All of us at AAFCO in Denver 2015

Find Out What Happened in Denver at the AAFCO Conference

UPDATE: I have no association with Susan Thixton of Truth About Pet Food, either personally of professionally, or the Association for Truth in Pet Food.

Have you ever wonder what happens when a cat is set among the pigeons? Put a bunch of pet food safety advocates among a room full of pet food industry big wigs and government officials at an AAFCO meeting and you’ll find out.

This time, along with long-time pet food consumer advocates Susan Thixton of Truth about Pet Food, Dr. Jean Hofve of Little Big Cat and yours truly, we were joined by a fabulous crew of fearsome advocates, including:

They all showed tremendous courage and passion by speaking up for pets and consumers in front of hundreds of pet food industry’s biggest players in Big Pet Food. I am proud and honored to call them my friends and colleagues.

First up was the Enforcement Issues Committee meeting, and the topic of fraudulent pet food (that’s pet food that doesn’t contain what’s on the label).

Keep in mind, these a just a few of the highlights of the meetings; if I were to discuss every topic we went into, it would be a several page report that most readers would find as dull as dishwater.

With that, here we go:

The Enforcement Issues Committee meeting

Discussion: Potential Misbranding of Feed Ingredients and Finished Commercial Feeds

The discussion opened with the chairman of the meeting, Stan Cook, describing a personal experience witnessing two lions consume their prey by eating the viscera first, and how some animal by-products the U.S. finds objectionable are happily consumed in other countries, suggesting that U.S. consumers distaste for animal by-products is misplaced and indeed even irrational.

He elaborated by saying that consumers who “humanize” their pets were incapable of rational thought. He said that people that humanize their pets make “irrational and erratic behavior,” examples included making their own food at home, feeding table scraps, buying all human edible foods for their pets, and so on.

Unfortunately, he succeeded in alienating every pet parent in that room who does think of their pets as members of the family by describing them as people driven by irrational choices.

I, as I’m sure all of my colleagues was, deeply offended by his dismissive attitude and criticisms of the deep bond and emotional connection that people have with animals.

After that unfortunate start, Dr. Jean Hofve put forward the discussion regarding food fraud in the pet food industry. She cited the recently published article in the Journal of American Veterinary Medical Association about fraud and mislabeling in pet food.

Dr. Jean noted in her proposal that,

“There have now been three recent studies that have found undeclared proteins in a variety of pet foods and treats in 38% to 100% of OTC products. In some cases, the protein source specified on the label was entirely absent from the product.”

Recent studies suggest widespread misbranding of commercial pet foods in regards to the type of animal proteins labeled to be included in the product versus what animal proteins were found in the pet food after testing.

Despite the tests put forward as an example of food fraud and/or sloppy manufacturing processes, members of industry quibbling over the unreliability of the testing methods used. They argued that, because there was no standard for conducting species identification tests, the suggestion was that therefore they must be invalid.

Yet, food fraud is not a new problem, nor is species identification. Despite a global effort to stop food fraud, particularly in the wake of the horse-meat scandal in Europe, and the pervasive problem of mislabeling of fish for economic gain, industry did not seem to acknowledge that the same problem exists in the pet food/animal feed sector, as the studies cited by Dr. Jean Hofve, consistently demonstrated.

The outcome of the topic on how industry and control officials can work together to ensure labeling compliance to avoid the misbranding and adulteration of commercial feeds was to establish a standard for testing pet food to eliminate comparative problems in testing methodologies and suggested that a uniform testing method be approved by AAFCO.

After that auspicious opening, we come to AAFCO’s Pet Food Committee, of which Susan, Jean, and I are advisers:

The Pet Food Committee meeting

Discussion: ‘Human-grade’ and ‘human-grade ingredients’ claims

One of the most hotly anticipated topics was what should be done about the proliferation of ‘human-grade’ ingredient claims in pet food.

A little background: Before the meeting began Susan, Jean, and I submitted a formal request to eliminate the term, as it has no legal definition and replace them with the terms used in the Code of Federal Regulations: that food is either edible or inedible. More specifically, the terms refer to human-edible vs. inedible but suitable for use as animal food.

We proposed that ‘human-grade’ claims on pet food should be defined and labeled as human edible; while pet food not meeting that criteria should be defined and labeled as inedible/condemned per USDA definition.

During the meeting I requested that the FDA consider continuing to issue ‘Statements of No Objection’ for qualifying pet food manufacturers who have verified that their pet food is indeed ‘human-grade’ in order to avoid problems with regulators, such as when states refuse to accept such claims as valid and block a manufacturer from selling that food in their state.

The FDA has said,

If a manufacturer is able to substantiate and verify the claim, it neither untruthful nor misleading and a company has a constitutional right to make truthful statements about the human grade quality of its products on the labels.

