Akbash dog in field

Condemned, Inedible Meat & Poultry: It’s What’s in Pet Food

I know what you’re thinking: Not another alarmist pet food report. Stop with those stories already. Can’t you just tell me what’s a good pet food to buy, Mollie?

Oh, how I wish I could stop shouting from my soapbox, “Your pet food is poisoned! Your pet food is poisoned!” But, I can’t. Not a day goes by that I don’t discover some new, jaw-dropping, incredulous thing allowed in pet food. Just today, I came across this horrifying new tidbit: Meat and poultry processors are legally allowed to denature inedible (aka pet food /animal food) meat and poultry with anything they want.

Stay with me here, it’s a bit of a kerfuffle, but let me explain: According to US law, all meat and poultry not used as human food must be “denatured.”

What in the world is denaturing you ask?

The USDA requires, by law, that any and all meat and poultry not meant for human consumption must be destroyed. The primary method for destruction is achieved by denaturing it.

I already knew about denaturing, in fact I wrote about it in this informative article about denaturing last year.   But, what I didn’t know was that the USDA lets meat and poultry processors to use anything to destroy meat for human consumption.

Anything.

Anything can be used to denature meat and poultry – as long as it changes its character, so much so, that it could not ever be mistaken as something a human might eat.

According to the USDA (the agency responsible for regulating all meat and poultry processing in the US):

Type of Denaturant to Use on Meat or Poultry Condemned Carcasses, Inedible Parts or Other Products Not Intended For Human Food

The following regulations list denaturing agents and their intended uses for condemned or inedible meat or poultry products: 9 CFR 314.3(a), 325.11(a), 325.13(a)(1) through 325.13(a)(7) and 381.95.

Question: Can an establishment utilize denaturants other than those listed in each specific regulation to denature condemned or inedible carcasses, parts or other food products?

Answer: Yes.  The establishment may use any of the denaturing methods described in the regulations cited above as long as the denaturing agent is mixed intimately with all of the material to be denatured and applied in such quantity and manner that it cannot easily and readily be removed by washing or soaking. A sufficient amount of the appropriate agent shall be used to give the material a distinctive color, odor, or taste so that such material cannot be confused with an article of human food.  

The establishment can elect to use the same approved denaturant for all inedible and condemned carcasses, parts, or other food products, provided it meets the criteria above.

When verifying establishment denaturing procedures, IPP should focus primarily on whether the method ensures that the condemned or inedible materials are clearly distinguished from human food.

Can anything really be used to denature meat and poultry?

That virtually anything could be used to denature meat and poultry is astounding, considering the mind-numbing list of toxic chemicals they are already allowed to use, such as:

  •   Crude carbolic acid;
  •   Cresylic disinfectant;
  •   Kerosene, fuel oil, or used crankcase oil;
  •   FD&C green No. 3 coloring;
  •   FD&C blue No. 1 coloring;
  •   FD&C blue No. 2 coloring;
  •   Finely powdered charcoal or black dyes;
  •   Any phenolic disinfectant conforming to commercial standards CS 70-41 or CS 71-41 which shall be used in at least 2 percent emulsion or solution.
  •   A formula consisting of 1 part FD&C green No. 3 coloring, 40 parts water, 40 parts liquid detergent, and 40 parts oil of citronella;
  •   A 6 percent solution of tannic acid for 1 minute followed by immersion in a water bath, then immersing it for 1 minute in a solution of 0.022 percent FD&C yellow No. 5 coloring;
  •   A solution of 0.0625 percent tannic acid, followed by immersion in a water bath, then dipping it in  a solution of 0.0625 percent ferric acid;
  •   No. 2 fuel oil, brucine dissolved in a mixture of alcohol and pine oil or oil of rosemary, finely powdered charcoal;
  •   A 4 percent by weight of coarsely ground hard bone; or
  •   A 6 percent by weight of coarsely ground hard bone; or
  •   ‘other proprietary substance’ approved by the USDA

It boggles the mind to consider what other types of toxic chemical concoctions they could possibly want to use, other than the horrible ones already allowed by the USDA.

