CONTAMINATED GRAIN IN PETFOOD
As with the sources of proteins used in commercial pet foods, grains used in dry pet foods are materials unfit for human consumption. Often these are listed as middlings or screenings. These can include broken grains, hulls, chaff and joints, and can be contaminated with straw, dust, sand,dirt and weedseeds.
In less than 10 years we have seen two major recalls of pet foods because of mycotoxin contamination. Mycotoxin safe fungi which grow when grains are stored in damp conditions. Many types of mycotoxin scan cause serious illness and even death in both humans and pets.
In 1995, Nature’s Recipe pulled thousands of tins of dog food off the shelves after reports came in that dogs were vomiting and would lose their appetite after consuming the food. The fungus in this product was vomitoxin, caused by mouldy wheat used in the food. Although not a deadly toxin, it can cause serious illness in pets.
In late 1998, Doane Products, the manufacturer of a large number of private-label foods including 01′ Roy, recalled over 50 lines of foods it produces. The deaths of approximately 25 dogs were attributed to aflatoxin, a deadly toxin that was found in the corn Doane had used in its products.
We have to wonder how many other pets have become ill or died from eating contaminated pet food. If owners are unaware of other cases, they may never question the illness or death of a pet.
SODIUM PENTOBARBITAL RESIDUES IN PET FOOD
In the first edition of Food Pets Die For, I wrote about the studies undertaken by the University of Minnesota and the fact that its research showed that the euthanising drug, sodium pentobarbital, withstood the rendering process without degrading. This drug is used primarily to euthanise dogs and cats. Animals euthanised with this drug were ending up in pet foods, but no one could be sure from batch to batch how much of this drug was actually in the finished product.
In early 1999, while researching another aspect of the pet food industry, I came across a note in a report from the United States Animal Health Association (USAHA): “Over the years, the Center for Veterinary Medicine has received sporadic reports of tolerance to pentobarbital in dogs. In 1996, the CVM developed and validated a method to detect pentobarbital in dry dog food and a preliminary survey of 10 samples found low levels in 2 samples. CVM had collected 75 representative dry dog food samples and were in the process of analyzing these for pentobarbital levels.” At that point in time, testing had been ongoing for three years. It was clear from the onset that the FDA/CVM would not provide me with the test results. In May 2001, I filed a request under the Freedom of Information Act for all documentation relating to the testing of dry commercial dog foods.
Again the waiting began, and again I enquired numerous times as to the status of my request.
In September 2001, I did receive a reply from the Office of Communications for the FDA: “We request you wait until the evaluation process is complete, at which time we will send the full results to you.” They expected these to be ready in January 2002. It had been well over two years since I first
requested the information, five years from the time they had begun testing these foods.
Finally, in early March 2002, the results were published. In the 74 samples analysed, over half contained residues of this drug at levels ranging up to 32.0 parts per billion (ppb). In an earlier study done in 1998, the FDA found other products containing this drug, although the amounts were not listed in its report. Results of both studies can be viewed at the FDA/CVM website,http://www.fda.gov/cvrnlefoi/dfchart.htm
. The FDA/CVM also undertook an assessment of the risk dogs face if they ingest sodium pentobarbital in pet food. For eight weeks, an undisclosed number of dogs was given various
levels of this drug, and it was found that: “Dogs who received 150 and 500 micrograms of pentobarbital once daily for eight weeks had statistically higher liver weights (relative to their body weights) than the animals in the control groups. Increased liver -weights are associated with the increased production by the liver of cytochrome P450 enzymes.” The report concluded that the levels
of exposure to sodium pentobarbital which the animal might receive through food are “unlikely to cause them any adverse health effect”. The FDA/CVM has admitted that if these levels- any levels for that matter-of sodium pentobarbital were found in human foods, those products would be pulled from the shelves immediately.
