The United States Department of Agriculture (USDA) has jurisdiction over the production of meat, poultry and egg products – this includes slaughter facilities. A USDA representative is onsite during hours of operation in all slaughter facilities, and food production facilities (foods that contain greater than 2% cooked meat and foods that contain greater than 3% raw meat). The Food and Drug Administration (FDA) has jurisdiction over all food products that contain lower than 2% cooked meat and lower than 3% raw meat. The FDA isn’t onsite during hours of operation in any food production facility.
One would think that because pet foods contain greater than 2% cooked meat, they might be regulated by USDA…but, that isn’t the case. For undisclosed reasons, the FDA has jurisdiction over pet food – each manufacturing and distribution.
The one pet food exception is human grade pet foods that are manufactured per human food standards (in a USDA licensed manufacturing facility). These pet foods are under USDA jurisdiction during manufacturing, but return to FDA jurisdiction once they are sitting on store shelves. All other pet foods are under FDA jurisdiction during manufacturing and distribution.
Every three months the USDA releases statistics to the general public regarding the variety of animals slaughtered for meat consumption, and significant to pet food consumers the agency releases statistics of condemned animals (animals the USDA deemed unsafe for consumption).
The USDA statistics for the primary three months of 2024 are:
The “Livestock Carcasses Condemned” total is 51,142 animals (mainly cattle and hogs). The “Poultry Carcasses Condemned” is 1,961,040 animals (mainly chicken and turkey).
If we estimate a median weight of livestock animals at 300 lbs each, and estimate the common weight of poultry animals to be 8 lbs each – the entire kilos of USDA condemned animals in the primary three months of 2024 is 31,030,920 lbs.
Once this material is condemned, it isn’t any longer inside USDA jurisdiction. The USDA has no authority to come to a decision where these condemned animals go – so long as it isn’t inside their jurisdiction (foods – except feed grade pet foods – that contain greater than 2% meat).
Enter FDA jurisdiction.
Completely opposite of USDA, the FDA welcomes these 31 million kilos of condemned animals into pet food. The FDA position on condemned animals in pet food is (quote from Dr. Steven Solomon director of FDA Center for Veterinary Medicine in April of 2019): “we do not believe that the use of diseased animals or animals that died otherwise than by slaughter to make animal food poses a safety concern and we intend to continue to exercise enforcement discretion.”
The regulatory authority on meat/poultry safety (USDA) believes these 31 million kilos of animals weren’t protected for consumption. But in one other jurisdiction (FDA) – which has no experience at meat/poultry safety – has decided these 31 million kilos of condemned animals don’t ‘pose a safety concern’ to the animals consuming them.
By the way in which, the USDA used to supply a “certified pet food” program. Unlike the FDA, the USDA required all pet food meats to be sourced from USDA inspected and passed animals. Meats sourced from condemned animals was not allowed.
And by the way in which, the FDA not only allows diseased animals and non-slaughtered decomposing animals to be processed into pet food…in addition they refuse to require pet food manufacturers to reveal these ingredients on pet food labels.
Pet owners usually are not informed if their pet’s food comprises meats sourced from diseased or condemned animals. Pet food manufacturers (that utilize this quality of ingredients) are allowed to benefit from selling undisclosed condemned animal material. We submitted an official request to FDA (Citizen Petition) in July 2022 evidencing the legal requirement for disclosing this information to pet food consumers. FDA was required by law to offer us a response inside 120 days. However FDA has ignored this deadline, almost two years later we proceed to attend for FDA’s decision.
Wishing you and your pet(s) the perfect,
Susan Thixton
Pet Food Safety Advocate
Author Buyer Beware, Co-Author Dinner PAWsible
TruthaboutPetFood.com
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