Friday, March 21, 2014

Dead Dogs in Pet Food? Nonsense Says the FDA.

.  . . . . -- The US Food and Drug Administration

As a species, we are naturally drawn to the gruesome, the frightening, and the macabre.

We pay good money to see slasher movies and ride death-defying roller-coasters.

And so it should come as no surprise to find that folks love to speculate about whether... maybe... dead dogs and cats are being ground up for kibbled dog food.

Here's the short answer....


The U.S. Food and Drug Administration web site addresses the issue directly if folks will actually take the time to read.


Good God man, where's the fun in that? Next you'll be telling us there's no Sasquatch, no Chupacabra and no alien autopsies -- and Lord knows we've all seen the videos of those things!


True enough.

But there are no videos of dead dogs and cats being turned into dog food. None.

And while there is a trace amount of pentobarbital residue in a very few bags of kibbled dog food, it does not seem to be a health concern, and it has a perfectly simple source explanation: farm livestock.

But don't take my word for it. Here's what the FDA has to say about the pentobarbital found in dog food and where it does NOT come from:

A test, derived to determine source of pentobarbital in pet food, is so sensitive it can identify the species of origin for animal products on a scale of 7 lbs. per 500 TONS. Tests find no cat or dog DNA in pet food. 
A PCR primer set specific for a canine mtDNA sequence was deduced, and subsequently shown to amplify only that mtDNA derived from dogs, but not mtDNA derived from cattle, swine, sheep, goat, pig, cat, deer, elk, poultry, turkey, rabbit, or horse blood (Fig 1).

When the PCR process is applied to a sample, researchers look for the process to yield PCR products called amplicons that are specific both to the animal species and gene sequence the researchers are looking for.

Thirty-one dog food samples previously analyzed for the presence of pentobarbital 2 were then subjected to the DNA extraction process and tested for the presence of canine DNA. The results demonstrated the complete absence of canine DNA in all 31 samples (Fig 2) at a level exceeding 0.0007% (w/w). In other words, at this level of detection, we can say that if there is any canine material in the dog food, it is present at a rate of less than 7 lb. per 500 TONS.

Cats and horses are also euthanized with pentobarbital and thus might be the source of this drug in dog food. PCR primer sets that are specific for either feline or equine mtDNA were also developed to test the same dog food samples for presence of mtDNA that might have been derived from cats or horses. The results from these analyses demonstrated the complete absence of PCR products, the amplicons, specific for either cat or horse mtDNA in all 31 dog food samples. This analysis was carried out under conditions that achieved 0.007% sensitivity.

Because the results so far were negative, it was important to demonstrate that mtDNA from these dog food samples could be amplified to increase the sensitivity of the test. Therefore, the mtDNA from these samples were subjected to PCR amplification using a set of PCR primers (termed “universal” primers) shown to amplify only mtDNA from cow, deer, elk, sheep, goat, horse and pig. These particular animal species were expected to be present in the samples due to the ingredient statements of the dog food labels.

The results demonstrated that most, but not all, samples had a PCR amplicon, indicating that one or more of these species (cow, deer, elk, sheep, goat, horse or pig) were present in these dog food samples. Interestingly, two samples that were positive for pentobarbital did not produce a PCR amplicon when the universal primers were used, suggesting a complete absence of mammalian-derived mtDNA from species that are typically euthanized with pentobarbital.

Using PCR primer sets specific for bovine, swine, or sheep mtDNA, we were able to demonstrate the presence of rendered material derived from one or more of these species. As expected, samples that did not produce a PCR amplicon using the universal primers failed to produce amplicons when the species-specific primers were used.

For the most part, the PCR results confirmed the ingredients as listed on the package label. Unexpectedly, there were four samples that had PCR results inconsistent with the package label.

Two dog food samples listed lamb in the label, yet both samples also had a PCR amplicon specific for bovine mtDNA. One of the samples labeled as containing lamb proteins produced no amplicon specific for sheep (lamb). While the remaining two samples listed only poultry on the label, one sample had a PCR amplicon specific for bovine mtDNA, whereas the other sample had a PCR amplicon specific for swine mtDNA. Pentobarbital was present in these latter two samples.

