AAFCO is concerned with issues involving animal feed, and it advises the FDA and USDA on such matters. But it has no regulatory authority itself, it does not test pet food, and it does not issue any kind of certificate that a pet food is "complete and balanced." When that statement goes on the label, the company making the food is solely responsible for it being there. AAFCO doesn't verify. AAFCO publishes minimum standards for "complete and balanced nutrition." But serious questions have recently been raised about those standards which may have more to do with making pet food profitable than making pets healthy. AAFCO makes no secret of the fact that it wants to cooperate with, not regulate, members of the pet food industry. The industry is made up of rendering plants; manufacturers of vitamin premixes and flavorings; and multinational corporations.
Commercial pet food (pet food sold in supermarkets, pet stores, feed stores and veterinary offices in bags or cans) is a mixture of rendered (cooked) animals including road kill, unwanted animal parts such as diseased organs from slaughter houses, chicken feet, beaks, feathers and excrement. It is blended with a vitamin mix, doused with flavoring and coloring to mask the gray color, put into a bag, box or can, labeled and sold. Except for brands that use "human-grade" meat, all commercial pet food is, literally, garbage that nobody wants. If something that resembles human food gets into commercial pet food (excluding "human-grade" pet food), it happens accidentally. Some argue that cats and dogs do not need to eat filet mignon. That's true, but here is the problem.
Millions of animals and their owners are relying on the promise that commercial pet food is "complete nutrition." Some manufacturers even go so far as to warn people not to feed their animal(s) genuine food -- only their products -- as if it would be dangerous to feed little Fluffy meat and vegetables. That would suggest that pet food provides something unique and special. A glimpse behind the scenes, however, reveals that there is little science behind commercial pet food.
A Good Look at
"Complete and Balanced"
Researchers do not even agree how to verify "adequate" nutrition. Is adequate nutrition what will enable an animal to maintain its weight over a period of a few weeks? A few years? Is adequate nutrition what it takes to keep an animal from developing obvious deficiency diseases, such as soft bones? Or is it what it takes to keep a dog or cat from developing skin disorders, cataracts or cognitive dysfunction over the long haul? Currently the most basic standards, like amino acid requirements, are being challenged. Things like antioxidants, methylation enhancers, and mineral balance aren't even on the map yet.
So how is it that a manufacturer can claim "complete and balance?" What are the criteria? One way a manufacturer can prove that its dog food is "complete and balanced" is to feed the product to eight dogs for six months. If six of the eight dogs make it through the study without dying of a nutritional disease or losing more than 15% of their body weight, the food is "complete and balanced."
Who created these standards? The pet food industry working through AAFCO. And while they appear to be similar to those set by the National Research Council (NRC), the organization that sets RDAs for humans, they are not. AAFCO standards set minimal nutritional requirements -- not recommended daily allowances. AAFCO standards do not meet NRC standards which are based on 100% bioavailable purified food. Pet food is neither, yet AAFCO requirements use the same figures in most cases. A report in the Journal of Nutrition skewers the AAFCO claim of complete and balanced nutrition. "Until the AAFCO allowances are adequately referenced citing experimental data, they lack scientific veracity. Although the pet food industry has been given a set of tables to use to make a nutritional claim on the label, the claim lacks integrity and will remain so until measured bioavailability values are included in the calculation of nutrients allowances."
Bioavailability is a crucial issue. Bioavailability is how much of the food can actually be utilized by an animal for critical functions like the growth of cells. A bowl of chicken feet does not provide the same nutrition as a bowl of chicken thighs. The "meat" part of commercial pet food is whatever decomposing slaughter house refuse and dead animals the rendering plant took in that day. It could be a lot of chicken feet or a few chicken feathers. The company that makes it cannot tell you what's in a can, box or bag of commercial dog or cat food.
FDA Regulation of Pet
The letters were sent to Iams regarding Iams/Eukanuba dog food. Neither the FDA nor Procter & Gamble, which now owns Iams/Eukanuba, wants the public to see them. Motions have been filed in lawsuits to keep them secret and they are not available on the FDA website. However, the Life Extension Foundation obtained copies under the Freedom of Information Act. It shows that Iams and Eukanuba's dog foods did not meet AAFCO standards even though the AAFCO stamp of approval appeared on the label.
The FDA sent the letters after being notified by Nutro, another pet food company, that feeding studies commissioned by Nutro on Iams/Eukanuba had to be stopped because dogs couldn't maintain their weight on the products. Maintaining weight is a critical issue for AAFCO approved pet food. It is the only way to determine whether an animal is getting enough nutrients under current AAFCO testing guidelines. If the animal cannot maintain its weight on the prescribed amount of food, the animal is not only getting insufficient calories. In addition, it is not getting sufficient vitamins, minerals and protein as well. Iams tried to argue that its purpose for failing to meet AAFCO minimum standards was its concern over pet obesity. The company did not explain why it didn't increase the nutrients to make up for the caloric loss, nor indicate on the label that Iams is a diet food. The company also changed the numbers on the nutrient equations and tried various other explanations as to why their food didn't meet minimal standards. The FDA shot them down as "disingenuous."