Where does the law say that inedible meat and poultry must be denatured?

PART 314—HANDLING AND DISPOSAL OF CONDEMNED OR OTHER INEDIBLE PRODUCTS AT OFFICIAL ESTABLISHMENTS

§314.3 Disposition of condemned products at official establishments having no tanking [rendering] facilities.

(a) Carcasses, parts of carcasses, and other products condemned…be destroyed…by incineration, or denatured with crude carbolic acid, or cresylic disinfectant, or a formula consisting of one part FD&C No. 3 green coloring, 40 parts water, 40 parts liquid detergent, and 40 parts oil of citronella or any other proprietary material…

(b) Inedible rendered animal fats shall be denatured by thoroughly mixing therein denaturing oil, No. 2 fuel oil, brucine dissolved in a mixture of alcohol and pine oil or oil of rosemary, finely powdered charcoal, or any proprietary denaturing agent …the chosen identifying agents shall be used to give the rendered fat so distinctive a color, odor, or taste that it cannot be confused with an article of human food.

I’ll bet you’re wondering…

Just what does the USDA mean by referring to meat or poultry as “inedible and condemned?”

Glad you asked.

According to the USDA, the definition of inedible and condemned meat and poultry is any material not passed by USDA inspectors for human consumption. All meat and poultry is divided by the USDA into one of two categories: It is either human “edible” or “inedible.” One is passed for human consumption and all the rest is deemed “condemned and inedible”. “Inedible” is defined by regulation as adulterated, uninspected, or not intended for use as human food. There is no third category for a feed grade or pet food grade meat or poultry; such a category does not exist within the USDA law. This is all their is:

Edible. Intended for use as human food.
Inedible. Adulterated, uninspected, or not intended for use as human food.

So, just to make sure I have spelled this out as plainly as possible: All meat and poultry that is in an animal feed or pet food that is not intended for human consumption, is therefore considered, by the USDA’s legal definition, to be “condemned and inedible.” Period. Full stop.

Why go through all the trouble of denaturing it?

You’re probably wondering, why is this crazy rule mandated by law?

For one reason: The USDA is in charge of making sure that meat and poultry is inspected and approved and safe for human consumption. In order to protect the consumer (humans only, I’m afraid), they want to make sure that none of the condemned material could ever be diverted back into the human food chain, even accidentally.

In order to make sure that never happens, it must be “destroyed.” Destruction occurs by denaturing it in such a way, by changing its color, odor or taste would identify it as something a human would never consider eating.

I know what your next question will be.

But, aren’t there reputable pet food companies out there that don’t use this stuff?

Is it possible for pet food companies to somehow circumvent USDA law and are able to get perfectly good by-products that have not been denatured?

I suppose – anything is possible.

Although, I find it difficult to understand how that would be possible, considering a.) it’s illegal to allow inedible meat and poultry from leaving a USDA plant without denaturing it first, b.) line speeds don’t allow for processors to divide condemned material from what might be perfectly good meat and poultry products, and c.) a plant could be shut down for allowing un-denatured meat or poultry from leaving an official establishment.

According to the USDA,

“…except for lungs, no condemned or inedible meat/poultry products can be shipped from the official establishment (USDA inspected plant) to a pet food manufacturer without it being denatured.
Unless it is identified as “required by regulations to deter its use as human food (9 CFR 325.11(e)(1)-(5) and 381.193), no carcass, or part or product of a carcass, capable of use as human food that is adulterated or misbranded can be offered for transportation in commerce unless it is denatured.””

There is one way for pet food companies to obtain un-denatured condemned and inedible meat and poultry though. And that’s if they buy it from a slaughter facility that has its own tanks to render inedible material. More and more facilities have been integrated to render their animal proteins on site. Think Cargill and Tyson. Those facilities have integrated rendering capabilities, which do not require the product to leave the site and therefore is not to denature it.