Boom.  Science.  Get some.

In science, you do not make extraordinary claims and demand that others prove them wrong. That's what religions do.

Science is the opposite of religion; it says that extraordinary claims require at least some proof.

But here, there is NO PROOF.

None. Zero. Nyet. Empty set.  And people have been looking for a loooong time.

We have video tape of the Lochness Monster and Big Foot, and I myself have taken pictures of Chupacabra in my back yard and in the field.  So those clearly exist.

But is there any video tape of dead dogs and cats being rendered into dog food?

No there is is not, despite scores of thousands of workers making jaw-dropping amounts of dog food at dozens of factories all over the nation, and around the world.

In fact, the entire dead-dogs-turned-into-dog-food-story seems to have been sparked by a single 1995 story in the Baltimore City Paper (a free local newspaper more famous for its "personals" column than its reporting) which asserted -- but never proved -- that a local independent rendering plant was running two separate lines (one for slaughterhouse and butcher waste, and the other for roadkill and euthanized pets) and then mixing the fats at the end of the run.

But guess what?

When ABC television's 20/20 news program investigated,
they found the story had no legs. It was not true so far as they could tell, and they had to pull the plug on the story they had intended to take national.

Other reporters have chased the same story again and again over the years, but they too have come up with nothing despite the fact that everyone with an Ipod Nano now has a miniature camera and recording device capable of making a pile of cash for the right video tape.

It seems dead dogs and cats are simply NOT being made into dog food. They might be made into candles, industrial grease, floor wax, or chicken or hog feed (though not much evidence of that either), but not dog food.

Of course, a lot of people are not going to be swayed by silly things like facts.

Why let truth get in the way of a good story? Why let science derail the fear-inducing story-board which says ALL of our processed foods are bad, and that the FDA has NO IDEA what is in them.... and never mind if our foods are actually safer today than at any time in U.S. or world history.

But hey, I am not trying to sway the minds of the folks who stand in long lines at the fair in order to pay good money to be scared.

Everyone needs a thrill, a hobby, and a cause.  I get it.  Carry on. If you want to worry about what is in kibble, be my guess.

But be advised that your dog is definitely eating its own shit.

And if you run your dog loose in forest, field or fen, it's also eating the occasional fox and raccoon crap, cat turd, cow patty, pile of deer shit, and mouse dingle-berry as well.

If your dog spends any time outside on its own (even if it is just in your suburban back yard) it almost certainly eating a dead sparrow once in a while, and maybe a live lizard or snake. For sure it is eating the occasional live mouse or dead squirrel.

If you leave your food and water bowls outside on the patio or porch, your dog is certainly drinking a little rat pee, and has probably gobbled down a little possum snot as well.

And I have not even talked about what happens when your dog drinks out of the toilet bowl in your house, or licks its crotch, or sniffs the butt of the dog next door. Woooeeee!

You say you are worried about toxins in kibbled dog food?  OK. Worry away. I can't stop you. Just remember you are probably dosing your dog, inside and out, every month, with powerful poisons designed to kill, and which do kill every dayThose poisons are called Frontline and Heartgard.  But you say are still worried there might be a micro-trace of some toxin found in some bag of dog food?  That's a little amusing.  But hey, go ahead and have another bite of that apple and tell me all about it.  No, no, I will not say a word about your own weight, alcohol consumption, smoking, salt use, chemical hair dye, or prescription drug use.

I am not trying to tell you to change your area of concern.  Be strong and carry on.

That said, I am willing to bet
I know what will kill your dog, and it's not likely to be bagged kibble!

It's YOU.

You see, about 40% of all dogs are obese
and obese dogs have shorter lives and often live for years with collapsing joints and other ailments as well. Dogs are obese because of their owners and nothing else.

Add to obesity the breed of dog you selected.

Do you have
a French Bulldog, a Pug, an English Bulldog or a Pekingese?

These dogs have chronic breathing problems, and are routinely beset with joint and spine problems, to say nothing of chronic skin diseases and eye problems.

Of course, the flat-faced brachycephalic breeds are only a small slice of the canine parade of dysfunction.

