Safe Pet Foods and Truthful Labels: Are They Possible?
Elizabeth Hodgkins DVM, Esq.

Commercial Pet Foods Are More Unsafe Than You Think!

The recent recall of millions of cans and bags of commercial pet food after contaminants were found in these products has caused pet owners all over the world to wonder just how safe commercially-produced products are. It is well that they do so. The most recent safety crisis in dog and cat foods is only the latest in a shocking list of such problems in the past several years. Within the last 18 months, commercial products have been recalled several times because of adulteration with fungal toxins as well as excessive supplementation with Vitamin D. In the more distant past, thousands of pet cats consuming commercial pet foods suffered and died of a nutritional deficiency of the essential amino acid taurine, before it was discovered by accident that many popular feline foods available then were dangerously deficient in this nutrient. Furthermore, many of today’s pet foods contain massive excesses of nutrients like highly processed simple carbohydrate, known to be harmful to humans in these amounts.

New US Legislation Will Not Improve Safety of Pet Foods

Despite recent action taken by the US government to address this very serious shortfall in pet food quality, the legislation that has emerged in that effort does not fix this problem. In fact, that legislation only calls for better tracking and reporting of contamination once it is identified in ingredients and finished foods. While there is language in the law that suggests there must be “more uniform” standards for pet food labels, this is a very nebulous requirement considering that pet food labels in the US are already extremely uniform. The problem with pet food labels is not lack of uniformity, but a lack of truthful information on those labels.
Essentially, this new legislation leaves intact the entire regulatory infrastructure and legislative loopholes that have existed for decades in the United States, and which have allowed unsafe, even toxic foods to be freely marketed to pet owners all over the world. What makes this situation all the more shocking is the fact that every bag and can of recalled product in the recent and more distant recalls contained label guarantees that told the consumer that they are tested safe to feed for the lifetime of the pet! Clearly, those label guarantees were false and misleading. Nothing has changed in the past several decades to remedy this terrible situation, and our pets continue to pay the price. If Canadians wish to have safe pet foods packaged within truthful labels that do not mislead purchasers about the actual testing and quality control used in their production, it is up to the Canadian government, and Canadians themselves, to make this happen.

History of the Pet Food Industry

To understand how we have managed to arrive at this troubling state of affairs, it is necessary to understand the history of the pet food industry itself. By its own admission, and that of governmental regulators as well, the commercial pet food industry provides a constructive outlet for the “scraps” of human food production. Meat that is condemned or unacceptable for human consumption for any of a myriad of reasons, and vegetable matter unsuitable for use in human food product production, is shunted to the manufacture of pet foods. Pet food purchasers must understand this reality; pet foods are affordable for pet owners, and highly profitable for the industry, because the average quality of pet food ingredients is well below the standards required for humans.
Because of this disquieting truth, the pet food industry has, for its entire 60 year history, operated “in the shadows.” Regulations that attempt to insure the safety and wholesomeness of human food have been understood not to apply to pet foods, by their very nature. This is not to say that there are no good quality ingredients used to make pet foods, only that there is no real requirement for wholesomeness and no effective regulation of the industry. The quality of a company’s products is entirely a voluntary matter. In fact, the US government has recently recognized the industry as essentially “self-regulating.”

How Does the Pet Food Industry Regulate Itself?