Is it possible for them to separate the perfectly good by-products from the icky, diseased ones?

Is it possible that it there is some poor soul whose job it is to separate the diseased, sh*t splattered, liver-fluke infected, puss-filled abscessed meat from bins marked INEDIBLE from perfectly good by-products?

Honestly, I don’t know.

But, realistically: Not bloody likely.

Who knows, maybe it does happen. Anecdotally, I have heard that some pet food companies have “special arrangements” with certain slaughter facilities where they are able to get un-denatured or “lightly” denatured unrendered meat and poultry.

How denatured does it have to be?

It’s hard to imagine how inedible by-products could ever be “lightly” denatured considering that the USDA wants to make damn sure it never gets back into the human food chain,  so they require denaturants be used that cannot be washed or soaked off.

Accordingly, the USDA says that meat “…shall be freely slashed before the denaturing agent is applied, except that, in the case of dead animals that have not been dressed, the denaturant may be applied by injection. The denaturant must be deposited in all portions of the carcass or product to the extent necessary to preclude its use for food purposes.”

In case you missed it, even when animals are killed at an official establishment (USDA inspected facility), and not allowed to be slaughtered there because they were deemed unfit for slaughter (as in dying, diseased or disabled animals) with their fur and feet still attached, their corpses must be injected with a denaturant capable of deterring its use as human food. At which point, after having their dead bodies pumped full of poison, they are sent to a rendering plant.

How do you know if some pet food companies are not using denatured inedible meat and poultry?

How can you be certain a pet food company is telling you the truth and their food really does have only un-denatured human edible meat and poultry in it?

You don’t.

In fact, most companies that use the “human-grade” claim, are doing so illegally. But, there are two companies that I am aware of that can legally make the “human-edible” pet food claim. And that’s because their food is made in a facility certified to manufacture human food.

As for all the rest of the so-called, human-grade pet foods out there…

Well, you’ll just have to trust that they are telling you the truth. NOT.

Read more about it! 9 CFR 325.13 – Denaturing procedures.
And here: Type of Denaturant to Use on Meat or Poultry Condemned Carcasses, Inedible Parts or Other Products Not Intended For Human Food
And in case you aren’t convinced yet, read this: Shipment of condemned or inedible for Pet Food

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Mollie Morrissette

Mollie Morrissette, author of Poisoned Pets, is an animal food safety expert and advisor to AAFCO. Help support her work by making a donation today.

Comments (15) Write a comment

  1. Do you know of any dry dog food that is ACTUALLY human grade? I know the term “human grade” itself can ne tricky. Does a dry dog food even exist that DOES NOT have sll the disgusting stuff in it? Please let us know as soon ss you can. I have two big dogs and two small dogs that I make homemade food for which I give to them in the morning and then they always have access to dry dog food they can eat whenever they want. I give them the Racel Ray Nutrish zero grain turkey and potato kind. After reading your posts, I don’t want to do that anymore. PLEASE tell me – us – what kind of GOOD dry dog food we can feed our dogs. I’m desperate! I already spend so much time in the kitchen making their homemade food in bulk to last one week to give tjem in the morning and I just don’t have the extra time to feed them ONLY my homemade stuff – I would never get out of the kitchen! Thank you!!!!!!!!!

    Reply

  2. I think you’re amazing. God bless you – and I mean that. Keep getting the word out – our pets can’t speak for themselves. WE are their voice. THANK YOU for telling us about Honest Kitchen and Frenchies, Thank you for all you do!!!

