Learning never exhausts the mind.

More information on frozen raw food

After reading through the ingredients lists of 11 "chicken" frozen raw food products in an earlier post this week, it prompted me to ask: What are the guidelines or regulations, if any, for raw dog food? Warning: The info below is gag-inducing because it discusses animal feed, raw meat sources, pathogens and other creepy-crawly things, etc.

A quick Google search led me to a document entitled "Guidance For Industry:  Manufacture and Labeling of Raw Meat Foods for Companion and Captive Non-Companion Carnivores and Omnivores" by the Food and Drug Administration (FDA) Office of Surveillance and Compliance in the Center for Veterinary Medicine. It is 14 pages long and each page is stamped with the words "Contains Non-Binding Recommendations." Below are excerpts from the document specific to ingredients that I find interesting, eye-opening...hope you do too!

• "All meat- and poultry-derived ingredients should be United States Department of Agriculture (USDA)/Food Safety and Inspection Service (FSIS)-inspected and passed for human consumption." (page 5)

• "We recommend that bones and other hard materials be ground" (page 5) [to mitigate any risks of dental or gastrointestinal trauma] (page 9).

• "All other ingredients should be suitable for use in animal feeds; that is, the ingredients should be of an appropriate grade that qualified experts [by scientific training and experience to evaluate the safety of substances directly or indirectly added to food] would agree they are safe for use in raw food for animals. " (page 5)

• "There are generally three sources of animal tissues for raw meat foods for animals: meat obtained directly from human-food processing facilities; meat from animals that have died by means other than slaughter; and meat originally offered, but no longer suitable, for human consumption.  All raw tissues, even those inspected by the USDA and judged acceptable for sale to people for their consumption after proper cooking, pose a risk of being contaminated with pathogenic organisms and USDA requires safe handling instructions on raw meat products intended for human consumption (9 CFR 317.2(l)(3) and 9 CFR 381.125)."  (page 9)

• "However, raw tissues obtained from mammals or poultry that have died other than from slaughter pose significantly increased risk of contamination with pathogenic organisms.  Even when collected from a USDA-inspected slaughter facility, tissues that are typically not offered for human consumption, but instead are permitted for use in animal feed, may not be subjected to the same rigorous inspection needed to minimize the risk of contamination and disease transmission.  Likewise, tissues that originally passed USDA inspection for human consumption, but that were later diverted for use in animal feeds, pose a risk for increased numbers of bacterial organisms, some of which may be pathogenic.  To minimize risk, we recommend that only sources of animal tissue ingredients that come from a USDA-inspected facility and have passed USDA inspection for human consumption should be used for manufacturing foods that contain raw meat, or other raw animal tissues, for consumption by dogs, cats, other companion or pet animals, and captive noncompanion animal carnivores and omnivores." (page 9)

• "Manufacturers of raw meat foods for animals should take all measures necessary to prevent adulteration.  Measures that would help minimize contamination by pathogenic microorganisms and prevent the growth of pathogens could include irradiating the product after final packaging as provided for in 21 CFR Part 579, participation in the USDA’s voluntary inspection program (9 CFR Part 355), and practicing GMP’s such as those for human foods in 21 CFR Part 110.  Development and implementation of a HACCP program would be an effective and rational means of fostering food safety through hazard identification and preventive controls.  The desired outcome is to reduce the risk of microbial contamination or other adulteration for raw animal feed products." (page 9-10)

Bottom Line:  If a company or manufacturer did its homework, it would have considered all or some of these guidelines, which I think are rational and reasonable. Information in bullets #1 and #4 were the most thought provoking. Helps me understand why companies may put a lot of emphasis on the terms USDA-inspected or human-grade and that they are actual, allowable terms (so long as they can be substantiated). The document also discusses: food-borne pathogens and food contamination in the context of human health and safety; the long-term history and practice of raw feeding in zoo-settings; labeling requirements; and nutritional adequacy and deficiency of a raw diet. Worth a read (or download for later use). Information is power!

Resources
"Guidance For Industry:  Manufacture and Labeling of Raw Meat Foods for Companion and Captive Non-Companion Carnivores and Omnivores" - FDA Office of Surveillance and Compliance in the Center for Veterinary Medicine. Additional copies of this guidance document may be requested from the Communications Staff (HFV-12), Center for Veterinary Medicine, FDA, 7500 Standish Place, Rockville, MD  20855 and may be viewed on the FDA website.