If government is not regulating the pet food industry, who is? The truth is that the industry has over the past several decades has formed a very solid coalition among all of the major and most of the minor producers to “agree” upon a set of ground rules to provide a level playing field for all participants in this very crowded and highly competitive industry. Through the efforts of the Pet Food Institute (PFI) and the American Association of Feed Control Officials (AAFCO), vague ingredient definitions and a non-scientific set of nutrient content standards have been adopted and implemented across the entire industry. Because of this, it is almost impossible for the pet food purchaser to know from the astonishingly uniform labels that appear on all products just what is actually contained within the bags or cans on the store shelf. It is even more difficult for consumers to know how safe, or nutritionally adequate those foods are for exclusive feeding to their pets. Today, it is impossible for pet owners to read a label and tell which products are superior, or inferior, to others. This is a result of the deliberate “homogenizing” of pet food labels by the industry itself.
Because essentially all commercial pet foods carry meaningless AAFCO adequacy statements and ingredient definitions that deny the consumer real information about what is inside the package, the larger pet food companies have turned to other, less product-quality-focused methods to attract customers. Perhaps the most brilliant and successful of these have been the efforts of some manufacturers to enlist the veterinary profession to advocate and endorse specific products to their clients. It is well known that veterinarians are among the most respected and trusted of all professionals in society. When the pet’s doctor insists that a particular food is the very best choice for a pet, many if not most pet owners will listen. To gain the veterinarian’s endorsement, certain pet food companies have convinced the profession that they produce well tested, well researched, proven products with scientifically verified efficacy. Unfortunately, the science that actually supports even the best pet foods is scant and flawed in design with biased results interpretation.
The industry as a whole has accomplished a remarkable feat in convincing veterinarians and pet owners that only commercial pet foods can be trusted as safe and balanced nutrition for the pet. Pet owners and their pet health care providers now consider the natural diets of the dog and cat to be dangerous, even deadly, for those very animals. Sadly, pet owners have come to be viewed as incompetent simpletons, incapable of providing healthful diets for their pets, even though society trusts them to do just that for their children. The pet food industry insists that pet owners not trouble themselves learning anything about their pets’ nutritional needs, but rather rely solely on the industry’s good intentions and “perfect” development and manufacturing capabilities. With veterinarians endorsing this paternalistic view, what pet owner would argue? After all, don’t the labels of pet foods certify their quality?
Even though commercial pet foods have repeatedly shown themselves to be subject to serious contamination and catastrophic imbalances of various nutrients, the trust of pet owners and veterinarians alike goes on, bolstered by label claims that promise excellence. This unquestioning trust, and the label claims that create that trust, is the root cause of the present problem, and it threatens to be the cause of many more to come.

How Is It Possible For Pet Foods to Carry Unjustified Label Claims?

Naturally, pet owners find it hard to understand how this state of misleading, even fraudulent claims on pet foods can exist. The answer is simple, lack of effective regulation from outside the industry and a failure of the industry to self-regulate. The blind trust of pet owners and veterinarians makes pet food highly profitable, and without regulatory or market-driven incentive to invest in better quality assurance and scientific testing, no corporation is going to make that investment. It simply does not make business sense.
The claims that pet foods carry would be unthinkable for human foods. In fact, many of these claims are like those earned by pharmaceutical companies for drug products that have undergone a decade of rigorous clinical trials. The standards for pet food claims of quality, safety and medical efficacy are unconscionably low because government has not demanded otherwise from an industry that has been regulating itself for 60 years!
The pet food industry will argue that it is one of the most highly regulated industries there is. This is a statement of appearances only. There does appear to be a “cast of thousands” running around in tight circles regulating this industry. Between FDA (the Food and Drug Administration), AAFCO, and PFI, it does, indeed, seem that there are layers and layers of stringent regulation of pet food products. What is not so apparent is the cooperative and collaborative relationship between these groups. All desire the same thing; peace among the parties, profitability for the companies, and tax revenues for the government. Unfortunately, this leaves the pet owner, and the veterinarian, in the dark. This also leaves the pet at great risk of poor nutrition, and even intoxication or death when this unregulated industry makes a mistake.

How Do We Correct This Absurd State of Affairs?

The best news in this otherwise dismal situation is that starting to correct it is not that difficult. This is especially true in countries where pet food regulation is not already so complex and ponderous that meaningful change becomes impossible. Those who desire a regulatory environment that stimulates truly healthful products to develop and thrive, and where truth-in-labeling is fundamental, must act now to make sure that government and consumer work together to achieve these ends.
To be sure, regulations requiring enhanced ingredient and finished product quality testing can be a positive step. But we must look beyond this most obvious and often difficult step. Legal requirements for pre-and post-production contaminant testing are by their nature imperfect, costly for government to enforce, and are never as efficient as creating incentives for the pet food companies to produce better products themselves. Such incentives best come from the marketplace itself.
To do this, I propose that governments eliminate all unsubstantiated health and disease management label claims. Just as human foods are marketed without health or disease management claims, pet foods should also not carry such claims, unless such claims are substantiated scientifically according to the same standards that apply to health and medical claims for human foods. See attached “Supplemental Testimony for the Agriculture Appropriations Subcommittee Hearings, April 12, 2007 for the outline of how such “truth-in-labeling” regulations might be set out.
Although pet food companies will insist that all of their label claims are absolutely valid, and have been proven so, this simply not the case. Witness:

AAFCO feeding trials require only 10 weeks to 6 months of feeding of a “representative” food to 6 animals. This is the same kind of trial that permitted foods with deficiencies of taurine to be fed to millions of cats, with the result that thousands were sickened and most of these died from dilated cardiomyopathy. Nothing in the format of the AAFCO feeding trials requirements has changed since that time.