    Reply

  3. Does the assembly line worker who is working furiously to cut and separate the inedible from the edible, err on the side of cutting LESS of the inedible material off – or MORE, (such as what surgeons do when cutting out a tumor)? It sounds as though the speed of the line makes it almost impossible to make these rapid decisions, so that the inedible is probably mixed up with the edible. Then, what happens to a supposedly edible chicken with inedible things still clinging onto it? Is it inspected again? Or Is it then sold for human consumption?
    It brings to mind the I Love Lucy episode in the chocolate factory, but this isn’t funny.
    Thanks for your hard work, and looking forward to another of your “gross-me-out’ posts.

    Reply

    • Welcome to the world of food safety!

      Meat and poultry inspectors are up against Big Meat, and regulations which favor industry and not the consumer. They keep upping the line speeds, so they do the best they can, considering.

      Do they have time to cherry pick through the inedible guts?

      Seriously?

      Why do you think the USDA assumes meat and poultry is already contaminated?

      Because it is.

      Why do you think they’re always on about safe handling, and cooking the sh*t out of it.

      Because the sh*t literally does need to be cooked out of it. Ask any parent whose child died from eating an under-cooked burger.

      Why do you think the FDA is so freaked out about raw pet food?

      Because it’s probably contaminated (just like human edible meat and poultry is).

      Think of raw pet food in the same way you think of any other raw meat or poultry product for humans – practice safe handling procedures and scrub the hell out of your kitchen.

      Reply

    • Yes, “looking forward to another one of your ‘gross me out’ posts…” made me laugh. They used to call what you do “muckraking” before its modern term as “investigative journalism.” I am beginning to think that you need to find a way to integrate a virtual reality into the site… we need a barf bag at the bottom of almost every page… perhaps it could appear as a holograph if your readers wore 3-D glasses… it would help us endure this stuff!

      Reply

  4. Is there any way to identify the type of denaturant used by a specific manufacturer and link that to the brand names of the pet foods? This article makes me wonder if this is why pet feed like Beneful is full of the food dye colored pieces; not just to appeal to the pet owner, but to also apply a denaturant.
    Are you able to identify the two companies making human edible pet food?

    Reply

    • The two companies are Honest Kitchen and Frenchie’s Kitchen. It was Susan who told me about Frenchie’s, and I am not intimately familiar with the company or their product (yet), but I am familiar with Honest Kitchen. Readers of PP know that I feed their food to my cats. But, I don’t mention them in posts, because I don’t want people to get the idea that I am somehow endorsing any one pet food brand. Which I am, in a way, but I cannot appear to be endorsing any one brand. It is simply my own personal preference as far as commercially made pet food is concerned. And I make it clear that I don’t receive any compensation from them for using or recommending their food.

      My actual preference is a homemade diet, not a commercially made pet food. I like raw, certified organic, human edible and animal welfare approved (or secondly, a certified humane) ingredients. And there does not exist a single pet food that meets those strict criteria.

      As far as the first question – no. There is no way to know…which is why I caution consumers. They won’t be listed in the ingredient profile as they are used as a processing aid. The really scary part is, that they sell denaturants specifically intended to counteract the weird (green or blue) color of the denatured material. Many food dies are carcinogenic, and even ones that are approved for human consumption are problematic for humans and animals.

      But, the most worrisome aspect of these marketed denaturants for the industry, is that their formulas can be proprietary formulas. You will never know what is in them. It is considered a trade secret.

      Reply

  5. A wise boss once told me, “Don’t come to me with problems, come to me with solutions.”

    Reply

    • As an educator and advocate, it is my duty to inform and educate consumers. Unfortunately, in this industry, there are no simple solutions, just problems. Problems that have occurred for decades. Laws were not written to accommodate the animal feed industry as it is today. The FD&C Act was written in 1938, for example.

      I act as the counterpoint to the multi-billion dollar industry that has consistently lied to consumers about the true nature of pet food and animal feed.

      My solution is to make your own food.

      Reply

  6. I Love you……..keep up the good work. You are truly a enlightened beautiful person amidst this horrible subject matter.

    Keep on punching Mollie!

    Reply

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