4-D, For Shame. How FDA breaks the law and sickens animals
By GoodnessGraciousTreats
Driven by multi-billion dollar organizations like Whole Foods, the health food sections of regional chains, independent grocers, and small local co-ops and farm stands, access to and consumer awareness of quality food has grown dramatically. People increasingly demand organic, all-natural, GMO-free, free-range, sustainably-grown products. This surge fuels not only human health, but improvements in farming and the wellbeing of livestock. This is a great thing. The food for animals that people call their companions, however, still lingers in the dark ages.
One could argue it’s separated not only by eons, but by galaxies.
In flagrant violation of federal law, FDA allows illegal waste into our pets’ food. From the leading ingredients to the last on the list, you’ll find these toxins on the labels of not only the five biggest pet food companies but the premium and private-label brands of health-conscious players.
Materials from animals that are dead (other than by slaughter), diseased, dying, or disabled (“4-D” for short) are allowed into animal food. So are substances that have been tainted or otherwise spoiled so as to make them unfit. While specifically forbidden for use in whole or in part for humans or animals by the Food, Drug and Cosmetic Act, FDA has implemented their own “Compliance Policies” to avoid enforcement and break the law.
Driven by multi-billion dollar organizations like Whole Foods, the health food sections of regional chains, independent grocers, and small local co-ops and farm stands, access to and consumer awareness of quality food has grown dramatically. People increasingly demand organic, all-natural, GMO-free, free-range, sustainably-grown products. This surge fuels not only human health, but improvements in farming and the wellbeing of livestock. This is a great thing. The food for animals that people call their companions, however, still lingers in the dark ages.
One could argue it’s separated not only by eons, but by galaxies.
In flagrant violation of federal law, FDA allows illegal waste into our pets’ food. From the leading ingredients to the last on the list, you’ll find these toxins on the labels of not only the five biggest pet food companies but the premium and private-label brands of health-conscious players.
Materials from animals that are dead (other than by slaughter), diseased, dying, or disabled (“4-D” for short) are allowed into animal food. So are substances that have been tainted or otherwise spoiled so as to make them unfit. While specifically forbidden for use in whole or in part for humans or animals by the Food, Drug and Cosmetic Act, FDA has implemented their own “Compliance Policies” to avoid enforcement and break the law.
What's Cookin'? Ever Wonder What Happens to Dead Animals? By Van Smith
According to FDA: “No regulatory action will be considered for animal feed ingredients resulting from the ordinary rendering process of industry, including those using animals which have died otherwise than by slaughter.”
An article appearing in Baltimore’s City Paper highlights the routine of rendering road kill, decayed materials, and thousands of euthanized dogs, cats and wildlife from the city shelter into products sold to Purina, Alpo and Heinz.
Former AAFCO president Hersh Pendell discusses recycling dead pets into pet food
Former president of American Association of Feed Control Officials (AAFCO) Hersh Pendell admits in an interview that “Fluffy” can most certainly be a hidden ingredient in dog food. (AAFCO is the association that sets the definition of ingredients for animal feed - inclusive of the pet food industry. They also suggest nutrient standards.)
Moreover AAFCO allows materials coming from chickens that have died by means other than slaughter (e.g. bird flu) to meet the definition of “chicken”. The very fact that the pet food industry allows 4-D chicken to meet the definition of “chicken” on a label is misleading to consumers.
Howard Lyman discusses how and he and Oprah successfully defended themselves from libel claims by Texas ranchers by showing photographic evidence of piles of dead pets with collars still on destined for rendering into animal feed.
According to FDA: “No regulatory action will be considered for animal feed ingredients resulting from the ordinary rendering process of industry, including those using animals which have died otherwise than by slaughter.”
An article appearing in Baltimore’s City Paper highlights the routine of rendering road kill, decayed materials, and thousands of euthanized dogs, cats and wildlife from the city shelter into products sold to Purina, Alpo and Heinz.
Former AAFCO president Hersh Pendell discusses recycling dead pets into pet food
Former president of American Association of Feed Control Officials (AAFCO) Hersh Pendell admits in an interview that “Fluffy” can most certainly be a hidden ingredient in dog food. (AAFCO is the association that sets the definition of ingredients for animal feed - inclusive of the pet food industry. They also suggest nutrient standards.)
Moreover AAFCO allows materials coming from chickens that have died by means other than slaughter (e.g. bird flu) to meet the definition of “chicken”. The very fact that the pet food industry allows 4-D chicken to meet the definition of “chicken” on a label is misleading to consumers.
Howard Lyman discusses how and he and Oprah successfully defended themselves from libel claims by Texas ranchers by showing photographic evidence of piles of dead pets with collars still on destined for rendering into animal feed.
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Industry regulators are rightly criticized by consumer advocates – like Howard Lyman (the Mad Cowboy who together with Oprah Winfrey and Harpo Productions, successfully defended themselves from a libel claim by Texas Ranchers for discussing the process of recycling pets, cattle, road kill and other decayed matter into animal food); and Susan Thixton of Truth About Pet Food – for caving to big-business pressure; allowing deceptive and incomplete labeling; and failing to protect our pets, farm animals and people.
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Pet parents are not the only ones who should be concerned with FDA’s and AAFCO’s failures. The toxins allowed into farm animal feed trickle into the human food supply.
