dog and cats in snow

Pet food’s darkest secret: Chemically denatured condemned and inedible material

You’ll never see it listed on a pet food package. Yet, it is in nearly every single brand of pet food on the market.

What is it?

It’s not an ingredient at all – it’s a process – called denaturing. Because denaturing is a process, and not an ingredient, you’ll never see it listed as an ingredient.

However, you can be sure if your pet food contains meat and bone meal or animal fat – it was probably denatured.

Why?

Because the law requires it to be.

To comply with government regulations, all USDA condemned or inedible poultry and red meat identified as unfit for human consumption must be processed with a denaturing agent to deter its use as human food.

“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.”


Why denaturing is required

Quite simply, denaturing agents mark condemned and inedible material in such a way as it to be immediately recognizable as unfit for human consumption, thus ensuring it cannot be resold as human grade meat. The chemicals used (identifying agents) must give the material so distinctive a color, odor, or taste that it cannot ever be confused with an article of human food.

According to the FDA,

“The basic purpose of denaturing is to prevent salvage or diversion of violative materials for human consumption.”


Inedible—not intended for human food

During ante and post-mortem examination of carcasses, USDA inspectors are required to label, mark, stamp, or tag all animals, carcasses and parts thereof of animals found to be diseased or contaminated with feces as “Inspected and condemned” and will be destroyed for human food purposes. When it is shipped from a slaughterhouse to a rendering plant, the outside container of inedible products must be marked conspicuously with the words ‘‘Inedible—Not Intended for Human Food.”


Destruction of condemned and inedible material

The chemicals approved for denaturing is not as extensive as it is frightening: Fuel, kerosene, used crank case oil, creosote, ingredients you will never see listed as a pet food ingredient.

The following ‘identifying agents’ are allowed for use as denaturants in USDA inspected facilities:

  •   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

Because the USDA allows for ‘other proprietary denaturants’ in addition to the more common denaturing agents such as fuel, chemical manufacturers have taken advantage of this unique specialty market  by creating their own distinctive denaturants, the ingredients of which are proprietary – i.e.: they are a trade secret.

Proprietary denaturants

Chemical manufacturers provide the meat industry with a variety of proprietary formulas for denaturants, many of which are especially designed not to interfere with the color of pet food and animal feed. Some of the formulas they sell to pet food and animal feed manufacturers are specifically designed to counteract the strange blue and green tinged condemned meat.

For example, 4-D Denaturant™ is advertised as “a chemical denaturant (decharacterizer) for purposes of identifying meat and poultry carcasses and products condemned for pathology and intended for disposal as tankage.” The company claims that the product “does not affect meat and bone meal as animal feeds. The strongly identifiable green color penetrates both the meat and fat layer and will not wash off under ordinary conditions.”

For pet food, the chemical manufacturer recommends their ‘FD&C Red Concentrate’ as the preferred denaturant as it’s “product is safe to handle even in its concentrated form and do not adversely affect by-products intended for pet food.”

Another product called Liquik® Char (liquid charcoal) makes the claim that even though the meat is condemned, their product is “safe to handle even in its concentrated form and does not affect meat and bone meal in animal feeds. The strongly identifiable black color does not penetrate the meat parts and fat layer and does not adversely affect the meat color in pet foods.”

Final thoughts

Because the law requires condemned and inedible material to be denatured and rendered, and because we know that the most valuable by-product of the rendering industry is products for the pet food and animal feed industry, we can reasonably assume that any pet food that contains ‘meat and bone meal’ or ‘animal fat’ was denatured.

Because many of you will find this information not only shocking, but hard to believe, I’ve copied some of the sections of the U.S. Code of Federal Regulations relevant to denaturing below (emphasis mine).

Should you wish to read it in its entirety, read the U.S. Code of Federal Regulations on animals and animal products TITLE 9 —ANIMALS AND ANIMAL PRODUCTS [ 9 CFR ].

