When a consumer asked me to help her find a human edible dog food, I said, “Sure! No problem!” But, after spending days – making phone calls, writing emails, speaking to pet food company owners, industry insiders, government officials – I found that all of the companies she asked me to look into were making false and misleading claims. All of them.
It wasn’t surprising she was having such a hard time, not only had she been shafted by the last company she dealt with, because, what I found was an impenetrable world of murky and unsubstantiated claims and hollow assurances. None of the companies I interviewed could verify or validate their claims. Not one.
The consumer gave me the names of several companies she was considering and asked me, “Mollie, are they really human edible?”
Considering they were the most expensive brands on the market in the U.S., I thought they had better be human edible.
USDA INSPECTED, MY EYE
I looked into the brands, and sure enough, they all made human grade claims. Perhaps not on the label itself, but the claims were found most frequently in brochure and Web site-based promotions. After scouring their websites for validation and finding none, I called them. They all assured me that their pet food was indeed human grade because it was “made in a human edible licensed facility that is registered and inspected by the USDA.”
But, when I asked for verification, they faltered. I was stonewalled, threatened, and treated with naked hostility. None of them could provide me with any method of substantiating their claims.
When I pressed harder, they became defensive and combative. One company told me, I didn’t know what the hell I was talking about, insisting, they could “make any claims we want to because they’re true.” I insisted they were mistaken.
Because, if there is one thing I do understand, and that is the law – as it pertains to false and misleading claims – in pet food. In particular, the law with regards to human edible claims on pet food.
In the State of California, where I live, pet food companies cannot make human edible claims about a pet food. Period. Full stop.
Since the companies this consumer was considering happened to be in my state, I contacted the California Department of Public Health, who’s in charge of regulating pet food. Predictably, they referred me to California Code of Regulations, Title 17, Article 16, Processed Pet Food Regulations, § 19025. Labeling and Restrictions:
(g) The terms “fit for human food,” “fit for human consumption,” or any similar terms are prohibited on the labels or in advertisements of a processed pet food.
24K GOLD PLATES
Unfortunately, it doesn’t matter if their food was prepared in a sterile, hermetically sealed environment, or made on 24K gold plates, in a five-star restaurant using only the best ingredients money can buy – they cannot make human edible claims about pet food in the State of California. Period. Full stop.
If a company tries to pull a fast one and slip a so-called human-edible pet food into California, the California Department of Public Health can refuse entry of that product. But, because California is such a huge market – most manufacturers opt for leaving those claims off their labels altogether, but they leave the false and misleading human-edible claims on their websites.
The problem with that is, their websites are considered a form of advertising.
When I confronted the companies about this discrepancy, they tried to weasel out of it, by giving me excuses like, “well, it doesn’t say that on our labels – we’re very careful about that – it just says it on our website.”
Both federal and state laws state, that any representation – including all promotional material, which includes websites – must not make false and misleading statements or suggestions.
After arguing with the pet food companies, I asked them a simple question, “How can I verify your pet food is human edible?” They adamantly assured me their food was made “under USDA inspection in a human food facility.” Unfortunately, they made the mistake of assuming I would just take their word for it.
Let me emphasize: None of those companies I interviewed provided me with documentation to substantiate their claims.
If companies stonewall you – and believe me, they will – there is one simple tool to find out if their pet foods are made under USDA inspection. Go to the USDA and find out for yourself.
The companies that I looked into claimed to be under USDA rules for inspection. They would have applied for and received a Grant of Inspection from the USDA, and given an Offical Establishment number.
So, I went to the USDA website and checked their database of Official Establishments.
Were those companies listed?
EVIDENCE? WHAT’S THAT?
To substantiate whether a human grade claim is truthful and not misleading, a manufacturer must have information from each of the individual ingredient suppliers that verifies the individual ingredients supplied to the manufacturer are fit for human consumption. The manufacturer must have evidence that the finished product is manufactured under current good manufacturing practices for human food in a facility licensed to produce human food. Such evidence may include, facility licenses or permits for operation of edible food manufacturing facilities or results of most recent inspections issued by local or state public health authorities.
The manufacturer or distributor should be able to unequivocally demonstrate that if a human food label were placed on the product that it would be acceptable to human food authorities to sell the product for human consumption.
Did any of those companies provide me with any of this required evidence?
One company, realizing they were cornered, refused to answer any more of my questions. Instead, they told me they were “referring the matter to their attorneys”!
So, next time you’re shopping for a “human-grade” pet food, ask them one simple question:
“What is your Official Establishment number?”
If they give you their Official Establishment number (good luck with that!), then head on over to the USDA website and search their Official Establishment database to verify it.
It’s that dead simple.
Bottom line: If they can’t provide consumers with even the most basic evidence that their pet food is human edible – take a pass on it, ‘cause chances are, they’re bullsh*ttin’ you.
NOTE: Many will ask, which were the companies that stonewalled me. While it’s tempting to throw them under the Pet Food Safety Bus – and believe me, it is – I am unable to do so at present. Why? Because my investigation has now been expanded to include all pet food companies in the U.S. making human-edible claims. When my investigation is complete I will make a full report. Until then, the message I’m sending out today is that consumers need to ask for verification. Accept nothing less. And if consumers are unable to validate the human-edible claims, then they should report the companies to the state authorities. Sometimes, all it takes is a phone call or a short email. To find out who
your state officials are, visit: The Directory of State and Local Officials.
UPDATE: I would like to acknowledge the valued contribution, Lucy Postins of The Honest Kitchen made, in helping me understand this problem, her knowledge and personal insight into this problem is unparalleled. No other company has fought harder for to obtain the legal status of human food for a pet food. In 2004, The Honest Kitchen received the first official statement of no objection from the FDA allowing a pet food company the legal status of human food, permitting them to use the term “Human-grade” on their product labels. To this day, The Honest Kitchen remains, the only pet food company in the USA that can legally claim to be human edible, because it is human edible. Thanks, Lucy for your all that you’ve done, for me, and for pets.