By Dr. Bec Crawford, DVM CertAqV BSc (Hons)

I have often felt this weight; while speaking with a client about their beloved pet, while standing in a pet food or livestock feed store surrounded by a smorgasbord of options, while staring out at the open ocean wondering how many more sharks will be slaughtered for use in vaccines, pet foods and cosmetics. This weight drives me to continue lobbying for a restored world in which all species can thrive; for a world where sustainable sources are sought, required and printed on product labels of all kinds. This journey for a revitalized world began following the release of the documentary films Sharkwater in 2006 and Revolution in 2012. Fast forward to 2018 with the release of Sharkwater Extinction, Vetting The Pet Food Industry really started to take form. Since then, I’ve worked on this project from Canada to St. Kitts to Australia to California. Now as a veterinarian, it is my duty as a steward of animal, ecosystem and human health to continue vetting the pet food industry for the wild and to educate my clients seeking healthy, sustainable food options for their pets. Following our recent introduction to pet food and supplements, we’re diving deep into pet food labeling, production and regulation. There’s a lot going on here, so I’ve tried to break it down into digestible bites for us. Permission to get sharky.

CONSEQUENCES OF LABELING LOOPHOLES

One of the most well known historical tragedies resulting from a regulatory loophole occurred in 2007-08. Wheat flour mixed with melamine and a toxic flame retardant, cyanuric acid, was sold to animal feed suppliers in the United States disguised as wheat gluten. Melamine, a relatively nontoxic nitrogen rich compound used in fertilizers and plastics, passed the test for nitrogen level and went undetected as mislabeled wheat gluten. Following an investigation into acute and fatal kidney failure in many pets in 2007, cyanuric acid bound to melamine was identified in chicken feed, fish feed, livestock feed, pig feed and pet foods. In 2008, China and Korea prompted an investigation determining that melamine was utilized to falsify protein levels in human baby formula which similarly caused precipitation of urate crystals in the kidneys leading to fatalities of many infant children. 

LABELING, PRODUCTION AND REGULATION

As far back as 1938, the Food and Drug Administration (FDA) was to oversee the entire pet food industry, but they never have. Since 2007-08 with occurrence of the melamine:urate tragedies, there has been a push for this, but apparently the budget and man power are still not available to make this happen. Individual provincial and state departments of agriculture have control over which animal feeds are sold in their region if they choose to do so; some states are very lenient and do not look at pet foods at all whereas others are very strict. The United States Department of Agriculture (USDA) is involved in the inspection of plants and meats as ingredients in pet food and certifies the quality of meats.

The Association of American Feed Control Officials (AAFCO) regulates distribution and sale as well as labeling and production of animal foods, establishing cat and dog nutrient profiles and promoting uniform pet food regulations. Established in 1909, AAFCO has been a nonprofit private volunteer organization with one to two officials appointed per state. Volunteers must be state or government feed control officers in order to participate in AAFCO. Officers collectively publish and distribute model regulations for feed control; states can adapt them if they want to but are not obligated to. Currently 23 of the 50 states have adopted every single one of the model regulations printed in the most recent AAFCO text, whereas the remaining 27 states do what they want to do. However, pet food manufacturers do tend to follow all AAFCO regulations so that they are able to market their diet in every state.

LABEL REQUIREMENTS

Pet food labels are legal documents. Reading pet food labels is difficult but important with nutrients constituting water, vitamins, proteins, minerals, lipids and carbohydrates. Energy derived from carbohydrates, lipids and proteins should be presented with energy density as kcal per unit of volume to facilitate calorie counting for each individual pet based on their needs. All pet food and treat labels must provide a designator (species and/or age group for which the food is intended), energy content (metabolizable energy, ME), feeding directions, guaranteed analysis, identity (address, brand name, distributor, manufacturer name, packager name, universal product code), ingredient list, net weight and nutritional statement indicating adequacy, inadequacy or recommendation by veterinary prescription. For foods produced in North America, ingredients are listed in order by weight before the food is produced; in the European Union, ingredients are listed in order by weight in the finished product. Metabolizable energy is calculated or derived from feeding trials, and incorrect calculations will result in erroneously low ME reports; therefore in many cases, pet owners feed more food than needed based on the label, increasing risk of obesity. Principle display panels making claims such as lean, less, light/lite, low calorie/fat, reduced calorie/fat, should not contain more than ~3000 kcal metabolizable energy per kilogram.