However, going forward, the FDA wants to leave it up to the states to decide what is acceptable, and if they choose not to allow such claims, they can block the entry of pet foods making ‘human-grade’ claims in that state.

After that meeting, was the Ingredient Definitions meeting, which again, Susan, Jean, and I are advisers to:

The Ingredient Definitions Committee meeting

Discussion: Create a Human Food Processing By-Products definition and to edit Food Processing Waste to include Stored Grocery Products.

This discussion created quite an uproar with consumer advocates, because of the downright nauseating suggestion that ‘grocery store waste’ be included in the ‘Human Foods Processing By-Products’ definition an acceptable food for animals.

As Susan noted in her post about the meeting,

“On a pre-meeting conference call we learned that this ingredient is grocery store waste – examples given were expired yogurt and rotting lettuce. These expired, rotting foods are collected behind every grocery in a large dumpster. Yes, a dumpster – as in where garbage goes. Sitting there – in the weather – waiting for the rendering company truck to pick this waste up and cook it…including cooking the plastic packaging these rotting foods are contained in (such as all of those yogurt cups).”

The problem with the “waste,” or more accurate description “garbage,” is that it was unclear whether the packaging surrounding the garbage (such as yogurt containers, and Styrofoam meat trays, etc.) would be removed before processing. Mercifully, AAFCO rejected the proposal, because it did not specify whether packaging would be removed and the definition was not clear or concise enough for authorities.

Even so, it was affirmed that at least thirty states (possibly up to fifty states) already use grocery store waste as animal food. However, the FDA explained that they did not support this change since the name of this ingredient was too broad, therefore if AAFCO were to go ahead and amend the definition they would be in violation of the Memorandum of Understanding between the FDA and AAFCO.

Yet, an industry spokesperson tried to assure members that this proposal was nothing new, because the industry has been using bakery waste since 1962 in animal feed, with the requirement that bakery waste be “mechanically separated” from its packaging. This was somewhat reassuring, but contradictory to the pre-meeting disclosure that that would not be the case with waste products other than bakery products.

My first thought, aside from the horror of such a lack of concern for what livestock would be eating, was what about the dangerous chemical by-products of plastics (such as phthalates and BPA) that would be in the animal feed if plastic packaging were to be cooked up along with the rest of the garbage (that humans would also eventually consume as well by drinking their milk, etc.)?

I didn’t have a chance to address my concern, because Dr. Cathy Alinovi stepped up to the microphone and took the words right out of my mouth.

However, no sooner had she brought up her concern about the dangers of the chemical by-products in plastic that would contaminate milk, poultry and meat – when there erupted a loud chorus of boos, from what sounded to be like, nearly every member of industry in the audience.

We were so aghast at such a reaction to a valid concern, that we all gave Cathy a rousing applause and standing ovation when we met with her later.

I was very proud of her for standing up for animals and ashamed for the members of industry who attempted to silence her by publicly humiliating her. Read more about it in Susan’s post on Truth About Pet Food.

Discussion: What does “Feed Grade” mean?

We were really looking forward to this discussion, however, unfortunately, as it often happens in these meetings, time did not allow for this discussion and it was tabled until the next meeting. In the interim, a webinar is planned to discuss this and other topics the committee ran out of time for.

If you want to know more about the issue, read my post on ‘what is feed grade,’ because it applies to what’s in pet food.


Thanks to all of you who made this possible

I couldn’t have attended this AAFCO meeting had my readers not generously showed their support and chipped in to help me meet the cost. Incredibly, it cost well over $1,500 to fly there and attend the meeting. But, fortunately Dr. Jean Hofve graciously invited me to stay at her home in Denver, so I didn’t have the expense of a hotel. Thank you Dr. Jean!

The next AAFCO meeting will be in less than six months, so I hope you won’t object to another plea for funding again.

And, I hate to mention it again, but I desperately need to replace my broken-down old laptop, but I don’t have the money to buy one (even a refurbished one). So, is there anyone out there with a working laptop they no longer use who would consider donating it to me? Pretty please with sugar sprinkles on top? Or would you consider donating a wee bit of money to help me buy one?

I really find it distasteful to have to ask for donations, because I am such a proud person. But, when I think of all the pets that are harmed by unsafe pet food, I swallow my pride and beg like a dog for a bone!

I am so grateful to all of you for believing in me, in us, by helping us work for a future where pet food and animal feed will be safe, healthy and wholesome.

So, thank you and bless each and every one of you! I love you all!


Mollie Morrissette


p style=”text-align: justify;”>Note: I must apologize on behalf of my host for my website being down! When I came back from AAFCO, I found that my website was in a mess of trouble, which, as it turned out it was entirely my host’s fault. So, I switched to new (and significantly more costly) managed web-hosting solution. Naturally, I am happy to pay for this myself, but, help is always gratefully appreciated: Click here to make a donation. Thanks for your patience and tolerance!

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Mollie Morrissette

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

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