In a letter dated March 22, 2002, from Stephen Sundlof, Director of FDA’s Center for Veterinary Medicine, regarding my query about this drug and the fact that under the Code of Federal Regulations it states, “Do not use in animals intended for food”, he writes: “A euthanasia solution such as pentobarbital cannot have a withdrawal time and its mechanism of action results in tissue reside, so it could not be used to euthanize animals intended for human or animal food.” It is not allowed for use in either human or animal food, yet the FDA does not plan to take any steps to prevent or prohibit the presence of this drug in pet food. Are we slowly killing our pets each time we feed them commercial pet foods?
Although the FDA/CVM tested a number of pet foods, we do not know if the food we are feeding our pets contains this drug; nor do we know what the long-term effects of ingesting this drug will be. Each batch of rendered material, meat meal, is different. It depends on what animals they are rendering on that particular day and if they were euthanised, died in the field or were killed by another method.
In the last 10 years we have also seen a number of other species, primarily birds of prey, die from ingesting euthanised dogs and cats that have been buried at landfill sites. Sodium pentobarbital stays in the tissues of these animals for extended lengths of time. We have also seen bears and even a tiger die after eating animals euthanised with this drug. It is clear that any animal that has been euthanised with sodium pentobarbital should be incinerated, not rendered and fed back to other animals.
DNA TESTING OF PET FOOD
The FDA/CYM also undertook DNA testing on the commercial dog foods they analysed. Results of the study were announced in January 2001, and th~ press release stated that no dog or cat DNA was detected: “Presently, it is assumed that the pentobarbital residues are entering pet foods from euthanized, rendered cattle or even horses.” In communications with agriculture veterinarians, most stated that sodium pentobarbital is seldom, if ever, used to euthanise cattle; its cost is “prohibitive”. Cattle are killed by captive bolt and gunshot. Horses are sometimes killed with this euthanising agent but, again, unless for some specific reason, i.e., the horse is seriously injured at a racetrack, the methods used to kill cattle are also used on horses.
The DNA testing results were extremely vague and provided no insight into the methods used to conduct such testing. What it amounted to was: “Take our word for it. No dog and cat DNA was detected in the food we tested.” After I consulted with a number of forensic scientists, it became apparent that if indeed the FDA/CYM undertook such testing, the methods used would be extremely important. No information was given on the DNA primers. No information was provided regarding whether they tested for all the metabolites of pentobarbital. Rather than going the route of asking for the documentation related to the testing, I immediately filed a request under the Freedom of Information Act. This was on March 3, 2002.
The wait began, once again, and during that time I was sending emails to the department, enquiring into the status of my FOIA request. On December 20, I received what I had hoped was the information I’d requested, but what I was sent was actually a copy of a paper titled “Validation of a Polymerase Chain Reaction Method for the Detection of Rendered Bovine-Derived Materials in Feedstuffs”. This was described as a document “similar” to what I’d requested. But had I wanted a similar report, I would have asked for such material.
On January 14, 2003, I contacted Steven Unger, Ombudsman for the Food and Drug Administration, and was advised by him that they would look into the matter. While I was out of the country in late January, Mr Unger wrote to advise me that my request had been denied by the FDA/CYM and that the denial had been mailed to me on January 22. From the time a request is denied, you have one month to file an appeal. On February 13, I still had not received the denial. Finally, in desperation, I asked that they fax me the denial, which they reluctantly agreed to do. I might add that the mailed denial finally reached me in late April. According to Dr Larkins, Ombudsman for the CYM, I was denied the report based on the fact that the information the CYM released was not the final report and was made up of “summary statements which were the written end-product of some oral briefings”. In other words, the DNA information that the CYM released is not worth the paper it is written on.
With just days left to file an appeal, a lawyer for People for the Ethical Treatment of Animals (PET A) agreed to prepare the appeal. On February 15, I mailed, Priority Post, my appeal to the FOI office. Through a tracking system and communication with the Post Office, I found that by February 27 my document had not been received by the appropriate office. On February 28, the Freedom of Information officer informed me that it would be acceptable, given the problems I had encountered with the agency, to fax my appeal, which I did on that date.
