It is time for the Food and Drug Administration and the media covering it to stop pretending that our nation's massive pet food recall only concerns our pets, for the more we learn about common food industry practices, the breadth and scope of melamine contamination, and the lack of adequate regulatory safeguards, the more it becomes apparent that our entire food supply isn't nearly as safe as the average consumer assumes it to be.
The industrial chemical melamine has now been discovered in multiple high-protein food additives -- wheat, corn and rice gluten -- from multiple Chinese manufacturers, leading industry experts to conclude that not only was the contamination intentional, but that such "economic adulteration" is disturbingly widespread, at least in China. Testifying this morning before the House Committee on Energy & Commerce, ChemNutra CEO Steve Miller -- the importer of melamine-tainted wheat gluten that killed or sickened as many as 39,000 dogs and cats -- explains the theory:
"We at ChemNutra strongly suspect, at this point, that XuZhou Anying Biologic Technology Development Co. Ltd may have added melamine to the wheat gluten as an "economic adulteration" designed to make inferior wheat gluten appear to have a higher protein content. They can sell it to us at the price we would pay for a higher-quality product because the melamine, our experts tell us, falsely elevates the results of a nitrogen-content test used to assess protein content. Melamine is not something that we or, anyone else, including the FDA was ever testing for in the past, though of course we are now.
We have recently been told that there was a prior history of this same kind of economic adulteration related to a similar agricultural commodity about three decades ago, where this commodity was adulterated with urea, another nitrogen intensive additive, which had at the time become inexpensive enough to economically use to fool the protein testing."
Given the facts and the known history, no other theory can adequately explain the contamination, regardless of what FDA investigators eventually find once they are permitted entry to China. One synthetic organic chemist explained that he could think of no other chemical better suited to such economic adulteration than melamine. "What you would look for" he told me, "is an additive that is nontoxic, nonvolatile, high in nitrogen... and dirt cheap." At approximately 66-percent nitrogen by weight, with no explosive characteristics or previously known toxicity, and widely available for less than a penny a gram, melamine was the obvious choice.
If these known batches of adulterated gluten have not made it directly into the human food supply, it is only by sheer luck, but last week it was confirmed that the toxin most likely did make its way into American kitchens in the form of melamine-tainted pork from hogs fed on "salvage" pet food, exposing yet more of the dirty underbelly of our food industry.
What is "salvage" pet food, and why was it fed to hogs? A spokesperson for Diamond Pet Foods explained that the mixture from the beginning of each production run is "too high in moisture content to run through the manufacturing process," and that this is provided to farms with non-ruminant animals as "salvage" under regulatory guidelines. In all of its communications regarding the hog poisoning incident, Diamond is careful to frame the little known "salvage" and "distressed" pet food market in the best possible light.
"It is a common regulated practice for animal food facilities to provide salvage product to farms with non-ruminant animals. This regulated practice is mindful of the environment as it does not waste energy (food) and saves valuable landfill space."
Yeah sure, in fact, feeding salvage and distressed pet food to livestock apparently is a common practice... in the U.S. North of the border, however, not so much. Indeed, according to the Canadian Food Inspection Agency:
Because livestock animals are grown as food for humans, and pets are not, the pet food industry is able to make use of ingredients which may be unsuited for use in livestock feeds. Thus it is not acceptable to subsequently reintroduce these ingredients back into livestock feeds as waste pet food material. [...] Pet food, including salvaged and distressed pet food, is not an approved ingredient for use in livestock feed and as such its inclusion is not considered safe and will not be allowed at this time.
Makes sense. Unsuitable ingredients include those not approved for use in livestock feeds as listed in Schedule IV or V of the Canadian Feeds Regulations. (Interestingly, "rice gluten" or "rice protein concentrate" appear nowhere on the list. Or, for that matter, in the FDA's EAFUS -- Everything Added to Food in the United States -- database. Go figure.)
Other ingredients unsuited for livestock feed -- in Canada -- include those that "may contain animal proteins [...] which may be prohibited from feeding to ruminants." You know, it just isn't kosher (literally and figuratively) to feed cows, um... cows.
And according to a brochure provided by the Pet Food Institute, the same ruminant cannibalism prohibition holds true here. Sorta. In the U.S., salvage and distressed pet food may be repurposed for livestock feed, but must be labeled "Do Not Feed to Cattle or Other Ruminants" if it contains any mammalian protein at all. That is, any mammalian protein except:
- Milk products.
- Gelatin.
- Blood and blood products.
- Pure pork or horse protein.
- And inspected meat products of any type which have been cooked and offered for human food (such as "plate scrapings") and further heat processed for animal feed.
Yuck. Who knew that in the U.S. your unfinished burger could make its way into cattle feed via salvage dog feed, and then back onto your plate in the form of another burger? That type of dedication to recycling I can do without.
One of the take-home messages from the whole Mad Cow crisis was that it was unsafe and unnatural to feed animal protein to ruminants meant for human consumption, and yet the practice apparently continues to this day. Our lax, salvage pet food regulations have already directly led to human consumption of melamine-tainted pork, and there is no reason to be confident that this and other dangerous chemicals or diseases have not contaminated our beef and dairy supply. If it is unacceptable to feed salvaged pet food to livestock in Canada, it should be unacceptable here in the U.S. as well.
There has been much talk recently about the FDA lacking the funding and staffing necessary to adequately police our globalizing food industry, but after six years of Bush administration control, it also clearly lacks the leadership and mandate as well. This isn't merely an issue about management -- it is ideological -- and by now it should be clear to objective observers that the FDA's and other federal regulatory agencies' over-reliance on industry self-regulation has put the health, safety and welfare of the American public at risk.
This is what comes from electing politicians who despise government, and who appoint regulators who do not believe in regulation.
[Read more from David Goldstein at HorsesAss.org]