Evidence for the continuing inadequacy of feeding trials appeared recently when a major pet food manufacturer had to recall food that had been supplemented with excess Vitamin D, which caused excessive calcium levels in pets fed this food. These foods had carried AAFCO feeding trial guarantees on their labels, but the problem, as in the taurine situation, was not discovered until owned-pets became sick.

All of the recalls in the past many years have been for foods that carried AAFCO certification language. How can a food that has been “feeding trial tested” and found complete and balanced for feeding to pets turn out to be toxic in the short term or the long term? The answer is that the vast majority of the cans and bags of food you see in the store have never been tested for anything, despite the label language! Even the small numbers of foods that have been tested have undergone testing for such a short time, and in so few animals, that no long-term claims can be made for those foods, if genuine scientific standards are applied.

Despite all of this, pet food labels tell the prospective purchaser that the food in the package should be trusted absolutely to provide safe and highly nutritious food for long-term feeding of the pet.

The only long-term studies that are ever performed on commercial pet foods are those that occur in owned pets whose caregivers have purchased those foods for feeding to their pets. And these studies do disclose the problems that long-term studies would have disclosed had they been performed properly before the label claims were applied.

Medical claims are similarly unfounded and untested prior to marketing. The best example of this is the marketing of feline diets for “urinary tract health” (specifically, a type of crystal or stone known as struvite urolithaisis). When these foods were originally introduced, they had never been tested for long-term safety in the laboratory. Decades later, we now know that those foods caused a disease of a different type (calcium oxylate urolitiasis) in many of the pets they were supposed to be treating for the original problem. This very serious side effect came to light in owned pets whose owners spent considerable time and money to treat with the original diet. It was not discovered prior to the marketing of many millions of dollars of the untested diet. Many pet food companies copied the original “urinary tract diet formulas,” with similar results in people’s pets.

The pet food industry’s response was to develop a new diet that is said to correct this problem. Unfortunately, this new diet is no better tested than the old diet, and we cannot be confident that this diet to correct the old one will not cause a new problem, yet to be discovered in the decades ahead as this food is vigorously prescribed by veterinarians, and purchased widely by concerned owners trying to save their pets.

When will this scientific insanity end? It appears that no matter how many problems arise in commercial pet foods, no one, not the pet food companies, nor the regulators of the pet food industry, do anything meaningful to bring the actual safety and quality of pet foods into conformance with the high-sounding label claims these foods carry. Why should the pet food industry be allowed to do something no human food industry would be allowed to do?

I believe the solution is to eliminate the claims, and allow pet foods to compete in the marketplace without them, as human foods do. In time, if certain pet food companies wish to make those claims again, they should be required to prove their foods deserve them. The industry will never take this step on its own. Government must step up and make this change to protect the pet owner and the pet.

I went so far as to send Nutro 6 samples (2 cans each of all 3 varieties) along with her “renal failure” bloodwork report. These cans sat at their office for over a week and were never tested. In addition I also sent cans to UC Davis to be tested. On April 9, UC Davis contacted my
vet to let them know that they did in fact find the melamine in all 3 cans.
Please google – Sacbee, April 11, Pet food Recall to read article.
It seems as if every company is blaming one another.
My frustration is that this could have been recalled at least 1 week prior from Nutro, but of course they were “too busy”. I believe the recall wouldn’t have happened if it weren’t for UC Davis. I’m afraid that all of these tainted pet foods would still be on the shelf.
Please let me know if your pet was affected by the pet food from the expanded recall on April 11, and when they were affected.
Cleo is doing better but had to spend 10 days under 24 hour care at the pet emergency hospital. She is home now.

Thanks and my heart goes out to all that have been affected by this “Horrible Coincidence”.

For those interested in viewing the hearings they are available at http://appropriations.senate.gov/webcasts.cfm.

Speaking as one who has lost a beloved pet (Max, our cat) I think that if it weren’t for the dedication and commitment of Sen. Durbin and the rest of the sub-committee, the pet food industry would have been able to sweep this entire issue under the rug. While we have lost a pet that cannot be replaced I believe we will have answers and, more important, real solutions that will prevent companies like Menu Foods from allowing this to happen again.