It is clear that the FDA/CYM has been feeling the heat from the pet food industry with regard to the use of euthanised pets in commercial pet food. With its press release noting that no dog and cat DNA existed in the rendered dog foods, the agency felt that pet owners would no longer confront the industry with the fact that companion animals were being used as sources of protein in their products.
RESEARCH BY CORPORATIONS AND UNIVERSITIES
Having spent over 13 years researching this industry, I thought I was aware of all aspects as they relate to the ingredients used in pet foods. I was wrong!
In early January 2002, I received a letter from a student at the University of Illinois, asking ‘i I could make some suggestions as to what they could do about nine dogs that were housed in a windowless lab at the university. These dogs had cannulas (tubes) surgically implanted in their sides so that samples of digested food could be taken. The studies included feeding the dogs raw and rendered animal by-products including “poultry necks and backs and viscera, and ground-up poultry feathers”. Until 2002, this research was funded by the lams company, but now is being funded by the soybean industry and the US Department of AgIjculture.
Over the years I’ve been aware of dogs and cats being used for research-research into human medicine, a practice of which I don’t approve-but I’d never realized that an industry that claimed to care about the welfare of pets would undertake such barbaric practices. I was soon to learn that this was just the tip of the iceberg. lams had been notorious for carrying on such experimentation.
Two animal rights organizations-In Defense of Animals, based in the United States, and Uncaged, based in the United Kingdom-outlined some of the animal experiments. Iams claimed that it used these studies to support its nutritional claims, which it uses to market its products. lams experimentation conducted on dogs and cats included the following:
WARNING! Do not read if you have a weak stomach or just ate!
1.Twenty-eight cats’ bellies were cut to see the effect of feeding the cats fibre; then the cats were killed (University of Nebraska and the lams Company; Bueno, A.R., et aI., Nutrition Research, vol. 20, no. 9, pp. 1319-1328,2000).
2. Twenty-four young dogs were intentionally put into kidney failure, subjected to invasive experimentation, then killed (University of Georgia and the lams Company; White, lV. et aI.,
American Journal of Veterinary Research, vol. 52, no. 8, pp. 1357-1365, 1991).
3. The kidneys of 31 dogs were removed to increase the risk of kidney disease, then the dogs were killed and their kidneys dissected (University of Georgia and the lams Company; Finco, D.R. et aI., American Journal of Veterinary Research, vol. 55, no. 9, pp. 1282-1290, 1994).
4. Bones in the front and back legs of 18 dogs were cut out and stressed until they broke, to show the effect of diet (University of Wisconsin and the lams Company; Crenshaw, T.D. et aI., Proceedings of 1998 lams Nutrition Symposium).
5. Ten dogs were killed to study the effect of fibre in diets (Mississippi State University and the lams Company; Buddington, R.K. et aI., American Journal of Veterinary Research, vol. 60, no. 3, pp. 354-358, 1999).
6. Eighteen male puppies’ kidneys were chemically damaged; the puppies were fed experimental diets, tubes were inserted into their penises; then the puppies were killed (Colorado State University and the lams Company; Grauer, G.F. et aI., American Journal of Veterinary Research, vol. 57, no. 6,
pp. 948-956, 1996).
7. Twenty-eight cats were surgically forced into kidney failure and either died during the experiment or were killed to study the effects of protein (University of Georgia and the lams Company, Proceedings of the 1998 lams Nutrition Symposium).
8. Fifteen dogs’ bellies were cut open and tubes were attached to the dogs’ intestines, the contents of which were pumped out every 10 minutes for two hours; then the dogs were killed (University of Nebraska-Lincoln and the lams Company; Hallman, LE. et aI., Nutrition Research, vol. 16, no. 2, pp. 303-313, 1996).
9. Sixteen dogs’ bellies were cut open and parts of the dogs’ intestines were taken (University of Alberta and the lams Company, Journal of the American Society of Nutritional Sciences, 1998).
10. Healthy puppies, chicks and rats had bone and cartilage removed to study bone and joint development (Purdue University and the lams Company, Proceedings of the 2000 lams Nutrition
11. Invasive procedures were used to study bacteria in 16 dogs’ intestines (Texas A&M University and the lams Company; Willard MD, et aI., American Journal of Veterinary Research, vol. 55, no. 5, May 1994).