Title 9: Animals and Animal Products

PART 301—TERMINOLOGY; ADULTERATION AND MISBRANDING STANDARDS
Adulterated. This term applies to any carcass, part thereof, meat, or meat food product under one or more of the following circumstances:
(1) If it bears or contains any such poisonous or deleterious substance which may render it injurious to health; but in case the substance is not an added substance, such article shall not be considered adulterated under this clause if the quantity of such substance in or on such article does not ordinarily render it injurious to health;
(2)(i) If it bears or contains (by reason of administration of any substance to the live animal or otherwise) any added poisonous or added deleterious substance other than one which is:
(A) A pesticide chemical in or on a raw agricultural commodity;
(B) A food additive; or
(C) A color additive which may, in the judgment of the Administrator, make such article unfit for human food;
(ii) If it is, in whole or in part, a raw agricultural commodity and such commodity bears or contains a pesticide chemical which is unsafe within the meaning of section 408 of the Federal Food, Drug, and Cosmetic Act;
(iii) If it bears or contains any food additive which is unsafe within the meaning of section 409 of the Federal Food, Drug, and Cosmetic Act;
(iv) If it bears or contains any color additive which is unsafe within the meaning of section 706 of the Federal Food, Drug, and Cosmetic Act: Provided, That an article which is not deemed adulterated under paragraphs (aa)(2) (ii), (iii), or (iv) of this section shall nevertheless be deemed adulterated if use of the pesticide chemical food additive, or color additive in or on such article is prohibited by the regulations in this subchapter in official establishments;
(3) If it consists in whole or in part of any filthy, putrid, or decomposed substance or is for any other reason unsound, unhealthful, unwholesome, or otherwise unfit for human food;
(4) If it has been prepared, packed, or held under unsanitary conditions whereby it may have become contaminated with filth, or whereby it may have been rendered injurious to health;
(5) If it is, in whole or in part, the product of an animal which has died otherwise than by slaughter;
(6) If its container is composed, in whole or in part, of any poisonous or deleterious substance which may render the contents injurious to health;
(7) If it has been intentionally subjected to radiation, unless the use of the radiation was in conformity with a regulation or exemption in effect pursuant to section 409 of the Federal Food, Drug, and Cosmetic Act;
(8) If any valuable constituent has been in whole or in part omitted or abstracted therefrom; or if any substance has been substituted, wholly or in part therefore; or if damage or inferiority has been concealed in any manner; or if any substance has been added thereto or mixed or packed therewith so as to increase its bulk or weight, or reduce its quality or strength, or make it appear better or of greater value than it is;
Animal food. Any article intended for use as food for dogs, cats, or other animals derived wholly, or in part, from the carcass or parts or products of the carcass of any livestock, except that the term animal food as used herein does not include:
(1) Processed dry animal food; or
(2) Livestock or poultry feeds manufactured from processed livestock byproducts (such as meat meal tankage, meat and bone meal, blood meal, and feed grade animal fat).
Animal food manufacturer. Any person engaged in the business of manufacturing or processing animal food.
Capable of use as human food. This term applies to any carcass, or part or product of a carcass, of any livestock, unless it is denatured or otherwise identified as required by the applicable provisions of §§314.3, 314.10, 325.11, and 325.13 of this subchapter to deter its use as a human food, or it is naturally inedible by humans; e.g., hoofs or horns in their natural state.
Carcass. All parts, including viscera, of any slaughtered livestock.
Dead livestock. The body (cadaver) of livestock which has died otherwise than by slaughter.
Dying, diseased, or disabled livestock. Livestock which has or displays symptoms of having any of the following:
(1) Central nervous system disorder;
(2) Abnormal temperature (high or low);
(3) Difficult breathing;
(4) Abnormal swellings;
(5) Lack of muscular coordination;
(6) Inability to walk normally or stand;
(7) Any of the conditions for which livestock is required to be condemned on ante-mortem inspection in accordance with the regulations in part 309 of this subchapter.
Edible. Intended for use as human food.
Inedible. Adulterated, uninspected, or not intended for use as human food.
Meat. (1) The part of the muscle of any cattle, sheep, swine, or goats which is skeletal or which is found in the tongue, diaphragm, heart, or esophagus, with or without the accompanying and overlying fat, and the portions of bone (in bone-in product such as T-bone or porterhouse steak), skin, sinew, nerve, and blood vessels which normally accompany the muscle tissue and that are not separated from it in the process of dressing. As applied to products of equines, this term has a comparable meaning.
(i) Meat does not include the muscle found in the lips, snout, or ears.
(ii) Meat may not include significant portions of bone, including hard bone and related components, such as bone marrow, or any amount of brain, trigeminal ganglia, spinal cord, or dorsal root ganglia (DRG).
Meat byproduct. Any part capable of use as human food, other than meat, which has been derived from one or more cattle, sheep, swine, or goats. This term, as applied to products of equines, shall have a meaning comparable to that provided in this paragraph with respect to cattle, sheep, swine, and goats.
Official establishment. Any slaughtering, cutting, boning, meat canning, curing, smoking, salting, packing, rendering, or similar establishment at which inspection is maintained under the regulations in this subchapter.
Product. Any carcass, meat, meat byproduct, or meat food product, capable of use as human food.
Renderer. Any person engaged in the business of rendering carcasses or parts or products of the carcasses of any livestock except rendering conducted under inspection or exemption under Title I of the Act.
U.S. Condemned. This term means that the livestock so identified has been inspected and found to be in a dying condition, or to be affected with any other condition or disease that would require condemnation of its carcass.
U.S. Inspected and Condemned (or any authorized abbreviation thereof). This term means that the carcass, viscera, other part of carcass, or other product so identified has been inspected, found to be adulterated, and condemned under the regulations in this subchapter.
U.S. Passed for Cooking. This term means that the meat or meat byproduct so identified has been inspected and passed on condition that it be cooked or rendered as prescribed by the regulations in part 315 (see below) of this chapter.
U.S. Passed for Refrigeration. This term means that the meat or meat byproduct so identified has been inspected and passed on condition that it be refrigerated or otherwise handled as prescribed by the regulations in part 311(see below) of this subchapter.
U.S. Retained. This term means that the carcass, viscera, other part of carcass, or other product, or article so identified is held for further examination by an inspector to determine its disposal.
U.S. Suspect. This term means that the livestock so identified is suspected of being affected with a disease or condition which may require its condemnation, in whole or in part, when slaughtered, and is subject to further examination by an inspector to determine its disposal.

