August 25, 2010
A number of pet food companies make claims that their products are ‘human quality’ or ‘table grade’, but these are not actually legally defined terms and only a product that is actually produced in a plant that produces human foods, may legally be labeled ‘human grade’.
Pet owners should also beware of pet food manufacturers that that use ‘human grade’ (or related terms) liberally on their web sites and other marketing materials – but don’t actually state it on the bag. Short-staffed and under-funded labeling inspectors generally only have time to investigate claims made on packaging and don’t usually review the online and printed marketing pitch when they investigate (or license) a product.
Human-Grade or Food-Grade refers to the quality of a finished product. The term applies to a product that is legally suitable and approved for consumption by a person (“edible”).
Feed-Grade applies to a product that is not suitable for consumption by people and is only legally allowed to be fed to animals (“inedible”) because of the ingredients it contains or the way it (or its ingredients) have been processed.
Various ingredients used in many poor-quality pet foods are not fit for human consumption at all, and may include by-products, chemicals, fillers and parts from ’4D’ meats (animals which are dying, diseased, disabled or deceased). These ingredients do not have ‘edible’ because they are produced in a manner that makes them unfit for human consumption or are otherwise contaminated and unsafe for people to consume.
A good example is rendered meat. Meat rendering plants are defined by the Environmental Protection Agency (EPA) as,“Meat rendering plants process animal by-product materials for the production of tallow, grease, and high-protein meat and bone meal….. Independent plants 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.”
The term “Made with Human-Grade Ingredients” does not mean that a finished product is actually, legally, human grade either. An ingredient (let’s say, a carrot) may start off being fit for human consumption, but once that carrot has been shipped to a pet food plant and processed in accordance with regulations for feed-grade products, the ‘human-grade’ term can no longer legally be used. By definition, that carrot is now feed-grade.
Human food is produced in accordance with the FDA (Food and Drug Administration) Code of Federal regulations (CFR)Title 21. The CFR is a very in-depth document that defines how human food production should take place, and under what conditions.
The FDA is currently working on legislation for the regulation of pet food, and its web site defines this as follows: “There is no requirement that pet food products have pre-market approval by the FDA. However, FDA ensures that the ingredients used in pet food are safe and have an appropriate function in the pet food. Many ingredients such as meat, poultry and grains are considered safe and do not require pre-market approval. Other substances such as sources of minerals, vitamins or other nutrients, flavorings and preservatives, or processing aids may be generally recognized as safe (GRAS) for their intended use (See Title 21 CFR 582 and 584) or must have approval as food additives…”
The FDA’s Federal Food, Drug, and Cosmetic Act (FFDCA) requires that pet foods, like human foods, be safe to eat, produced under sanitary conditions, contain no harmful substances, and be truthfully labeled.
AAFCO, the Association of American Feed Control Officials, is a corporation whose purpose is to provide a mechanism for establishing and maintaining equitable laws, regulations and definitions and enforcement policies for regulating the manufacture, labeling, distribution and sale of animal feeds. Many states follow the regulations established by AAFCO, though each state can have its own regulations and feed control laws.
How does human food production actually differ from pet food production?
The following table provides abbreviated excerpts from the AAFCO regulations for feed production (AAFCO Official Publication 2010) and the FDA’s CFR Title 21 for human food production. The table outlines some of the contrasts between the regulations for (food grade) human food and (feed grade) pet food. For a more detailed comparison of the two sets of regulations in PDF format, click here.
|Pet Food (AAFCO Model Good Manufacturing Practice regulations)||Human Food (FDA CFR Title 21)|
(2) regulations, including:
Conform to good hygienic practices to minimize risk of adulteration
Be trained for the area of responsibility
(13) regulations, including:
Personnel excluded from operation if signs of illness, lesions etc.
Conform to hygienic practices including suitable garments, personal cleanliness, hand washing, removing unsecured jewelry, maintaining gloves in sanitary condition, wearing hairnets, beard covers and other hair restraints, eating & drinking in designated areas (outside production areas), taking precautions to protect against contamination with cosmetics, medicines etc, appropriate training in proper food handling techniques and food-protection principles.
(6) regulations, including
Must be of a size, construction and design to facilitate routine maintenance and cleaning.
The grounds maintained in a condition that minimizes pest infestation of feed and / or feed ingredients.
Kept in sufficient repair and condition to minimize risk of adulteration. Cleaned in a manner that minimizes risk of adulteration. Procedures that are effective in minimizing pest infestation.
Chemicals, lubricants, pesticides, fertilizers and cleaning compounds. Substances not approved for use in feed – received, stored and used in a manner that minimizes the risk of adulteration, and in accordance with applicable laws.
|PLANT & GROUNDS, SANITARY OPERATIONS
(40) regulations, including:
Plant kept in condition that will protect against the contamination of food.