So why didn't the food meet AAFCO standards? Probably money. When Procter & Gamble bought Iams and Eukanuba, it changed the formula of the dog foods to a cheaper recipe. Out went the meat, in went "by-product meal" (rendering plant product). Sorghum (cattle feed) and barley replaced rice. Feeding amounts were reduced 25%. When the dust cleared, these "premium" foods could compete price-wise with grocery store dog food. In fact, they were grocery store pet food with fancy labels. This is what got the ire of Nutro and Kal Kan, both of which have lawsuits against P&G's Iams/Eukanuba for false advertising and misleading labeling. A class-action suit on behalf of consumers has just been settled by the California firm of Wasserman, Comden, Casselman & Pearson. The other lawsuits are still pending as of this writing (May 2003).
AAFCO approves pet food but it doesn't regulate it. What about the Food and Drug? What is the FDA doing to regulate pet food? It is spending a lot of time on a joint effort with the AAFCO to create an "enforcement event" targeting dietary supplements/vitamins, herbs, antioxidants. The first "target" was rumored to be glucosamine and MSM -- proven supplements for arthritis support. That target was abandoned when veterinarians and others voiced major objections. New targets are planned including garlic. Investigators have been appointed, and surveillance has been set up. An FDA/AAFCO coalition believes that launching a war against these kinds of "unapproved" supplements and additives in pet foods will protect the health of cats and dogs. They want to keep dangerous supplements out of pet food, but meanwhile, what's being kept in pet food?
Commercial Pet Food
Although commercial pet food manufacturers deny it, it is widely reported that euthanized cats and dogs are sent to rendering plants and made into cat and dog food. In 1997, the FDA undertook a study to determine the level of pentobarbital in commercial dry dog food and whether or not cat and dog DNA is found in such dog food. It did not find cat/dog DNA. Another study is currently underway using different methodology that will address the same issue.
However, the agency did find what are apparently toxic levels of pentobarbital in some food. As of this writing, the agency has not released the data from the study, (only a brief synopsis). The agency estimates that dogs could consume up to 4 mcg of the anesthesia a day per kilogram of the dog's weight in dry dog food. An 80 pound dog could get about 160 mcg of pentobarbital a day. In an eight-week FDA study, fifty (50) mcg of pentobarbital per day was the limit used by researchers. As expected, they did not see any ill-effects. Despite finding what appears to be toxic levels of pentobarbital in dog food, the FDA states that ill-effects are "unlikely."
We asked Dr. William J. Burkholder if the FDA has found out what is causing the pentobarbital tolerance problem- the problem that prompted the FDA study in the first place. Burkholder is a "pet food specialist" at the FDA and a member of the "pet food committee" of AAFCO. He told us that the agency hadn't found what's causing the problem. When asked if more studies were going to be done, he replied, "no."
Keep Them Healthy
Issues beyond whether an animal can simply maintain its weight or avoid an obvious vitamin deficiency are not addressed by "complete and balanced" pet food. Protection of vital organs with antioxidants and amino acids, immune enhancement, longevity and the prevention of cancer are best achieved for our "best friends" by a high-quality diet and scientifically-proven supplements.
For example, studies have shown that if an animal is given vitamin E and other antioxidants before it undergoes physical trauma, it is more likely to survive. Likewise, if a cat or dog gets high levels of taurine and L-carnitine in its diet, it is less likely to get an enlarged heart (cardio-myopathy). The same amino acids given as supplements can also reverse heart conditions if they do occur. Probiotics can potentially protect dogs and cats from killer bacteria like salmonella, and provide a good source of B vitamins. And, although cats can't convert beta-carotene to vitamin A, they can use it to enhance their immune systems. These are only some of the ways our "best friends" can benefit from the same high-quality nutrients that protect us.
Jack the cat was living the good life in Hollywood and seemed to have the world by the tail until the day he couldn't move and stopped eating. His alarmed owner rushed him to the veterinarian where he was told that Jack had serious kidney problems and nothing much could be done. No reason could be identified Jack's condition at six-years-old, young for a cat which can live 20 to 30 years. Jack's owner refused to give up, however, and took his faithful friend to another vet for a second opinion. The second vet was trained in both traditional and alternative veterinary medicine.
When Jack landed on the examining table, he was anorexic and anemic. About half his body mass had disappeared. The laboratory test results were grim. Jack's creatinine and BUN (blood urea nitrogen) were ten-times normal. An ultrasound showed bloated, water-logged kidneys. The veterinarian didn't have much hope, but offered to do surgery to clear any potential blockage and get a better grip on the situation. Jack's owner agreed, and a biopsy was taken during the procedure.
Continued - Page 2 |
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