 

PART 311—DISPOSAL OF DISEASED OR OTHERWISE ADULTERATED CARCASSES AND PARTS
§311.1   Disposal of diseased or otherwise adulterated carcasses and parts; general.
(a) The carcasses or parts of carcasses of all animals slaughtered at an official establishment and found at the time of slaughter or at any subsequent inspection to be affected with any of the diseases or conditions named in this part shall be disposed of according to the section pertaining to the disease or condition: Provided, that no product shall be passed for human food under any such section unless it is found to be otherwise not adulterated. Products passed for cooking or refrigeration under this part must be so handled at the official establishment where they are initially prepared unless they are moved to another official establishment for such handling or in the case of products passed for refrigeration are moved for such refrigeration to a freezing facility approved by the Administrator in specific cases: Provided, that when so moved the products are shipped in containers sealed in accordance with §318.10(c) of this subchapter or in a sealed means of conveyance as provided in §325.7 of this subchapter. Owning to the fact that it is impracticable to formulate rules covering every case and to designate at just what stage a disease process or a condition results in adulteration of a product, the decision as to the disposal of all carcasses, organs, or other parts not specifically covered in this part shall be left to the veterinary medical officer. The veterinary medical officer shall exercise his judgment regarding the disposition of all carcasses or parts of carcasses under this part in a manner which will insure that only wholesome, unadulterated product is passed for human food.
(b) In cases of doubt as to a condition, a disease, or the cause of a condition, or to confirm a diagnosis, representative specimens of the affected tissues, properly prepared and packaged, shall be sent for examination to one of the laboratories of the Biological Control Section of the Program.
PART 309—ANTE-MORTEM INSPECTION
§ 309.13 Disposition of condemned livestock.
(a) Except as otherwise provided in this part, livestock identified as U.S. Condemned shall be killed by the official establishment, if not already dead. Such animals shall not be taken into the official establishment to be slaughtered or dressed; nor shall they be conveyed into any department of the establishment used for edible products; but they shall be disposed of in the manner provided for condemned carcasses in part 314 [rendered or denatured] of this subchapter.
PART 310—POST-MORTEM INSPECTION
§ 310.5 Condemned carcasses and parts to be so marked; tanking; separation.
Each carcass or part which is found on final inspection to be unsound, unhealthful, unwholesome, or otherwise adulterated shall be conspicuously marked, on the surface tissues thereof, by a Program employee at the time of inspection, as ‘‘U.S. Inspected and Condemned.’’
§ 310.16 Disposition of lungs.
(a) Livestock lungs shall not be saved for use as human food.
(b) Lungs found to be affected with disease or pathology and lungs found to be adulterated with chemical or biological residue shall be condemned and identified as ‘‘U.S. Inspected and Condemned.’’ Condemned lungs may not be saved for pet food or other non-human food purposes…
(c) Lungs not condemned under paragraph (b) of this section may be used in the preparation of pet food or for other non-human food purposes at the official establishment.
PART 311—DISPOSAL OF DISEASED OR OTHERWISE ADULTERATED CARCASSES AND PARTS
§ 311.1 Disposal of diseased or otherwise adulterated carcasses and parts; general.
(a) The carcasses or parts of carcasses of all animals slaughtered at an official establishment and found at the time of slaughter or at any subsequent inspection to be affected with any of the diseases or conditions named in this part shall be disposed of according to the section pertaining to the disease or condition…
PART 314—HANDLING AND DISPOSAL OF CONDEMNED OR OTHER INEDIBLE PRODUCTS AT OFFICIAL ESTABLISHMENTS
§314.1   Disposition of condemned products at official establishments having tanking [rendering] facilities; sealing of tanks.
(a) Carcasses, parts of carcasses, and other products condemned at official establishments having facilities for tanking [rendering] shall, except as provided in paragraph (c) of this section or elsewhere in this part, be disposed of by tanking [rendering] as follows…
…But, if the crushed or hashed material is not rendered in the establishment where produced, it shall be denatured as provided for in §314.3 before leaving such establishment.
If the crushed or hashed material is not rendered in the establishment where produced, it shall be denatured as provided for in §314.3 before leaving such establishment.           
§314.3   Disposition of condemned products at official establishments having no tanking [rendering] facilities.
(a) Carcasses, parts of carcasses, and other products condemned at an official establishment which has no facilities for tanking [rendering] shall, except as provided in paragraph (b) of this section or elsewhere in this part, be destroyed in the presence of an inspector 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 approved by the Administrator in specific cases. When such product is to be denatured, it 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.
