When looking into the many loopholes in dog food regulations, one big factor is Human Grade vs. Feed Grade pet food. All pet food falls into one of the two categories. Both of these terms refer to a final product, whether it’s food or treats, and define who is safe to consume it; hence the name Human Grade.
Human Grade
Food that is manufactured per human food safety standards, meaning it is safe for human consumption, is defined as human grade. This food abides by all of the regulations and typically is FDA-approved. Even if a product is made with human grade ingredients it does not mean its finished product will be legally human grade. This is due to outside factors such as cooking, preserving and storing of the final product.
Feed Grade
Feed grade is the opposite of human grade defined as a finished product that is ruled not suitable by the FDA for human consumption. It is still allowed to be fed to animals due to the ingredients being human grade, or the manufacturing process. For example, if the food or treat is heated to extreme temperatures most bacteria should be burned away leading it to be “okay” for dogs to eat. Some ingredients can also cause a food to be feed grade such as by-products, chemicals, fillers and “4D” meats. If you don’t know what 4D meats are, you may want to sit down before reading the next sentence. 4D meats are from animals who are dying, diseased, disabled or deceased. Yes, your dog could be eating decomposed meat from a premature animal.
To stray clear of feed grade, and 4D meats there are a few things to look for. If the list of ingredients contains a phrase like corn gluten meal, or animal digest, we recommend running in the opposite direction. The definition of animal digestion by the Association of American Feed Control Officials states that animal digestion is produced by the chemical or enzymatic hydrolysis of clean animal tissue that has not undergone decomposition. While including already broken-down meats in pet foods is not in of itself concerning, the fact that you have no idea what is hiding behind this label is. Everything from the diseased, animals who have prematurely died, and may have other contaminants.
Laws and Regulations Around Human/Feed Grade
While we do have laws around certain foods consumable for our dogs, some loopholes still exist. Pet food manufacturers are not required to disclose to consumers if ingredients included in pet food are human grade or feed grade. This leads us, the consumers, to do a little more investigating if we really want to know what’s in our dogs’ food. On top of the secrecy, there is not one AAFCO/FDA pet food ingredient definition that requires the ingredient to abide by federal law. Consumers are never informed if ingredients in a pet food violate law and manufacturers are not required to disclose it. In all, the FDA has approved food deemed unsafe for human consumption, safe for our dogs consumption. While we don’t understand the reasoning behind it, we believe it has to do with financial interests.
In 2019, the FDA had announced they were going to make changes to regulation of ingredients in dog food. This specifically included the use of 4D meats. However, after the announcement there has been no changes. The FDA concludes that “we do not believe that the use of diseased animals or animals that have died otherwise than by slaughter to make animal food poses a safety concern and we intend to use enforcement discretion where appropriate.” This will take us into another law loophole, GRAS (General Recognition of Safety). Food is determined to pass GRAS guidelines under the conditions:
- Been commonly used since the 1960s with evidence its been safe to consume.
- Scientific procedures showing its safe for dogs to consume.
- Companies can create their own GRAS determinations if they can support their claim.
Using GRAS first condition is how the FDA has approved, and continued to approve 4D meat.
