By Michele Taylor
A few years ago, I looked after my neighbor’s dog for a week. Supporting the Chow’s arthritic hips, I helped him hobble down the back door steps a few times a day. To encourage him to eat, I sprinkled my dogs’ favorite chicken jerky treats into his food. Contrary to what my neighbor told me about his eating habits, he licked the bowl clean.
Feeling sorry for the old boy, I bought him several packets of premium “cage free, NO hormones, NO antibiotics, NO fillers, NO byproducts, Helps Maintain Healthy Joints” labeled chicken breast strips. He quickly developed a half-pack-a-day habit. A month or so later, he died of kidney failure. Several years later, cancer killed my own dog, who insisted on bedtime chicken jerky treats every night for eight years.
About one month ago, the same neighbor sent me an email with the web address of the FDA’s warnings about chicken jerky pet food imported from China. Its website states, “The FDA continues to caution consumers of a potential association between the development of illness in dogs and the consumption of chicken jerky products also described as chicken tenders, strips or treats… If you choose to feed your dog chicken jerky products, watch the dog closely...” The agency lists kidney failure and death as potential risks to jerky-eating dogs.
I pulled my packet out of the cupboard and read the fine print. “Made in China.” There was a line of lawyer-speak. “For the safety of your pet, observation is recommended when giving your dogs treats or chews.” The packet also listed a website and a phone number. I punched the URL into my computer. My cursor went straight to the FAQ section. I scrolled down to the “Is your product USDA inspected?” line and read the answer. “We have USDA permits and we have permits in every state in the U.S.” When I called the company to ask exactly what kind of permits it had, the receptionist said, “Um, factory-standard permits?” When I asked if the FDA inspected the company’s Chinese slaughterhouses and dog food factories, I received an “I’ll get someone to call you back,” response.
I asked Nancy Cook, the Vice President of Technology and Regulatory Affairs at the Pet Food Institute—a D.C.-based trade association that represents 98 percent of U.S.-produced pet food--about the company’s USDA permit claims. “It probably has an import permit,” she says. “Import permits do not mean anything about product safety,” she notes that they speak to the export country’s animal health and disease status. Cook says that if she had a dog, she would never give it Chinese-manufactured food or treats. “The FDA has no idea what’s causing the problem of dogs eating chicken jerky,” she says.
Pet food safety inspections are generally carried out at the state level. But the FDA stepped in after widespread reports of dogs becoming sick after eating chicken jerky. “The FDA responds well to consumer concerns,” Cook says. “That’s why they’ve posted their warnings.”
Neither the FDA nor the USDA’s Food Safety Inspection Service inspect Chinese slaughterhouses or dog food factories. It’s not surprising that Emily Brown Rosen, the policy director at Pennsylvania Certified Organic, is dubious about my chicken jerky’s “NO hormones, NO antibiotics, NO fillers, NO byproducts” label. When it comes to Chinese pet food and packaging, “there are unregulated claims,” she says. “There’s no oversight, no third-party certification and very little monitoring.”
For pet food products sold in the U.S., federal and state laws control content and labeling. The USDA National Organic Program is involved in the enforcement of pet food products only when the product label displays claim to USDA organic certification. The NOP has clarified that while the Organic Foods Production Act provides coverage for pet food products, standards have not been developed therefore they fall outside the scope of the NOP. In other words they do not have regulatory authority over pet food companies using the term ‘organic’ on their products, unless they use the USDA organic seal or some other organic certification mark. They have further clarified that while pet foods products are outside of their authority, operators can voluntarily certifiy their pet food products as long as they meet existing USDA organic standards.
Oregon Tilth’s Processing Program Reviewer and Technical Specialist Gwendolyn Wyard says her organization is currently certifying organic pet food to the NOP human food standards until the NOP establishes standards specifically for pet food.
Both Cook and Rosen are working toward this goal. They are part of the National Organic Standards Board’s Pet Food Task Force, which recommended organic pet food labeling regulations to the NOP in November 2008. The NOSB’s pet food mission started in 2004, when it both acknowledged that the NOP lacked regulatory authority over pet food and recommended the formation of a 12-person task force to establish enforceable, industry-wide regulations. After reviewing organic standards already in place for humans and livestock, the task force recognized that neither would work for pet food.