(b) All carcasses and parts condemned on account of anthrax, as identified in §310.9(b) of this subchapter, at official establishments which are not equipped with tanking [rendering] facilities shall be disposed of by (1) complete incineration, or (2) by thorough denaturing with crude carbolic acid, or cresylic disinfectant, and then disposed of…
§314.5   Inedible rendered fats prepared at official establishments.
Except as provided in §325.11(b) of this subchapter, rendered animal fat derived from condemned or other inedible materials at official establishments shall be denatured to effectually distinguish it from an edible product, either with low grade offal during the rendering or by adding to, and mixing thoroughly with, such fat, denaturing oil, No. 2 fuel oil, or brucine dissolved in a mixture of alcohol and pine oil or oil of rosemary, and may be shipped in commerce in accordance with §325.11(c) of this subchapter.
§314.6   Inedible fats from outside official establishments.
Except as provided in §325.11(b) of this subchapter, inedible fats from outside the premises of any official establishment shall not be received into an official establishment except into the tank room provided for inedible products, and then only when they have been denatured in accordance with §314.5 and are marked in accordance with §316.15 of this subchapter, and when their receipt into the tank room produces no insanitary condition on the premises; nor shall such fats be received in such volume as interferes with prompt disposal of condemned or other inedible material produced at the establishment. When received, they shall not enter any room or compartment used for edible products.
§314.7   Carcasses of livestock condemned on ante-mortem inspection not to pass through edible product areas.
Carcasses of livestock which have been condemned on ante-mortem inspection shall not be taken through rooms or compartments in which an edible product is prepared, handled, or stored.
§314.8   Dead animal carcasses.
(a) With the exception of dead livestock which have died en route and are received with livestock for slaughter at an official establishment, no dead animal or part of the carcass of any livestock that died otherwise than by slaughter may be brought on the premises of an official establishment unless advance permission therefore is obtained from the circuit supervisor.
(b) Under no circumstances shall the carcasses of any animal which has died otherwise than by slaughter, or any part thereof, be brought into any room or compartment in which any edible product is prepared, handled, or stored.
§314.10   Livers condemned because of parasitic infestation and for other causes; conditions for disposal for purposes other than human food.
(a) Livers condemned on account of hydatid cysts shall be disposed of by tanking [rendering] pursuant to the provisions of §314.1 of this subchapter if condemned at official establishments having facilities for tanking; otherwise they shall be destroyed [denatured] pursuant to the provisions of §314.3 of this subchapter.
(b) Livers condemned because of parasites other than hydatid cysts; and livers condemned because of telangiectasis, angioma, “sawdust” condition, cirrhosis, carotenosis, or other nonmalignant change, benign abscesses, or contamination, when these conditions are not associated with infectious diseases in the carcasses, may be shipped from an official establishment only for purposes other than human food, and only if all tissue affected with abscesses is removed and destroyed within the establishment, and all livers are processed and denatured…

§314.11   Handling of certain condemned products for purposes other than human food.
Condemned carcasses of animals affected with one or more of the following conditions may be shipped from an official establishment only for purposes other than human food and only if permission therefor is obtained from the circuit supervisor: Anasarca, Ocular Squamous Cell Carcinoma (after removal of neoplastic tissue), emaciation, eosinophilic myositis, immaturity, nonseptic bruises and injuries, and sarcosporidiosis. This provision also applies to unborn calves and to products such as paunches and udders when they have not been handled as required under this subchapter for products for human food purposes; provided, such articles have not been condemned for other pathological reasons. Such permission will be granted only if all parts to be so used will be promptly handled, freely slashed and adequately identified as required by §325.13(a)(2) of this subchapter [denaturing]. The slashing, identification and packing of the product shall be accomplished in an inedible product area under the supervision of an inspector. Facilities must be adequate so that the carcasses or parts saved under these provisions are not contaminated with pus, manure, septic, or toxic materials, or similar substances. The operation must not result in unsanitary conditions within the establishment.

