Requirements for human food production
Within human food production, there are two major routes of manufacturing or producing a food. In a large manufacturing facility, USDA Food Safety and Inspection Service (FSIS) personnel are on site during production to ensure the standards are being met. Imagine a person with a checklist ensuring proper handling, processing, cooking, packaging and storage. The second type of production facility would be a restaurant or open-kitchen type of setting. In this case, USDA FSIS personnel are not on site; however, public health authorities generally have jurisdiction and will do both announced and unannounced audits.
Yet although the regulatory authorities are very different between human food and pet food, the food safety and quality concerns are still the same.
Human grade in consumer terms
When the consumer purchases a pet food touting human grade claims, they may not be thinking in specifics that the AAFCO guidelines have set forth or 21 CFR part 117 outlines. With that being said, they do have reasonable expectations that all ingredients are human grade, they are handled in a manner that complies with human food safety standards and they are made in a facility that is licensed for human food production.
(Reminder: pet food ingredients whose legal definitions allow them to be sourced from diseased or non-slaughtered animals are poultry by-products, chicken by-products, turkey by-products, poultry by-product meal, chicken by-product meal, turkey by-product meal, meat meal, meat and bone meal, animal digest and animal fat.)
Some moist pet foods – purchased in tubs – are human grade (manufactured in a human food plant), some are not (manufactured in a pet food plant).
Note: Human edible means human grade. Pet food ingredients are one of two things…edible or inedible.
Feed grade pet foods could use 100% human grade ingredients or they could use 100% feed grade ingredients or they could use a combination of both. Unfortunately, there is no way to tell by looking at the label. Considering that each US State and the FDA allows pet foods to use illegal, risky ingredients (diseased and non-slaughtered animals) – every pet food consumer should ask their pet food these questions…
Note: Some ingredients classified as ‘inedible’ are perfectly safe for your pet. Example of this would be chicken frames. When chicken is processed for human consumption the meat is mechanically separated from the bone. Mechanical separation leaves quite a bit of meat on the bone frame. These poultry frames are sold to pet food. This is a quality inedible ingredient example. Some inedible ingredients are not quality. Example of this would be DOA (dead on arrival) animals or diseased animals rejected for use in human food. This is not a quality ingredient. Will a pet food manufacturer admit to using these types of material? It is doubtful. But you should ask regardless.
Top 5 Reasons to Feed Human-Grade Pet Food by Dr. Karen Becker
Many pet food brands label their products as being “human-grade,” but what does this really mean? Is human-grade dog food safer or healthier than traditional pet food?
Let’s take a look at the ingredients, manufacturing, and packaging requirements that pet foods claim to meet when they use the term “human-grade,” and whether or not they offer any real benefits to pets.
Until recently, the term “human-grade” has not been well-defined when it comes to pet food, but in 2018, the Association of American Feed Control Officials (AAFCO) tried to clear up the confusion. AAFCO is the advisory body that develops standards for pet food labels and ingredient definitions for the pet food industry.
A claim that something is “human-grade” or “human-quality” implies that the article being referred to is “edible” for people in legally defined terms…. For a product to be human edible, all ingredients in the product 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 exist, then human-grade claims may be made.
The US Food and Drug Administration (FDA) oversees 21 CFR 110 and is following a similar protocol for determining if pet foods can use the term “human-grade” on their labels.
Despite these clarifications, you might find dog food manufacturers who say that their products are made from “human-grade ingredients.” This implies that while some or all of their ingredients may have started out as being fit for human consumption, somewhere along the manufacturing, packing, and holding process, 21 CFR 110 standards were not adhered to, and the final product can’t be labeled as “human-grade dog food.”
Now that clear guidelines are available, the FDA may soon begin to take notice of these sorts of infractions, but pet parents must decide for themselves whether the distinction between human-grade dog foods and those made from human-grade ingredients is important to them.
The standards used to regulate human food production are more meticulous than those applied to pet food production. If a manufacturer’s goal is to stay just on the legal side of applicable regulations, foods that are edible for people will be made with higher-quality ingredients and have a lower risk of contamination than will those that are made for pets.
That said, pet food manufacturers can (and many do) choose to make their products using ingredients and processes that far exceed the minimums put forward by AAFCO and the FDA. This is true whether or not the pet food is labeled as human-grade.