12. Twenty-four cats had their female organs and parts of their livers removed; they were made obese, then were starved (University of Kentucky and the lams Company; Ibrahim, W.H. et aI., American Journal of Veterinary Research, vol. 61, no. 5, May 2000).
13. Fifty-six dogs had their female organs removed to study beta carotene (Washington State University and the lams Company; Weng, B.C. et aI., Journal of Animal Science, vol. 78, pp. 1284-1290,2000).
14. Sixteen dogs’ bellies were repeatedly cut to take parts of the intestines (Texas A&M and the lams Company; Willard, M.D. et aI., Journal of the Veterinary Medical Association, vol. 8, pp. 1201-1206, 1994).
15. Six dogs had tubes implanted into their intestines and fluid drained repeatedly to study cereal flours (University of Illinois and the lams Company, Murray, S.M. et aI., Journal of Animal Science, vol. 77, pp. 2180-2186, 1999).
16. Thirty dogs were intentionally wounded and patches of skin containing the wounds removed to study diet and the effect of various ingredients on wound healing (Auburn University and the lams Company; Mooney, M.A. et aI., American Journal of Veterinary Research, vol. 59, no. 7, pp. 859-863, 1998).
17. Five dogs’ bellies were cut open and tubes inserted into their intestines to study the effect of fibre
(University of Illinois and the lams Company, Muir, H.E. et aI., Journal of Animal Science, vol. 74, pp. 1641-1648, 1996).
18. Parts of the large intestines of 28 dogs were removed to study the effects of fibre (University of Missouri and the lams Company; Howard, M.D. et aI., Journal of Animal Science, vol. 75, suppl. 1, pp. 136,
19. Parts of the intestines and immune system of 16 dogs were cut out to study the effects of fibre (University of Alberta and the lams Company, Proceedings of the 1998 lams Nutrition Symposium).
20. Five dogs had tissue from large and small intestines removed to study intestinal tract needs (University of Illinois and ” the lams Company, Proceedings of the 1998 lams Nutrition Symposium).
Procter & Gamble (P&G) purchased lams in September 1999 and issued a code of ethics. Animal People, an on-line organization devoted to the health and welfare of pets, reported in June 2001 that P&G stated its intention to phase out animal testing as quickly as alternatives could be developed and approved by regulators.
In 2002, an investigator from PETA infiltrated one of the lams labs in the US. What was found was a horrifying situation where dogs and cats were confined to small cages for up to six years. Dogs had their vocal cords removed so they could not bark. The animals suffered with severe heat in the summer and freezing temperatures in the winter. Videotapes showed researchers dumping dogs on concrete floors after having huge chunks of muscle cut out of their thighs. The cruelty continued. Cats were confined in cinder-block rooms with wooden boards, nails sticking out of them, as resting places. The PETA investigator watched as one of these boards fell on a cat, killing the animal.
Be assured that lams is not the only company involved in such cruel research. Ralston Purina, prior to its acquisition by Nestle, Hill’s Pet Nutrition, owned by Colgate-Palmolive, Pedigree Pet Foods, owned by Mars, and Alpo Pet Foods, prior to its acquisition of Nestle, are just a few of the companies involved in animal experimentation.
PETFOOD: A GLOBAL CONCERN
The pet food industry worldwide is basically the same as that in the United States with little, if any, regulations regarding the ingredients used in its products. And as with the situation in Canada, a vast percentage of the pet foods sold in other countries is imported from the United States.
In Australia, the Pet Food Industry Association of Australia (PFIAA), a voluntary organisation, fills the same role as the Pet Food Institute in the United States, with a goal of promoting pet foods and setting standards for this self-regulated industry. Again, labelling text, not the source of ingredients, is the prime concern of this agency.