PART 325—TRANSPORTATION
§ 325.8 Transportation and other transactions concerning certain undenatured lungs or lung lobes from official establishments or in commerce; provisions and restrictions.
(a) Lungs or lung lobes, other than those condemned under § 310.16(b) of this subchapter, that are prepared at any official establishment, may be sold, transported, offered for sale or transportation, or received for transportation from the establishment, in commerce or otherwise, without denaturing as prescribed in § 314.1 or § 314.3 of this subchapter: Provided:
(1) The lungs or lung lobes are sold, transported, or offered for sale or transportation to, or received for transportation by: An animal food manufacturer for use in manufacturing animal food…
(d) All such lungs or lung lobes, if intended for animal food, are subject to the Federal Food, Drug, and Cosmetic Act.

§ 325.10 Handling of products which may have become adulterated or misbranded; authorization and other requirements.
(a) When it is claimed that any inspected and passed product, marked with an inspection legend, has become adulterated or misbranded after it has been transported from an official establishment, such product may be transported in commerce to an official establishment after oral permission is obtained from the area supervisor of the area in which that offical establishment is located. The transportation of the product may be to the official establishment from which it had been transported or to another official establishment designated by the person desiring to handle the product. The transportation shall be authorized only for the purpose of officially determining if the product has become adulterated or misbranded and making the appropriate disposition…
(b) Upon the arrival of the shipment at the official establishment, a careful inspection shall be made of the product by a Program inspector, and if it is found that the article is not adulterated, the same may be received into the establishment; but if the article is found to be adulterated, it shall at once be stamped “U.S. inspected and condemned” and disposed of in accordance with part 314 of this subchapter, and if it is found to be misbranded, it shall be handled in accordance with § 318.2(d) of this subchapter…
§ 325.11 Inedible articles: denaturing and other means of identification; exceptions.
(a) Except as provided in § 325.8 and § 325.10, no carcass, part of a carcass, rendered grease, tallow, or other fat derived from the carcasses of livestock, or other meat food product, that has not been inspected and passed at an official establishment under the provisions of this subchapter and is not exempted from such inspection, and no carcass, part of a carcass, fat or other meat food product that is adulterated or misbranded, shall be offered for transportation in commerce by any person unless it is handled in accordance with paragraph (b), (c), (d), or (e) of this section or is denatured or otherwise identified as prescribed in § 325.13, § 314.1, § 314.3, § 314.9, § 314.10, or § 314.11 of this subchapter.
(b) Inedible rendered animal fats from official or other establishments in the United States having the physical characteristics of a meat food product fit for human food may be transported in commerce without denaturing, if the following conditions are met:
(1) Such inedible rendered fat shall not be bought, sold, transported, or offered for sale or offered for transportation in commerce, or imported, except by rendering companies, dealers, brokers, or others who obtain a numbered permit for such activities from the Regional Director.
(2) Such inedible rendered animal fat may be so distributed only if consigned to a domestic manufacturer of technical articles other than for human food or to an export terminal for exportation or storage for exportation as an inedible article, and provided, in the case of such fat consigned to a domestic manufacturer, the product is for use solely by the consignee for manufacturing purposes of non-human food articles and may not be further sold or shipped without first receiving approval of the Regional Director: And provided further, That such fat intended for export and stored at a terminal point prior to export will be subject to review by Program employees to assure that it is exported as inedible.
