Within the last decade, there has been an increase in the level of concern for the moral and ethical treatment of animals. Pets are now increasingly treated as if they were members of the family, and there is an increased concern for the safety and well-being of commercial livestock, as evidenced by the increased cage size requirements for egg-producing chickens and the consumer-driven preference for “free-range” animal-derived products. Today’s consumers and pet owners demand that every aspect of an animal’s health and welfare be evaluated.
Critical to health for both pets and livestock is a safe and nutritious food supply. All animals require a diet sufficient in fat, protein, and carbohydrates to meet basic energy requirements for sustaining life. In addition to the basics, there are also a myriad of other nutrients required for optimal animal growth and nutrition, which many times need to be added to the diet in the form of dietary ingredients. Unlike in human food, where we have a diverse set of options for every meal, the food provided to commercial livestock and pets is generally the sole source of food. For this reason, every component of the overall diet must be evaluated to make sure it is appropriate, safe and nutritious for that species of animal. This also makes evaluating the safety of the ingredients added to the feed especially important for the well-being of both pets and commercial livestock. Evaluating safety is more than studying the growth of the animal; the assessment of safety of feed ingredients requires thorough study of the animal’s physiological response to the ingredient, as well as the adherence to proper scientific procedures.
Animal feed ingredients may follow one of three regulatory paths in order to be sold in the United States: a feed additive petition, a generally recognized as safe (GRAS) determination, and an Association of American Feed Control Officials (AAFCO) new ingredient definition petition. Each path has a different level of federal oversight prior to marketing the ingredient, but all require that a new ingredient be determined safe under its intended conditions of use. Under federal regulations, a food additive and a substance determined GRAS should have the same qualitative and quantitative level of scientific data to substantiate safe use of that ingredient. A feed ingredient evaluated by AAFCO has no such federal requirement on safety evaluation.
As the name indicates, AAFCO is an association of feed control officials from each of the 50 States, along with Puerto Rico, Canada and Costa Rica, originated in 1909 to standardize feed specifications through individual state law – this took place 50 years before federal feed ingredient regulations existed! AAFCO still meets twice yearly to provide a forum for the states to agree on regulations. Each year, AAFCO releases an annual Official Publication (OP) that includes a list of ingredients that the state regulators have agreed upon, In addition, the OP has included an overview of in vivo studies that can be conducted to show that pet food is appropriately formulated to sustain growth for a dog or cat’s particular life stage (e.g., maintenance, growth, or reproduction). Some of these study designs were utilized to prepare protocols to determine the safety of feed ingredients for pets. However, because these study designs were often abbreviated compared to more modern test designs, in recent years the Food and Drug Administration’s (FDA’s) Center for Veterinary Medicine (CVM) representatives have stated that these study designs are insufficient to determine the safety of feed ingredients, and is insisting on more comprehensive testing protocols that are consistent with CVM’s recommended testing for food additives.
The FDA has stated that there must be “reasonable certainty of no harm” such that a food additive is safe under the intended conditions of use and that a GRAS substance must meet the same scientific standard for safety. For the determination of the safety of animal feed ingredients, CVM has stated that studies that are critical to the determination of safety should be conducted under Good Laboratory Conditions (GLP), which includes extensive documentation and adherence to standard operating procedures (SOPs) and statistical analysis of the results, where warranted. In addition, specific to the analysis of the safety of new food ingredients, study protocols must include the evaluation of parameters that indicate potential toxicity, such as liver enzyme levels, kidney function, or other tissue specific analyses that may herald organ damage. Short-term evaluation of only growth, feed consumption or feed-to-gain ratios (primary endpoints for showing efficacy of a feed ingredient for commercial animals) are not sufficient, as they are not indicative of potentially toxic effects. Because it is often not feasible to conduct a lifetime test of an animal feed ingredient, the evaluation of safety must also include an assessment of the effects of consumption of the ingredient at exaggerated use levels over a less-than-lifetime period.
As with any industry, the animal feed industry works to increase efficiency and decrease production costs, while maintaining safety to both its workers and to the consumers of its products. Those that produce animal feed ingredients are all too aware that the well-being of both commercial livestock and pets starts with feed ingredients that are nutritious and safe. According to regulation and scientific research, safety of animal feed ingredients should be evaluated utilizing study protocols sufficient to analyze for potential toxicity of the ingredient when consumed by the animal under the intended conditions of use. Ensuring the safety of feed ingredients is critical to the overall safety, welfare and nutrition of pets and livestock.Tags: AAFCO, animal feed, CVM, FDA