Final Proposed Definitions Feed Grade and Human Grade

After many meetings, a few arguments, and several stress related headaches – we have finalized the proposed definitions of feed grade and human grade.

These are still proposed definitions; they will be presented to the Pet Food Committee and the Ingredient Definitions Committee for a final discussion and vote (by AAFCO members) at the January 2016 AAFCO meeting.

“Human Grade: Every ingredient and the resulting product are stored, handled, processed, and transported in a manner that is consistent and compliant with regulations for good manufacturing practices (GMPs) for human edible foods as specified in 21 CFR 117.”

This translates to: each ingredient including each supplement is human grade (humans could consume it) and each ingredient and the final product has been manufactured, warehoused, and transported per legal requirements of human food. Pet foods that meet these requirements will be allowed to state on the label ‘Human Grade’. Basically, human grade = food.

“Feed Grade: Material that has been determined to be safe, functional and suitable for its intended use in animal food, is handled and labeled appropriately, and conforms to The Federal Food, Drug and Cosmetic Act unless otherwise expressly permitted by the appropriate state or federal agency.”

The same definition as Feed Grade will be used for ‘Suitable for use in animal feed’ (which also applies to Pet Grade).

The Feed Grade definition translates to: ingredients might meet the legal requirements of food (per The Federal Food, Drug and Cosmetic Act), or ingredients might be considered illegal (per The Act). Illegal feed grade ingredients – allowed by FDA Compliance Policies or allowed by any State that decides to give permission to a supplier to sell an illegal ingredient (adulterated ingredient per The Act) to pet food or animal food – will NOT be required to be disclosed to consumers the illegal ingredient quality. Feed Grade pet foods will be classified as pet ‘food’ even though they do not meet the legal requirement of food.

We (consumer advocates) proposed including the words “determined to be safe and functional through valid scientific evidence” in the feed grade definition. However no one else agreed – we were shut down with this request. The argument from everyone was that this would place a burden on industry to prove ingredients are safe. Our response was ‘So?’ They felt it would confuse some ingredient suppliers, and that the definitions of each feed grade ingredient and existing law already required ingredients to be safe. This was a blow to our side. The wording for the ‘valid scientific evidence’ was taken from AAFCO – in their ‘Affidavit of Suitability’ statement (which any regulatory authority can require a manufacturer to provide). But again, they did not agree with including this in the definition.

I believe the definitions are about the best we can do. We won’t know until January what a stir they will cause at the meeting – when the vote to finalize them takes place (of course, I will share every word after the meetings in January).

Something new learned from these meetings: any U.S. state – at their own discretion – can individually approve a feed ingredient to be used in any animal food (livestock or pet). The perfect example of this is euthanized bird flocks (chicken, geese, turkey) diagnosed with avian flu. Each state – at their own discretion – can allow these euthanized birds to be sold as feed ingredients or each state at their own discretion can require the euthanized birds to be destroyed (and not sold as feed ingredients). And at each state’s individual discretion – a feed ingredient can be sold to pet food or livestock food even if it does not have a legal definition. The perfect example of this was pea protein, pea flour, and pea starch. Individual states allowed these products to be included into pet food for years prior to being a legally defined pet food ingredients. This ‘individual discretion’ is written into law in many states. And of course, no consumer is told what is ‘discreetly approved’ by their state or why it was approved. In other words…individual states (and FDA) can do whatever they want.

Learning the above – that it is specific state law (in most states) to allow State Department of Agriculture representatives to approve feed ingredients is very concerning to me. As I don’t trust most in this industry – a concern is a ‘pay-off’ to a underpaid/overworked State official to approve something that should not be approved. We have no evidence this has happened or will ever happen in pet food/animal feed – but it does make me wonder.

Something else that has happened over the last 3 or so meetings, is that industry went almost silent. During the first couple of meetings industry representatives were VERY argumentative. And then they went silent. On one of the meetings (after the silence went into effect), no one but myself, Dr. Hofve and the AAFCO representative said anything. Not one peep from industry (but they were on the call – all attendees are listed in the web meeting software). I’m sure they haven’t given up and decided to sit back and let us have our way – my guess is that they decided to do their ‘work’ directly with regulatory authorities and will do more of their ‘work’ when the definitions we developed go for a final vote. It certainly was/is suspicious for them to go silent.

It will be significantly important for all pet food consumers to educate other consumers on the legal definitions of feed grade and human grade (and their translations). Once these definitions are finalized (scheduled for the January meeting in South Carolina) – I will work on providing tools for pet owners to help share these definitions.

We – consumers and their AAFCO advocates – did an amazing thing getting ‘feed grade’ to the table to be defined. And I have to thank AAFCO President Richard TenEyck for getting feed grade to discussion. The term feed grade has been used in pet food/animal feed for decades – never having a legal definition, never being held to a particular standard. Soon, it will be legally defined. This is a very good first step. We have many more steps in front of us, but this one was/is a very good start.

Wishing you and your pet(s) the best,

Susan Thixton
Pet Food Safety Advocate
Association for Truth in Pet Food

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