It is not uncommon in my line of work, while digging around for information, to unearth some – how shall I put it – pretty unsavory tidbits. Being somewhat used to examining the underbelly of the animal feed business, hardened by the nitty-gritty of the rendering industry, jaded by images of diseased carcasses, used to seeing what vats of slaughterhouse waste looks like, seldom do I come upon something so revolting that it shocks me.
But I read something the other day while perusing an American Feed Industry Association (AFIA) document that caused my mouth to actually drop open in utter disbelief. It was then, after staring at it this incredulous information, that I decided to finally begin my series of informative articles on the unsavory and odoriferous fixings that are allowed in pet food and animal feed. The working title for the series is, the Encyclopedia of Sh*t You Don’t Want to Know About, But Should.
It started like any other day – continuing with the excavation the mountain of research into the feed industry, sifting through heaps of documents on food law – when I had one of those rare, jaw-dropping, moments.
While ruffling through the various documents relating to the AFIA’s Safe Feed/Safe Food Certification Program – a third-party-certified initiative designed for feed mills and feed ingredient facilities – that bills itself as a program that establishes a “comprehensive standards of excellence that go beyond existing regulations to show leadership and maximize food and feed safety,” that I came across a paragraph that stunned me.
There, tucked in the AFIA’s website was the proud announcement of a partnership with the National Renderers Association (NRA) joining two animal food safety certification programs— and NRA’s Rendering Code of Practice (COP) the later of which reads, in part: [emphasis mine]
5.3.2 Control of Raw Materials and Ingredients
Decomposition of animal tissues begins the moment slaughter takes place, and some time is needed to get these materials into the rendering process. Decomposition is not always a negative for product quality and food safety. The rendering process effectively “re-sets the clock” by processing raw materials including offal, outdated meat, and fallen animals that may be deemed filthy, putrid, or decomposed substances with respect to human food into safe, wholesome, and useful feed ingredients for animals.
SAFE & WHOLESOME FILTHY, PUTRID & DECOMPOSING FOOD
What shocked me was not that filthy, putrid, and decomposing 4-D meat is used in pet food, or that there is the general belief in certain circles that by simply cooking it, it can be transformed a “safe and wholesome” feed ingredient – but what stunned me was who was saying it: The AFIA.
The AFIA is the world’s largest – and most powerful – lobbying association that represents interests of the livestock feed and pet food industries; whose members represent about 75% of commercial feed and pet food sold in the United States.
Make no mistake, the AFIA is the supreme authority and arbiter of everything animal feed industry related; and no other group holds such sway in the industry, holds such immense power and influence, with members of the global animal feed industry.
ILLEGAL FILTHY, PUTRID & DECOMPOSED FOOD
Having said that, it is even more astonishing that their statement is in direct violation of the Federal Food Drug & Cosmetic Act, Section 402 (21 U.S.C. 342) where it deems food, including animal food, adulterated in several circumstances, which includes: “If it consists in whole or in part of any filthy, putrid, or decomposed substance, or if it is otherwise unfit for food.”
Worse, is the AFIA and the NRA’s promotion of the dangerous – and illegal – practice of making an adulterated food for animals, in direct violation of the FD&C Act.
WORTHLESS FILTHY, PUTRID & DECOMPOSED FOOD
In the document’s guidance, it suggests that because incoming material to rendering plants may be considered worthless by the suppliers, care may not have been taken to ensure its safe delivery:
“…[The] materials entering the rendering stream may not have any value to the supplying firm or farm…”
Which may not be surprising considering the source of such material, specifically:
“…slaughter plants, lockers, and 4-D operators must be current and on file…”
And don’t be surprised if the incoming raw material looks and smells like sh*t, that’s because it’s coming from a rendering plant, not a feed mill:
“…Incoming raw materials for rendering are not yet finished feed ingredients and may have unpleasant odors and appearances. However, sometimes physical hazards can be observed or chemical hazards can be smelled. Inspection of incoming raw materials for rendering should be based on criteria appropriate for rendering plants which may be different from feed mills.”
What I found astonishing, was the naked admission that material entering the rendering stream was generally considered it to have no economic value. None. Valueless.
DEADLY DECOMPOSING FOOD
There’s a reason why filthy, putrid and decomposing food is not allowed to be fed to animals – it’s dangerous – and illegal. According to the Final Rule on Current Good Manufacturing Practice, Hazard Analysis, and Risk-Based Preventive Controls for Food for Animals which reads, in part, that:
“Decomposition of animal food consists of microbial breakdown of the normal food product tissues and the subsequent enzyme-induced chemical changes. These changes are manifested by abnormal odors, taste, texture, color, etc., and can lead to reduced food intake or rejection of the food by the intended animal species, resulting in illness or death.”
GOVERNMENT ENDORSEMENT = FEWER INSPECTIONS
The AFIA also says that because the U.S. Food and Drug Administration officials support Safe Feed/Safe Food Certification Program, who cite it as a “model feed program”, that those facilities participating in the programs will have “fewer and shorter inspections as FDA expects these programs to be used in their risk ranking of facilities.”
AFIA TWEETS @RENDERERS
What is rendering? The recycling of unused #animal byproducts = 50 billion lbs annually.
W/o #animal rendering landfills would fill up in 4 years. @Renderers
AFIA’s goal for their Safe Feed/Safe Food Certification Program is to “further enhance consumer confidence in the feed and food supply. Healthy, productive animals mean a safe, sound food supply. And it starts with “Our Responsibility, Our Promise” to provide the best feed for dairy and beef cattle, swine, horses, poultry, fish and companion animals.” Further, they claim their sole mission is to “establish and promote generally accepted food safety guidelines designed to ensure continuous improvement in the delivery of a safe and wholesome feed supply for the growth and care of animals.”
And yet, all the while, the AFIA cloaks its abhorrent practice in the guise of a noble, ecological effort; that rendering is a green, sustainable practice that recycles an otherwise worthless material into a valuable, safe and wholesome food. To disguise such a repugnant – and illegal – practice into some quasi-Utopian vision for the sustainability of the earth’s resources is reprehensible.