Recall the mad-cow epidemic in the 1980s? Its cause was cattle being fed the remains of other diseased animals (as rendered meat and byproducts). While 4.4 million cattle were slaughtered in an eradication program that followed, a variant of Mad Cow disease infected and killed another person in 2008.
While FDA Compliance Policies state that they are “aware of the sale of… 4-D animals to salvagers for use in animal food… [that this] raw, frozen… meat may present a potential health hazard to the animals that consume it and the people who handle it,” they specifically limit any regulatory action to “follow up to complaints or reports of injuries” and advise against “expending substantial resources.”
Recall the mad-cow epidemic in the 1980s? Its cause was cattle being fed the remains of other diseased animals (as rendered meat and byproducts). While 4.4 million cattle were slaughtered in an eradication program that followed, a variant of Mad Cow disease infected and killed another person in 2008.
While FDA Compliance Policies state that they are “aware of the sale of… 4-D animals to salvagers for use in animal food… [that this] raw, frozen… meat may present a potential health hazard to the animals that consume it and the people who handle it,” they specifically limit any regulatory action to “follow up to complaints or reports of injuries” and advise against “expending substantial resources.”
Propagation of disease is not the only risk of 4-D meat sources. Pentobarbital, the euthanasia drug, is not destroyed in any rendering process.
According to the US Fish and Wildlife Service (“FWS”), “rendering is not an acceptable way to dispose of a pentobarbital-tainted carcass. The drug residues are not destroyed in the rendering process, so the tissues and by-products may contain poison and must not be used for animal feed.”
The FWS is correct as FDA’s own analysis has found pentobarbital residues in dozens of US pet foods including premium brands. Bottles of Fatal-Plus (i.e. pentobarbital) used on animals clearly warn against using the drug on food animals. And just this year in Spain, canine and feline DNA was identified in some international brands of dog food.
According to the US Fish and Wildlife Service (“FWS”), “rendering is not an acceptable way to dispose of a pentobarbital-tainted carcass. The drug residues are not destroyed in the rendering process, so the tissues and by-products may contain poison and must not be used for animal feed.”
The FWS is correct as FDA’s own analysis has found pentobarbital residues in dozens of US pet foods including premium brands. Bottles of Fatal-Plus (i.e. pentobarbital) used on animals clearly warn against using the drug on food animals. And just this year in Spain, canine and feline DNA was identified in some international brands of dog food.
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This is not the worst of it. In other Compliance Policies, FDA does not object to the diversion to animal feed of:
So how does a health-conscious pet parent ensure they are not feeding their beloved companion the 4-D toxic waste FDA and AAFCO allow into animal food?
The answer: read the label and do your homework. According to the FDA, “meat” for animal feed comes from:
“independent [rendering] plants that obtain animal by-product materials, including grease, blood, feathers, offal and entire animal carcasses from the following sources: butcher shops, supermarkets, restaurants, fast-food chains, poultry processors, slaughterhouses, farms, ranches, feedlots, and animal shelters.” [emphasis added]
- Food adulterated with rodent, roach, or bird excreta.
- USDA detained meat and poultry products contaminated with drug or other chemical residues
- Food with pesticide contamination in excess of the permitted tolerance or action level
- Food with pesticide contamination where the pesticide involved is unapproved for use on a food or feed commodity
- Food contaminated by industrial chemicals
- Food contaminated by natural toxicants
- Food contaminated by filth
- Food with microbiological contamination
- Food over the tolerance or unpermitted drug residues
So how does a health-conscious pet parent ensure they are not feeding their beloved companion the 4-D toxic waste FDA and AAFCO allow into animal food?
The answer: read the label and do your homework. According to the FDA, “meat” for animal feed comes from:
“independent [rendering] plants that obtain animal by-product materials, including grease, blood, feathers, offal and entire animal carcasses from the following sources: butcher shops, supermarkets, restaurants, fast-food chains, poultry processors, slaughterhouses, farms, ranches, feedlots, and animal shelters.” [emphasis added]
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Aside from the loophole that allows 4-D materials to be called “chicken,” illegal 4-D waste in our pets’ food can fall under a number of names. Any ingredient that does not disclose the species (e.g. beef, lamb, etc.) from which it came is a flag. The likely culprits are: “meat” or “meat and bone meal;” “byproduct” or “byproduct meal;” “animal fat;” “animal digest” or “natural flavors” (a term that includes animal digest).
As for the rest of the poisons from pesticides, industrial chemicals, unpermitted drug residues, natural toxicants, and filth, the answers are to start by looking for premium, USA made, USA-sourced brands that specify they use ingredients that meet USDA or FDA standards for human consumption. You may have to call the manufacturer, however, to find this information as the pet food industry – which remains under the oppressive thumb of five Goliaths: Nestle Purina, Proctor & Gamble, Colgate Palmolive, Mars, and Del Monte (collectively controlling 85% of the global market) – bars manufacturers from labeling their ingredients as “human grade.”
As for the rest of the poisons from pesticides, industrial chemicals, unpermitted drug residues, natural toxicants, and filth, the answers are to start by looking for premium, USA made, USA-sourced brands that specify they use ingredients that meet USDA or FDA standards for human consumption. You may have to call the manufacturer, however, to find this information as the pet food industry – which remains under the oppressive thumb of five Goliaths: Nestle Purina, Proctor & Gamble, Colgate Palmolive, Mars, and Del Monte (collectively controlling 85% of the global market) – bars manufacturers from labeling their ingredients as “human grade.”
