Omit This Single Word, and Your Odds of Quality Food Vanishes

human grade pet food

Story at-a-glance -

  • The Association of American Feed Control Officials (AAFCO) is in the process of trying to define some of the label claims pet food companies are making or want to make about their products
  • One of those claims is “human-grade,” which is currently unofficially defined as human edible, with 100 percent human edible ingredients produced in a human food manufacturing facility under USDA inspection
  • A pet food industry insider has proposed a change to the definition to remove the term “edible,” which will in effect make the human-grade claim untrustworthy and ultimately invalid
  • If you want to see human-grade pet food be reliably and truly human edible, you can make your voice heard to members of AAFCO’s Pet Food Committee

By Dr. Karen Shaw Becker

The Association of American Feed Control Officials (AAFCO) is in the process of trying to define some relatively new claims pet food manufacturers are using with increasing frequency, such as "organic" and "natural", and the especially thorny "human-grade" declaration.

If you're unfamiliar with the terms "feed-grade" and "human-grade" with regard to pet food, watch this short and easy-to-understand video from my friend Susan Thixton, a pet food consumer advocate and owner of TruthAboutPetFood.com:

How 'Human-Grade' Is Currently Defined by AAFCO

The AAFCO "Guideline for Human-Grade Claims" was passed in 2016, and appears in the 2017 AAFCO Official Publication. From AAFCO.org:

"This term has no definition in any animal feed regulations. Extremely few pet food products could be considered officially human edible or human-grade. A pet food that actually met these standards would be expensive. While pet owners can buy what they feel is best for their pet, they should understand the definitions and the odds.

The U.S. Department of Agriculture (USDA) defines products fit for human consumption to be officially 'edible.' These foodstuffs have been processed, inspected and passed manufacturing regulations (i.e. process control regulations) that are designed to assure safety for consumption by humans.

Edible is a standard; human-grade is not. For a product to be deemed edible for humans, all ingredients must be human edible and the product must be manufactured, packed and held in accordance with federal regulations in 21 CFR 110, Current Good Manufacturing Practice in Manufacturing, Packing, or Holding Human Food.

If these conditions are met for a pet food, human-grade claims may be made. If these conditions are not met, then it is an unqualified claim and misbrands the product. Misbranding a feed is a prohibited act subject to enforcement action on the responsible party. The presence of human-grade on a label implies a product or ingredients may meet the legally-recognized edible standard."1

Also, on their Labeling & Labeling Requirements FAQ page, AAFCO explains:

"When one or more human edible ingredients are mixed with one or more non-human edible ingredients, the edible ingredients become non-human edible. To claim that a product composed of USDA inspected and passed chicken, plus poultry meal, which is not human edible, plus other ingredients is made with human-grade chicken is misleading without additional qualification and disclaimers in the claim because the chicken is no longer edible."2

Bottom line: In order for a pet food company to make the claim that a product is "human-grade," it must contain 100 percent human-grade (human edible) ingredients, and be 100 percent produced/handled/stored at and shipped from a facility that manufactures only human edible foods.

Human-grade pet food, based on this definition, would be completely safe (though biologically inappropriate) for humans to eat, which non-human grade pet food (technically pet feed) is not.

A Proposed Change to the 'Human-Grade' Definition Opens an Unacceptable Loophole for Pet Food Manufacturers

I think all of us who are concerned with the quality of our pet's food can agree that human-grade diets, as described above, would be ideal (setting aside the cost).

Unfortunately, a pet food industry insider has thrown a monkey wrench into the works by suggesting a change to the definition of human-grade.3 His argument seems to be that because the FDA, not the USDA, regulates pet food, and the FDA doesn't recognize the term "edible," it should be removed from the definition of human-grade pet food. However, the USDA does recognize the term "edible" — an important distinction.

"USDA requires a food that contains more than 3 [percent] meat to be 'edible' and manufactured under inspection," explains Susan. "If the term 'edible' is removed from the definition of Human Grade pet food, the link to USDA is removed, the requirement to be manufactured under inspection is removed. If the term 'edible' is removed, consumers lose."4

Bottom line: Removing the "edible" requirement from the definition means pet foods claiming to be human-grade may or may not be. I'm not here to judge the intentions of the industry insider who proposed the change, but it appears removing the "edible" requirement creates a loophole big enough for pet food manufacturers to drive a truck through.

"This means that anyone can slap the words 'human grade' on their labeling without having that claim stand up to an inspection," writes Dr. Cathy Alinovi of Next Generation Pet Food Manufacturers Association, to her membership. "Ultimately, this takes away YOUR best efforts (of actually providing EDIBLE human grade food products for pets) of NO marketable advantage because it will be able to be used by anyone.

This is similar to reducing the 'human grade' term to what the term 'natural' has become, which is untrustworthy and without true advantage."5

If You Want Human-Grade Pet Food To Be Truly Human-Grade, Let Your Voice Be Heard

This year's annual AAFCO meeting was held at the end of July, and the proposed change to the definition of human-grade came up for discussion. From the meeting notes: "There is a large amount of confusion and concern from consumers regarding the proposed change."6

As a result of the proposed change and ensuing confusion, a Human Grade Pet Food Validation workgroup was formed with a mission to identify opportunities for the FDA and USDA to partner together "for the purpose of validating human grade pet food claims in products that span both agencies jurisdiction."

If you're interested in having your voice heard on this issue by AAFCO, Susan has provided a list of AAFCO Pet Food Committee voting members and their contact information here under the section "What can you do?" She also provides a copy of the letter she sent for your use.