(3) When transported in commerce, or imported, such inedible rendered fat shall be marked conspicuously with the words “technical animal fatnot intended for human food” on the ends of the shipping containers, in letters not less than 2 inches high; in the case of shipping containers such as drums, tierces, barrels, and half barrels, and not less than 4 inches high in the case of tank cars and trucks. All shipping containers shall have both ends painted with a durable paint, if necessary, to provide a contrasting background for the required marking…
(c) Inedible rendered animal fat derived from condemned or other inedible materials at official or other establishments in the United States may be transported in commerce if mixed with low grade offal or other materials which render the fat readily distinguishable from an article of human food, and if the outside container bears the word “inedible.”
(d)
(1) Except as provided in paragraphs (d)(2), (3), and (4) of this section, or in §§ 314.10 and 314.11 of this subchapter, no animal food prepared, in whole or in part, from materials derived from the carcasses of livestock in an official establishment or elsewhere, shall be bought, sold, transported, offered for sale or transportation, or received for transportation, in commerce, or imported, unless:
(i) It is properly identified as animal food;
(ii) It is not represented as being a human food; and
(iii) It has been denatured as prescribed in § 325.13(a)(2) so as to be readily distinguishable from an article of human food.
(2) Notwithstanding the provisions of paragraph (d)(1) of this section, an animal food that consists of less than 5 percent of parts or products of the carcasses of livestock and that is not represented by labeling or appearance or otherwise as being a human food or as a product of the meat food industry need not be denatured in accordance with § 325.13(a)(2).
(3) Notwithstanding the provisions of paragraph (d)(1) of this section, animal food packed in hermetically sealed, retort processed, conventional retail-size containers, and retail-size packages of semi-moist animal food need not be denatured in accordance with § 325.13(a)(2) if the name of the article clearly conveys the article’s intended use for animal food and appeared on the label in a conspicuous manner.
(i) Except as provided in paragraph (ii) of paragraph (d)(3), the name of the article must be stated on the label as “Animal Food,” “Pet Food,” or “(name of species) Food” (e.g., “Dog Food” or “Cat Food”). To be considered conspicuous, the name of the article, wherever it appears on the label, must be in letters at least twice as high, wide, and thick as the letters indicating the presence in the article of any ingredients derived from the carcasses of livestock.
(ii) Notwithstanding the provisons of paragraph (i) of this paragraph (d)(3), the article’s name may be stated on the label to show that it is or contains livestock-source material and that the article is for animals; e.g., “Horsemeat for Pets” or “Beef Stew for Dogs”: Provided, That the entire name of the article is stated, wherever it appears on the label, as an individual, contiguous unit, whether stated on a single line or more than one line, and the letters denoting the article’s intended use for animal food are at least as high, wide, and thick as the letters indicating the presence of material derived from any livestock carcass…
(4) The requirements of this part do not apply to livestock or poultry feeds manufactured from processed livestock byproducts (such as meat meal tankage, meat and bone meal, blood meal, and feed grade animal fat), or to processed dry animal food.
(e) Except for inedible rendered animal fats and lungs or lung lobes, inedible products (including condemned products only if condemned for causes specified in § 314.11 of this subchapter) which were prepared at any official establishment, or at any State inspected establishment in any State not listed in § 331.2 of this subchapter, and which have the physical characteristics of a product fit for human food, may be transported from an official establishment or in commerce, without denaturing as required by this subchapter, if the following conditions are met:
(1) The shipper must have obtained a numbered permit…
(2) Such inedible products may be transported under this paragraph (e) only if consigned to a manufacturer in the United States of articles other than for human food and if the product is for use solely by the consignee for manufacturing articles not for human food…
(3) When transported from an official establishment or in commerce under this paragraph (e), the outside container of such inedible products shall be marked conspicuously with the words “Inedible—Not Intended for Human Food”…