MODIFIERS AND NUTRITION STATEMENTS

Modifiers are utilized to describe protein content and are very often misinterpreted. A label that claims chicken without a modifier must contain at least 70% chicken in the total product by weight when it is made. In contrast, chicken dinners, formulas, meals or platters contain 10% chicken for canned products and 25% chicken for dry products. Labels with chicken contain at least 3% chicken, and chicken flavor simply means it should be recognizable by the pet. When it comes to canned/tinned food items, moisture/water content is not to exceed 78% and if that maximum is exceeded, the label must include a modifier such as in aspic, in gravy or in sauce. 

Another labeling loophole comes with the splitting of ingredients, whereby for example, the first ingredient chicken meal is listed with 23% moisture because meat holds significant water weight, the second ingredient ground rice at <4% moisture, followed by rice bran as the third and rice flour as the fourth ingredient. If ground rice, rice bran and rice flour are added together, they weigh more than chicken meal as the first ingredient.

Nutrition statements are not regulated or required on pet food labels; examples are complete and nutritious, 100% complete and balanced, 100% nutritionally complete, 100% nutritious, and sufficient quantities of ingredients to meet nutrient requirements. There are also no regulations for foods that claim to be designed for spayed/neutered/desexed pets. 

Following AAFCO protocol, pet food companies utilize feeding trial methods to substantiate claims for “feeding tests performed in accordance with the procedures established by AAFCO.” Statements such as “passed feeding trial for all life stages or stressful stages of life” indicate that the food met nutrient requirements when fed to the pregnant and lactating female as well as her kittens/puppies. This confirms that the food contains adequately bioavailable nutrients for all life stages. However the results of maintenance feeding trials, especially those with small sample sizes, should be taken with a grain of salt. AAFCO maintenance feeding trials are conducted with a minimum of eight dogs over the course of >12 months, feeding one diet as the sole source of nutrition for a minimum of 26 weeks with a physical exam at beginning and end, weekly body weigh ins, and blood testing for albumin, hemoglobin, packed cell volume and serum alkaline phosphatase at the start and end of the trial. These trial requirements may be considered irresponsible, especially given the small minimum trial group size of eight animals; this is why most veterinarians recommend brands with more robust feeding trials such as Hill’s Science Diet, Just Food For Cats, Just Food For Dogs, Purina Pro Plan and Royal Canin.

NATURALLY ORGANIC?

At the end of the day, it is up to the State Department of Agriculture or another pet food company to sue other pet food companies for illegal claims and slogans such as all natural pet food or human grade pet food. Truly, nothing on the market is all natural; chelated minerals and synthetic amino acids and vitamins are often used in both human and pet foods. Per the USDA, natural ingredients are those derived solely from animal, mined or plant sources. All ingredients must meet this definition when it comes to natural pet food, and this is not synonymous with organic. When it comes to human grade ingredients, the manufacturer is free to interpret and use this term as it sees fit. There are no organic standards for pet foods, rather USDA organic labels indicate that the pet food company probably followed USDA regulations for human foods (95%+ organic). USDA organic standards (not AAFCO) imply that animals are not given antibiotics or growth hormones. These standards also dictate food grown without using most conventional pesticides, made without synthetic ingredients or sewage sludge, bioengineering or ionizing radiation, with processors and producers inspected and certified by the USDA.

NUTRITIONAL DISASTERS AND OBESITY

With over 5,000 pet food labels in the US, many commercial, farm, grocery and industrial brands tending toward bulk marketing, low cost and palatability with decreased digestibility and increased mineral content, many pet parents are opting for home cooked options. If you’re going home-made, please consult Balance IT to ensure consistent safety, precision and guidance in preparing food for your pet. Human prepared foods are deficient in the essential nutrients required by pets. For this reason, board certified veterinary nutritionists have developed amino acid, mineral and vitamin supplementation protocols for all 30 essential nutrients to ensure appropriate intake for pets on an individual basis. 

Nutritional disasters often result from home-made pet food containing excess protein and fat, deficient in vitamins, microminerals, EPA and calcium. The average content of calcium, phosphorus and fat soluble vitamins A and D in home prepared pet foods often far surpass the minimal daily recommended (MDR) intake for pets (Kallfelz, ACVIM Proceedings 1990). Over supplementation of calcium in Schnauzers and some other breeds known for calcium hyperabsorption predisposes them to calcium oxalate urolith formation in the urinary bladder. Other breeds that cannot absorb all of the calcium will complex it with zinc in the gastrointestinal tract and excrete the excess in feces, leading to zinc deficiency.

