(some) Pet Food is Dumping Ground for Fda's 'specified Risk Materials'

While imported ingredients remain high on the awareness of pet owners across the US and Canada, there is something right here in the US that few are aware of and poses a similar threat to our pets. The FDA terms the ingredients SRM’s – specified risk materials. SRM’s are a common pet food ingredient that is little more than waste from the human meat industry. The name alone – Specified Risk Materials – explains the concern.

To start, you should understand that the pet food industry began by doing about the same thing that pet owners used to do…feeding their dogs and cats leftovers from family meals. Corporations saw the opportunity with leftover ingredients from the manufacturing and processing of human food and commercial pet food was born. While leftovers from your family dinner doesn’t sound too harmful for pets – leftovers from the commercial side can be quite different. Interestingly enough, back in the 1960’s the pet food industry initiated a nationwide campaign warning pet owners of the ‘dangers’ in feeding your dog or cat leftovers – yet they themselves did and continue to do the very same on a commercial level.

A common concern discussed by those in the know about pet food is known as the 4-D ingredients. The 4-D’s are dead, diseased, drugged, and downed meat producing animals. These 4-D animals are rejected for use in human food for apparent reasons. Common sense would cause one to assume the animals are destroyed, but that is not the case. 4-D animals are processed for use in pet food and are one part of the FDA’s Specified Risk Materials.

Another concern of SRM’s comes from a more modern day risk of mad cow disease – BSE - Bovine Spongiform Encephalopathy. The FDA’s definition of BSE is “Bovine spongiform encephalopathy (BSE) is a chronic, degenerative disorder affecting the central nervous system of cattle.” For more information, visit the FDA’s web page on BSE at http://www.fda.gov/oc/opacom/hottopics/bse.html. To give the FDA credit, they have stepped up control a great deal in recent years and does not allow SRM’s to be introduced into the human food chain by prohibiting any possible SRM’s into the feed of cattle, sheep, or pigs – ruminant animals. But these SRM’s are allowed in pet foods. BSE or mad cow disease has crossed species to cats in Europe, mink worldwide, and deer and elk in the US. (For more information on BSE visit http://w3.aces.uiuc.edu/AnSci/BSE/ ) I’m the first to admit that the risk of mad cow disease entering the pet population of the US is a long shot, but it remains a risk of concern. 

To provide you with some startling numbers explaining just how much Specified Risk Material is processed, I will quote a letter from Garth Merrick to the FDA…”Federal Measures To Mitigate BSE Risks: Considerations for Further Action”….( full letter available here: https://web01.aphis.usda.gov/regpublic.nsf/168556f5aa7a82ba85256ed00044eb
1f/b5773ca9a76035d487256edf00540410/Body/M2?OpenElement )

“SRM’s in cattle under 30 months of age have been estimated to be 20 pounds per head. In Texas there are four packing houses processing approximately 100,000 head per week times 20 pounds equals 2,000,000 times 52 weeks equals 104,000,000 of product that no one has discussed what to do with. Also, in Texas, there are approximately 18,000 head of cows over 30 months of age slaughtered weekly at four packing plants which have approximately 60 pounds per head of SRM material equals 1,080,000 per week equals 56,160,000 pounds per year. Our company services mostly Texas and parts of New Mexico, Oklahoma and Kansas. Last year we processed 255,000 head of dead stock not counting calves with an average weight of 600 pounds per carcass. The total weight comes to 153,000.000 pounds that makes its way into feed ingredients.”

The 4-D material discussed above – from one company – processed 153 million pounds of dead cattle in one year. I repeat – 153 million pounds of processed dead cattle in one year from one company! There is no testing to determine the reason the animal died – causes could run from old age to disease. We just don’t know. The current FDA and AAFCO regulations allow dead (4-D) animals to be processed into pet food. They are not allowed to be processed into the human food chain either directly or in-directly (through use in cattle or pig feed). The other 104 million and 56 million pounds of SRM’s processed by this one company in one year is also allowed into pet food but not allowed to be processed into human food directly or in-directly. The current FDA ruling on the processing of SRM’s - effective 1/9/07 - does not protect pet food. http://www.fda.gov/OHRMS/DOCKETS/98fr/E6-16830.htm

Mr. Merricks letter to the FDA does bring up a valid point in that what should the processors of meat do with these millions and millions of pounds of SRM’s? I don’t have an answer to that question. But I can tell you that I don’t want SRM’s in my pet’s food bowl. It’s not my responsibility to find a selling point for SRM’s.

Besides pet owners that are aware of SRM’s in pet food and a handful of knowledgeable veterinarians, there are some national organizations that feel SRM’s should be eliminated from pet food as well. From a December 2005 letter from the American Farm Bureau Federation to the FDA… (http://google2.fda.gov/search?client=FDA&site=FDA&lr=&proxystyles
heet=FDA&output=xml_no_dtd&getfields=*&q=what+is+4D+animals
+in+pet+food&as=GO ) …
“Our members recognize the importance of and strongly support the ruminant-to-ruminant feed ban that went into effect in August 1997. Given what is currently known about the epidemiology and characteristically long incubation period of BSE, we agree that it is appropriate for the Food and Drug Administration (FDA) to implement additional measures which will minimize the risk of BSE recycling in the U.S. cattle herd. Specifically, we support extending to all livestock, poultry and pet feed the current ruminant ban on brain and spinal cord material from bovines 30 months of age and older.”

If the FDA doesn’t extend the ban of SRM’s to include pet food, at the very least the pet food label should state their presence in the food. Currently you won’t find SRM listed on any dog food or cat food label. Pet food manufacturers weren’t born yesterday. I doubt that many sales would occur from the words Specified Risk Materials listed on a dog food or cat food label. SRM’s come in the pet food ingredients by-products (meat by-products, chicken by-products, by-product meal, and so on). Unless you are comfortable with your pet eating a specified risk material – I’d suggest you avoid feeding any pet food or pet treat with by-products listed in the ingredients!

SRM’s in pet food is frightening to consider. One estimate of the economic impact of destroying SRM’s instead of recycling SRM’s into pet food has been estimated to cost $15 million dollars a year. Considering the 56.4 million pet owning U.S. households spend over $40 billion dollars a year on their pets, I say it is money well spent.

Wishing you and your pet the best,

Susan Thixton