§325.13   Denaturing procedures.
(a) Carcasses, parts thereof, meat and meat food products (other than rendered animal fats) that have been treated in accordance with the provisions of this paragraph shall be considered denatured for the purposes of the regulations in this part, except as otherwise provided in part 314 of this subchapter for articles condemned at official establishments.
(1) The following agents are prescribed for denaturing carcasses, parts thereof, meat or meat food products which are affected with any condition that would result in their condemnation and disposal under part 314 of this subchapter if they were at an official establishment: Crude carbolic acid; cresylic disinfectant; 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, or other proprietary substance approved by the Administrator in specific cases.
(2) Except as provided in paragraphs (a)(3), (4), and (5) of this section, the following agents are prescribed for denaturing other carcasses, parts thereof, meat and meat food products, for which denaturing is required by this part: FD&C green No. 3 coloring; FD&C blue No. 1 coloring; FD&C blue No. 2 coloring; finely powdered charcoal; or other proprietary substance approved by the Administrator in specific cases.
(3) Tripe may be denatured by dipping it in 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;
(4) Meat may be denatured by dipping it in 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; and
(5) When meat, meat byproducts, or meat food products are in ground form, 4 percent by weight of coarsely ground hard bone, which shall be in pieces no smaller than the opening size specified for No. 5 mesh in the standards issued by the U.S. Bureau of Standards or 6 percent by weight of coarsely ground hard bone, which shall be in pieces no smaller than the opening size specified for No. 8 mesh in said Standards, uniformly incorporated with the product may be used in lieu of the agents prescribed in paragraph (a)(2) of this section.
(6) Before the denaturing agents are applied to articles in pieces more than 4 inches in diameter, the pieces shall be freely slashed or sectioned. (If the articles are in pieces not more than 4 inches in diameter, slashing or sectioning will not be necessary.) The application of any of the denaturing agents listed in paragraph (a)(1) or (2) of this section to the outer surface of molds or blocks of boneless meat, meat byproducts, or meat food products shall not be adequate. The denaturing agent must be mixed intimately with all of the material to be denatured, and must be 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.
(7) Carcasses (other than viscera), parts thereof, cuts of meat, and unground pieces of meat darkened by charcoal or other black dyes shall be deemed to be denatured pursuant to this section only if they contain at least that degree of darkness depicted by diagram 1 of the Meat Denaturing Guide (MP Form 91).
(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 approved for the purpose by the Administrator in specific cases. The charcoal shall be used in no less quantity than 100 parts per million and shall be of such character that it will remain suspended indefinitely in the liquid fat. Sufficient of 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.
PART 381—POULTRY PRODUCTS INSPECTION REGULATIONS
Subpart L—Handling and Disposal of Condemned or Other Inedible Products at Official Establishments
§381.95   Disposal of condemned poultry products.
All condemned carcasses, or condemned parts of carcasses, or other condemned poultry products, except those condemned for biological residues shall be disposed of by one of the following methods…
(a) Steam treatment (which shall be accomplished by processing the condemned product in a pressure tank under at least 40 pounds of steam pressure) or thorough cooking in a kettle or vat, for a sufficient time to effectively destroy the product for human food purposes and preclude dissemination of disease through consumption by animals.
(b) Incineration or complete destruction by burning.
(c) Chemical denaturing, which shall be accomplished by the liberal application to all carcasses and parts thereof, of:
(1) Crude carbolic acid,
(2) Kerosene, fuel oil, or used crankcase oil, or
(3) 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.
(d) Any other substance or method that the Administrator approves in specific cases, which will denature the poultry product to the extent necessary to accomplish the purposes of this section.
(e) Carcasses and parts of carcasses condemned for biological residue shall be disposed of in accordance with paragraph (b) of this section or by burying under the supervision of an inspector.
§644. Regulation of transactions, transportation, or importation of 4-D animals to prevent use as human food.
No person, firm, or corporation engaged in the business of buying, selling, or transporting in commerce, or importing, dead, dying, disabled, or diseased animals, or any parts of the carcasses of any animals that died otherwise than by slaughter, shall buy, sell, transport, offer for sale or transportation, or receive for transportation, in commerce, or import, any dead, dying, disabled, or diseased cattle, sheep, swine, goats, horses, mules or other equines, or parts of the carcasses of any such animals that died otherwise than by slaughter, unless such transaction, transportation or importation is made in accordance with such regulations as the Secretary may prescribe to assure that such animals, or the unwholesome parts or products thereof, will be prevented from being used for human food purposes.

References

TITLE 9 —ANIMALS AND ANIMAL PRODUCTS [ 9 CFR ], Federal Meat Inspection Act TITLE 21 – FOOD AND DRUGS CHAPTER 12 – MEAT INSPECTION

Subscribe to Blog via Email

Enter your email address to subscribe to this blog and receive notifications of new posts by email.

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. Thank you for your great work. I am horrified to learn about denaturing. I understand you don’t endorse. In light of these horrific industry standards for pet food, are there any commercial brands out there that don’t succumb to denaturing and if so, would I be able to find out through my own research? I’m thinking the answer is no but I had to ask. Barring that, is the only other option to home-cook pet food prepared with human grade meat? I understand there are certain nutrients that must be included with the meat to make a healthy balanced meal for cats in particular. Any thoughts and information are greatly appreciated. Thank you!

    Reply

  2. Which dry dog foods do not contain these harmful ingredients? So we know what right dog fods to buy for our dogs

    Reply

  3. I don’t own a pet, and I’m certainly not obsessed with animal rights. Most “articles” I read that discuss “pet rights” are often appeals to emotion; i.e., they don’t have a lot of facts to back up their arguments (and if they do, the facts aren’t always true).