Properly storing equipment, removing litter and waste, and cutting weeds or grass
Maintaining roads, yards, and parking lots. Adequately draining areas . Operating systems for waste treatment and disposal
Plant buildings and structures shall be suitable in size, construction, and design to facilitate maintenance and sanitary operations for food-manufacturing purposes: Provide sufficient space for such placement of equipment and storage of materials for sanitary operations and the production of safe food, reduce the potential for contamination of food.
Proper precautions to protect food in outdoor bulk fermentation vessels by any effective means, including: protective coverings.
Floors, walls, and ceilings kept clean and kept in good repair; aisles provided between equipment and walls of adequate width to permit employees to perform their duties and to protect against contaminating food
Adequate lighting, adequate ventilation, adequate screening or other protection against pests.
Adequate sanitary facilities and accommodations including, adequate water supply, plumbing, sewage conveyance, floor drainage and toilet facilities.
Maintaining the facilities in a sanitary condition & in good repair at all times. Providing self-closing doors.
Hand-washing facilities, fixtures, such as water control valves, to protect against recontamination of clean, sanitized hands.
Adequate rubbish and waste disposal
(7) regulations including:
Feed and / or feed ingredients considered adulterated shall not be used unless first made safe
Minimizing the risk of adulteration and ensuring safety and identity.
Description of the manufacturing operation such as formulation, mixing and production practices.
Measures to minimize manufacturing errors, cleanout practices, which may include sequencing, flushing or other methods.
Measures to minimize inclusion of physical adulterants, including metal.
Records document the production history maintained for at least one year from the date of disposition.
|PROCESSES & CONTROLS
(47) regulations, including:
Appropriate quality control operations shall be employed to ensure that food is suitable for human consumption and that food-packaging materials are safe and suitable, sanitation. Chemical, microbial, or extraneous-material testing procedures shall be used where necessary to identify sanitation failures or possible food contamination.
Raw materials and other ingredients inspected and segregated, washed or cleaned as necessary to remove soil or other contamination. Water used for washing, rinsing, or conveying food – safe & sanitary.
(5) Raw materials, other ingredients, and rework shall be held in bulk, or in containers designed and constructed so as to protect against contamination & prevent adulteration
Liquid or dry raw materials and other ingredients received and stored in bulk form shall be held in a manner that protects against contamination.
Equipment and utensils & containers maintained in an acceptable condition
Conditions and controls necessary to minimize the potential for the growth of microorganisms, or contamination of food, careful monitoring of physical factors such as time, temperature, humidity, aw, pH, pressure, flow rate, and manufacturing operations such as freezing, dehydration, heat processing, acidification, and refrigeration to ensure factors do not contribute to the decomposition or contamination of food.
Effective measures to protect finished food from contamination by raw materials, other ingredients, or refuse.
Equipment, containers, and utensils used to convey, hold, or store raw materials, work-in-process, rework, or food shall be constructed, handled, and maintained to protect against contamination.
Effective measures to protect against inclusion of metal or other extraneous material in food: sieves, traps, magnets, electronic metal detectors, or other suitable effective means.
Washing, peeling, trimming, cutting, sorting and inspecting, drying, performed to protect food against contamination.
Using ingredients free of contamination.
Filling, assembling, packaging to protect against contamination.
Adequate cleaning and sanitizing of all food-contact surfaces and food containers, physical protection from contamination, sanitary handling procedures.
Food such as dry mixes & dehydrated food processed to and maintained at a safe moisture level.
AAFCO Feed Definitions:
Adulteration means the presence of any poisonous or deleterious substance at a level that may render the feed and / or feed ingredient injurious to human or animal health.
Establishment includes, but is not limited to, buildings structures, facilities, equipment and conveyances that receive, store, manufacture, process, package, label, transport or distribute feed and / or feed ingredients.
Pest means any objectionable animal including but not limited to bats, birds, rodents, insects and insect larvae.
In addition to the above model regulations for feed manufacturing, AAFCO places a major emphasis on feed definitions and terms, label format, brand and product names, expression of guarantees, ingredient definitions and terms, nutritional adequacy and other details which pertain to a pet food label.
Pet food labeling is regulated at two levels. The current FDA regulations require proper identification of the product, net quantity statement, name and place of business of the manufacturer or distributor, and a proper listing of all the ingredients in the product in order from most to least, based on weight.
When shopping the pet food aisle, look for a brand that is marked as being produced in a human food factory under FDA or USDA inspection. If in doubt, call your pet food manufacturer and ask them what sort of facility produces their products, and what inspections that facility undergoes.
© 2013 Lucy Postins & The Honest Kitchen This article may only be copied with prior written permission from the company. Reproductions must include credit to the author and a link to this website.