The other Australian agency involved with pet food, the National Registration Authority for Agriculture and Veterinary Chemicals, has as its “main role, with regard to pet foods, the registration of therapeutic claims associated with veterinary diets”. Their role would not cover pet foods sold in
Supermarkets or feed stores; only pet diets that are sold through veterinary clinics and used for health-related problems. The NRA’s role parallels that of the Center for Veterinary Medicine(CVM) in the USA.
In August 1997, the Australian Competition and Consumer Commission (ACCC) asked for a guideline review of pet foods after consumer complaints about the labelling of certain varieties of pet food being potentially misleading as to which protein was the main one. One example was a pet food which was essentially a meat product and was labeled as a fish product. During its investigation,the ACCC found that the labelling of other varieties of canned pet food was also potentially misleading and deceptive. It was agreed by the ACCC and the PFIAA that revisions to thelabelling wereneeded.
In the United Kingdom, the organization that oversees the pet food industry is also much like the Pet Food Institute in the United States. The Pet Food Manufacturers’ Association (PFMA) represents approximately 95% of the UK pet food manufacturing industry and is comprised of 56 member companies. Their role is to promote pet food products and responsible pet ownership, represent
their members’ views to United Kingdom and European Union government departments and raise standards in the pet food industry.If you believe PFMA’s literature, then the policies in the United Kingdom are much stricter than those of other countries. “Member companies only use materials from animal species which are generally accepted in the human food chain,” states Alison Walker, spokesperson for the PFMA. “This rules out the use of any materials from horses, ponies, whales and other sea mammals, kangaroos and many other species. The pet food industry only uses materials of beef, Iamb, poultry and pork origin, fish, shellfish, rabbit and game.”
The literature further states that PFMA members use only material derived from animals that have been inspected and passed as fit for human consumption. Most of the material derived from these animals would be listed on the labels as meat by-products. I questioned the PFMA about the pet foods that are imported to the United Kingdom because of the dubious ingredients used in some
of these products. Alison Walker of the PFMA replied to my inquiry, writing: “The import certification relates to materials specifically allowed in pet food-e.g., low-risk materials or, in other words, that [which] is fit for, but not intended for, human consumption.” Ms Walker also advised that it is illegal to use dead companion animals in the manufacture of pet food in the United Kingdom and in most European countries. In the US and Canada, there are no regulations which prohibit this material from being used in commercial pet food.
The PFMA leaves it to the member companies to operate their own in-house quality assurance programs and feeding trials. Pet food manufacturers are also in charge of testing the incoming raw materials used in their products. Because of the number of cases of bovine spongiform encephalopathy (BSE) in the United Kingdom, and the number of cats that have died from the feline form of this disease (90 documented cases to date), certain materials derived from beef have been banned for use in pet food. This includes the head, spleen, thymus, tonsils, brain and spinal cord, and the large and small intestines of cows as well as sheep or goats. It is still legal to use pigs in pet foods because there have been no known cases of spongiform encephalopathy in these animals.
WHAT PET OWNERS CAN DO
As we have seen, the commercial food we are feeding our pets is generally garbage and, in my opinion, is unfit to feed to our pets. For the last 13 years, I have fed my pets a home-prepared diet comprised of lightly cooked meat or fish, grains and’ fresh vegetables and fruit. All of them, including my 27-year-old cat, have done extremely well.The only way we will see a change in this industry is for pet owners to boycott pet foods that contain inferior ingredients, including drugs which would never be allowed in the human food chain. We must also boycott companies that undertake experiments on animals-not only on dogs and cats but on all animals. It is apparent that the only reason these experiments are undertaken is to ascertain the cheapest, most viable sources of protein, grains and fats that can be used in pet foods. It is you and I who will make a difference.
About the Author:
Ann Martin is the author of Protect Your Pet (NewSagePress, 2001) and Food Pets Die For (NewSage Press,1997, 2nd edition 2003). For more information, visit the web page http://www.newsagepress.com/foodpetsdiefor.html#author
. To order Ann Martin’s books, contact NewSagePressby telephone on 877 695 2211 (toll free in North America only), by email at email@example.com
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