Organic regulations prohibit mammalian products in organic livestock feeds. Organic regulations for human foods prohibit natural additives that livestock regulations allow. Rosen says that both rules are problematic when it comes to cat and dog food. Both species must have meat—prohibited by livestock regulations--and certain amino acids—prohibited by human regulations—to thrive.
In 2006, the NOP drafted a proposal to set organic pet food standards somewhere in the middle of livestock and human ones. Obeying livestock rules, pet food could include essential feed ingredients, such as the amino acid taurine, as well as slaughter by-products. In accordance with human standards, pet food labeled “made with organic ingredients” must contain a minimum of 70 percent organic ingredients. An “organic” claim must reflect a 95 percent organic content.
After two years of collaboration between the task force and the NOSB handling committee, formal labeling recommendations to the NOP were made. The task force put pet food under the livestock section of organic rules, allowing them to contain non-organic meat or meat products and essential feed ingredients. However, labels would conform to either “made with” or “organic” formulations consistent with human standards. In either case, the task force banned genetically-modified ingredients, nitrites, nitrates, processing with sludge or irradiation and synthetic substances not on the National List. Organic pet foods cannot contain non-organic ingredients if organic ones are available.
The NOP has not yet accepted these recommendations. But this lack in organic standards has not deterred consumers’ willingness to purchase organic pet food products. The Organic Trade Association’s spokesperson Barbara Haumann says that Americans spent $30 million in organic pet food in 2005 and $41 million dollars in 2006. The projected annual growth from 2007 and 2010 is about 33 percent per year. “That’s phenomenal,” Haumann says. Some of this growth may be attributed to last year’s melamine scare. When pet food recalls began, several organic pet food companies reported double and triple sales rates.
Once the NOP’s pet food policies are in place, the agency will need to monitor companies that label their product with a trademark word suggesting an organic product --organica, organix, organimax—without actual certification. “There have been complaints about this since 2000, but no action is ever taken,” Rosen says. *
The preamble to the NOP labeling regulations state that“We will consult with the Federal Trade Commission and the FDA regarding product and company names that may misrepresent the nature of the product and take action on a case-by-case basis.”
From a consumer’s perspective, it makes sense that the NOP establishes clear organic pet food regulations and certifiers follow the same ingredients and labeling laws. Pet owners who buy premium organic products pay premium prices. One company sells a 15.4 pound bag of organic, free-range chicken-based dog food for $41.00. The same amount of money buys 30 pounds of premium grain-free dog food made with roasted bison and venison. The organic company sells a one pound bag of dog treats for nearly $10, double the price of its non-organic “honey-glazed chicken recipe treats with apples cinnamon and stone-ground grains.” With hundreds of different pet foods on the market marked “human-grade,” “holistic,” “healthy” and “organic,” consumers need to know what’s behind these labels.
The label on my Chinese-made chicken jerky treats reads, “all natural, cage-free, digestible.” Skeptical of these claims, I called the company back to clarify their safety standards. “We’re certified with AIB International,” an employee told me.
Jon R. Anderson, AIB International’s Head of Occupational Safety and Educational Product Development, was asked about this comment. “The AIB inspection has nothing to do with claims on product labels or the component content of raw materials,” Anderson stated. “Its key requirement and role is to ensure that the handling and processing of food products in a facility takes place in a wholesome and safe manner. We measure and comment on specifics regarding the cleanliness of an operation by conducting a thorough inspection that may be regarded as a detailed snapshot at a point in time.”
I have no idea if toxic chicken jerky treats played a role in the death of my friend’s Chow or my own dog. But I do know melamine-contaminated Chinese pet food sickened or killed 1,000s of cats and dogs in the U.S. and Canada last year. Although the Chinese government executed the man responsible, the FDA’s current warning about imported chicken jerky indicates a continuing health risk.
I threw several $7.00 packets of unopened chicken jerky into the trash bin. My puppy now gets treats made in the U.S. in USDA-inspected facilities. Her life depends on what I feed her. And I won’t jerk her around.
Michele Taylor is a freelance writer living in Eugene, Ore. She once jumped in the Willamette River to save Mona, the editor’s dog.