry food processing.
Further, the acids that pet food companies
put into “urinary tract diets” can and
do even cause other diseases, proving that those acidifiers
are not only not needed, but are even harmful to many
cats. Pet food companies absolutely DO put things
in pet food that are not needed and that can even
cause harm.
Question
What is ingredient "splitting?"
Answer
Some people incorrectly believe pet food makers
split up ingredients to give the illusion that some
ingredients are at higher concentrations than others.
Pet food makers are required to carefully label their
products according to stringent government regulations.
Just as the case with food for people, pet foods must
clearly state what ingredients are included in the
product. Each ingredient in pet food is there for
a reason and to serve a nutritional purpose.
The stringent ingredient regulations
have been developed by the industry in concert with
AAFCO. AAFCO has no real authority over the pet food
companies, and goes along with the desires of an industry
that, by the admission of the FDA, is a good way for
by-products of American agriculture to “dispose”
of those by-products of agriculture that are not fit
for or undesirable for humans to eat. Many ingredients in pet food serve no nutritional
purpose in our pets, but keep farmers and ranchers
from having to throw them away.
An example of ingredients splitting:
Pet food companies who wish to disguise the
amount of cereals in their products will list several
different cereals in stead of using just one (not
top quality cereals either) so that what meat IS in
their products will legally be listed as the one of
the first ingredients. In many, if not most of these
foods, cereal actually makes up the majority of the
food, but consumers see “chicken” as one
of the top 2-3 ingredients and think that chicken
is a predominant component of the food.
This is “smoke and mirrors.”
The regulations may demand that the
ingredients be listed in order of predominance, but
there is NO prohibition against the sleight of hand
described in this example.
The pet food industry is an ineffectively
regulated 15 billion dollar industry that produces
everything your pet eats, day in day out.
This should make you want to know a lot more
about what is going into those cans and bags, and
into your pet!
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