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 more than 2% cooked meat and foods that contain more than 3% raw meat). The Food and Drug Administration (FDA) has jurisdiction over all food products that contain less than 2% cooked meat and less than 3% raw meat. The FDA is not onsite during hours of operation in any food production facility.
One would think that because pet foods contain more than 2% cooked meat, they would be regulated by USDA…but, that is not the case. For undisclosed reasons, the FDA has jurisdiction over pet food – both manufacturing and distribution.
The one pet food exception is human grade pet foods which are manufactured per human food standards (in a USDA licensed manufacturing facility). These pet foods are under USDA jurisdiction during manufacturing, but go back to FDA jurisdiction when 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 public regarding the number 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 first 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 an average weight of livestock animals at 300 lbs each, and estimate the average weight of poultry animals to be 8 lbs each – the total pounds of USDA condemned animals in the first three months of 2024 is 31,030,920 lbs.
Once this material is condemned, it is no longer within USDA jurisdiction. The USDA has no authority to decide where these condemned animals go – as long as it is not within their jurisdiction (foods – except feed grade pet foods – that contain more than 2% meat).
Enter FDA jurisdiction.
Completely opposite of USDA, the FDA welcomes these 31 million pounds 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 pounds of animals were not safe for consumption. But in another jurisdiction (FDA) – which has no experience at meat/poultry safety – has decided these 31 million pounds of condemned animals do not ‘pose a safety concern’ to the animals consuming them.
By the way, the USDA used to offer 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, the FDA not only allows diseased animals and non-slaughtered decomposing animals to be processed into pet food…they also refuse to require pet food manufacturers to disclose these ingredients on pet food labels.
Pet owners are not informed if their pet’s food contains meats sourced from diseased or condemned animals. Pet food manufacturers (that utilize this quality of ingredients) are allowed to profit 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 provide us a response within 120 days. However FDA has ignored this deadline, almost two years later we continue to wait for FDA’s decision.
Wishing you and your pet(s) the best,
Susan ThixtonPet Food Safety AdvocateAuthor Buyer Beware, Co-Author Dinner PAWsibleTruthaboutPetFood.comAssociation for Truth in Pet Food
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