    But I read a couple other articles here including this one, and I must say that this is great expository writing. You explain what the subject is by using a general description and specific examples, but then you had a restrained appeal to emotion. When I read your articles, It feels more like I’m reading the newspaper, and less like I’m reading an amateur internet blog about animal safety. I don’t feel like I’m wasting my time reading somebody’s typed-out whining.

    Keep up the good work Mollie. I’m bookmarking your blog because I have friends and family who (unlike me) are very concerned about what their pets eat. This blog is a great resource for their concerns.

    Reply

    • Why, thank you William. I try, I really do.

      I started out as a pretty lame “blogger” and made all the usual mistakes, but the farther I get into this topic the more I realize the responsibility I have to inform and educate the consumer. It’s too easy to rant and rave, I do the hard work of digging through mountains of research to get to the facts. I focus on law and science to make my arguments, as I would if I was asked to present a case in a court of law. And at the same time make it accessible to the average reader.

      If I had to do it over again, I would probably would choose another name for the website. Poisoned Pets is too suggestive of the kind of hysterical reporting of most other pet-centric websites.

      Thanks again for your kind words.

      Reply

  4. OMG that’s disgusting. I have a small 11 pound dog and buy expensive dry dog food that my dog treat as a garnish because I buy cow’s heart and chop it up and cook for him.

    Reply

  5. Thanks Mollie, for an excellent article! This information really does need to be more widely known!

    Just to clarify one point that came up in a comment, “denature” has multiple meanings. Cooking also “denatures” proteins, but does so by causing their molecular structure to change. What happens to pet food ingredients is big and visible, and is limited by law to the methods you describe.

    Another tip-off to denatured ingredients is the presence in the food of “titanium dioxide” – which is basically white paint. It’s used to cover the color of the denaturants before brown coloring is added to make the food look good.

    Reply

    • Thanks Dr. Jean. Yes, by law denaturing is by the methods they describe are basically used as identifying agents to make it so that it cannot be mistaken for human food – and cooking or marinating condemned and inedible material definitely doesn’t qualify (legally anyway). I am still stunned that this is the law. But when I saw that chemical manufacturers sell proprietary formulas specifically to the pet food and animal feed industry that’s when I knew it has to be going on.

      Reply

    • You’re welcome. For the longest time I avoided doing this story because it was so awful – I didn’t want to believe it was possible. I even asked Susan Thixton (the expert) and asked her if it was true (I wanted her to say no) and she said it is. I just hope and pray we are both wrong – that they don’t really do it.

      Reply

      • With your knowledge and experience in the issue, I can’t imagine that at this stage that you’d doubt anything when it comes to the manufacturing of pet foods… pet food manufacturers are in the business of recycling garbage into pet food. We continue to be disgusted… but honestly, I cannot say that I am shocked. Giving the issue publicity as you have done is a public service!

        Reply

        • I hope it isn’t as bad as I suspect it probably is. I know that if manufacturers buy their MBM or animal fat from an independent renderer – it most likely is true. I was amazed that no one had covered this issue before – so I guess it had to be me! Thanks again for your kind words.

          Reply

  6. Denaturing of proteins occurs in several ways including using heat, an acidic compound as a citrus marinade, radiation, or as you state a solvent. I have known about the rendering process of pet food, which denatures the proteins but I certainly had no idea that meats in pet foods were denatured with chemical solvents prior to rendering. This truly is disturbing, and I will share this info. My question is this, i understand that all the different meat by products in pet foods are not for human consumption therefore I can see why they would be denatured with solvents, but are you saying that this occurs with foods listing whole meats, whole chicken etc?
    of course, I cook for my beloved dog since I am a canine nutritionist and can formulate a balanced diet.

    Reply

    • According to the law, anything that leaves a slaughter house that is not UDSA inspected and approved for human consumption it must be denatured. If the slaughter house has on-site tanks for rendering it probably isn’t. Fortunately, the number of independent renderers is shrinking. I do not know how a pet food manufacturer would buy “whole meat” or “whole chicken” unless they buy USDA inspected and approved meat or poultry. If the manufacturer does not state that their protein is USDA inspected and approved the only other alternative is USDA inspected and condemned. There is no middle ground.

      Reply

    • Here is what the USDA has to say about it in one of their Q&As:

      Shipment of condemned or inedible for Pet Food

      Published 11/15/2007 05:55 PM | Updated 02/05/2014 06:22 AM

      Except for lungs, can other condemned or inedible meat/poultry products be shipped from the official establishment to a pet food manufacturer without 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.

      http://askfsis.custhelp.com/app/answers/detail/a_id/825/related/1

      Reply

Love it? Hate it? Tell us! We want to know.

This site uses Akismet to reduce spam. Learn how your comment data is processed.