Diet drift occurs with excessive treat offerings. It is important to ensure treat replacement by diet percentage of less than 5%. It has been demonstrated that treat intake exceeding 5% of daily energy requirements causes deficiency in one or two nutrients, while treat based intake exceeding 15-20% causes 50-100% deficiency in most essential nutrients. Over 60% of cats and dogs today are overweight, thus controlling treat intake will promote a balanced diet and healthier lean body condition. When it comes to human foods and table scraps for example, one cubic centimeter of cheese for a 10lb cat has the caloric equivalent of three cheeseburgers for a human. Needless to say, few commercial treats are balanced and complete. It is important to know the nutrient content of treats in order to reduce risk of exacerbating disease and predisposing to obesity. A typical dog biscuit treat has an imbalanced calcium to phosphorus ratio of 0.15:1. A typical cat treat contains 1.7% phosphorus, and a typical dog jerky treat contains 6.9% sodium chloride; that’s twice the salinity of seawater. High phosphorus and salt levels in these treats are inappropriate, and should be avoided especially in patients with heart, kidney and liver disease or impairments.

YOUR PET PROJECT: COUNTING CALORIES

The resting energy requirement (RER) for canine and feline pets is calculated based on their ideal body weight as (kg^0.75)*70. This is a good estimate for kcal needed per day for basic metabolic function in an adult cat or dog at rest. The daily energy requirement (DER) is then calculated utilizing a maintenance factor variable dependent upon species, reproductive status, environment, age and activity level. DER will be determined and calculated by your veterinarian following examination of your pet’s body condition and assessment of your pet’s needs. It is very important to recognize that an eight ounce measuring cup holds eight fluid ounces by volume, not eight ounces by weight; this is especially important in the pet food world. For this reason it may be worth investing in a gram scale for at home use. 

Let’s work through an example together. My patient Finn ideally weighs 35 kilograms, and my client informs me that he’s an active dog that loves to play tug-o-war with his shark toy at the beach. His RER is (35^0.75)*70 equating 1007 kcal/day. Given that Finn is an active neutered male with appropriate lean muscling and in good body condition on physical exam, I selected an appropriate maintenance factor and calculated his DER at 1410 kcal/day. Finn eats Royal Canin large breed adult dry dog food at 360 kcal/cup. Finn loves his treats, and following our less than 5% kcal dietary treat replacement per day rule, the goal is that Finn’s treats would sum to a total of 60 kcal/day with 1.75 cups of kibble for breakfast (630 kcal) and 2 cups for dinner (720 kcal). On strenuous hiking days, it may be more appropriate for Finn to receive 2 cups of food for both meals.

As a generic rule in feeding commercial brand adult cat foods, the typical healthy 8-11lb house cat requires one quarter of one cup of dry food and one quarter of one 5.5oz tin of wet food two times daily. If you’re feeding more than this, you’re probably feeding too much, but each patient is unique. Please consult your veterinarian to determine your cat or dog’s daily energy requirement based on their ideal body weight with the goal to use a dry measure cup and/or gram scale to meet your pet’s kcal per day needs. Targeting their daily nutritional needs will decrease osteoarthritis, obesity and metabolic disease risks, including diabetes, as your pet ages. If your pet needs to lose weight, your veterinarian will recommend baseline lab work to rule out underlying medical issues and may prescribe a prescription weight loss diet, as food formulations and product quality clearly varies. The American College of Veterinary Nutrition (ACVN) and World Small Animal Veterinary Association (WSAVA) are world leaders in pet nutrition, with Global Nutrition Guidelines readily available. Veterinary medical formulated foods are produced for treatment and prevention purposes such as weight loss; these therapeutic prescription diets include Royal Canin Veterinary Diet, Purina Pro Plan Veterinary Diet, Just Food For Dogs, Hill’s Prescription Diet and Eukanuba Veterinary Diet.

Actionable Items

• Avoid coconut oil in your pet’s diet; it does not contain essential fatty acids.

• Consult your veterinarian to determine your cat or dog’s daily energy requirement based on their ideal body weight.

• Ensure treat replacement of less than 5% of the total daily food intake for your pet.

• Read your pet’s food label closely. How many grams/cup? How many kcal/gram? How many kcal/cup? Use this information to help you measure your pet’s daily intake with a gram scale and/or measuring cup.