We also have the dogs that are four-legged cancer bombs: the Scottish Terriers, the Bernese Mountain Dogs, the Flat-coated Retrievers, the Greyhounds, the Deerhounds, and the Golden Retrievers.

The cancers here are gene-based, and are exacerbated by inbreeding.

But do the owners of these breeds stand up and demand an open registry to perhaps reduce the incidence of cancer?

They do not.

Do the owners of these breeds tell every prospective puppy owner that there is a better than 50% chance that the little puppy they are about to buy will die from a heart-breaking cancer which, before it dies, will suck thousands of dollars from the poor rube's wallet?


And a similar silence is heard from the myriad other breeds wrecked by dyplasia, heart and liver disease.

Instead of a demand for AKC reform, we get a lot of hand-wringing about what might be in dog food, and what it might do to dogs.

Which is fine with me.

I get it.

There will always be folks
standing in line to pay good money to see a slasher movie or ride the roller coaster.

There will always be people standing in line to pay money to see the freak show.

There will always be people willing to pay a lot of money for a Jaguar sports car, and never mind the crappy construction and enormous repair bills, or the fact that the owners will never drive the car more than 75 miles an hour.

Form and image over construction and function. I get it

As a species, we like to scare ourselves, and we like to amuse ourselves, but we hate to take responsibility for our own actions and much prefer to blame the great and mysterious THEM.

And so our dogs cannot be dying early and tragic deaths because we selected deformed, defective and diseased breeds and then overfeed and under-exercised them.

It must be the food. It must be the dog food companies.

Those bastards!



Rick said...

I was pleased to read that you have made the connection between the Jaguar cars and seriously inbred dogs. I've always thought they (the cars) were the result of the stuffy "form over function" attitudes of some of the people across the pond. And also amused by the joke: "What is the best motor for a Jaguar?" Answer: "A Chevy 350 V-8." It's true, ask any mechanic, it bolts right in. It's the Jaguars and the AKC that are the real jokes.

Peter Apps said...

It will be a huge comfort to those who need something to worry about that the rigorous processing that carcase meals and similar materials undergo on their way to becoming pet food ingredients is likely to cause DNA tests to generate false negatives.

PBurns said...

False positives and negative are always a possibility, but statistically it's pretty hard to get a false negative on 31 straight samples -- it's a .000000000000000000000000000001 chance. False negatives and positives are also getting a bit rarer now with the use of more powerful denaturants and reagents brought about by the pressure to certify this and that as NO-GMOm organic, etc. But yeah, I would worry like hell if I was those people. No reason not to pucker up and live in terror of imaginary stuff every day. Eat up the lies and shit out the fear I say!

mugwump said...

Um...I recently watched a video of a stray dog eating a puppy. The puppy had died, the dog was own barn dog has been known to mistake newborn kittens for rats, I'm not saying anything more on that one.
I guess my point is, I don't think the dogs would actually mind. Would it help if the ingredients actually listed dog and cat meat?

Peter Apps said...

The rate of false negatives depends on the lower limit of detection of what you are aiming to detect. In this particular case concentration of DNA is being measured as a proxy for the presence of dog meat. The lower limit of detection that is given is an extrapolation based on the based on the lower limit of detection for the DNA - the report does not address what fraction of dog DNA survives the processing (what analytical chemists would call the recovery), so the true detection limit for dog meat is unknown. If the processing destroys dog DNA then there could be lots of dog meat but no dog DNA. Do the dogs care ? - I doubt it.

PBurns said...

So cow, chicken, lamb, pig, beef DNA does not get destroyed by processing, but somehow dog DNA is destroyed? Sorry, not buying that. The testy here is accurate to 7 pounds to 500 TONS as it says several times. So that is 7/1,000,000. Pretty sure these folks know what they are doing. US FDA is the top food and drug regulatory agency in the world.

Richard Goth said...

"US FDA is the top food and drug regulatory agency in the world."

In conspiracy land though, they are jackbooted Nazis plotting the deaths of millions of americans through fluoride, artificial sweeteners and mandatory vaccination! ;-)

Peter Apps said...

HI Patrick

IF the potential dog meat and the actual beef or lamb go through the same process, then the recovery and lower limits of detection for the original meats can be accurately estimated from the detection limits for the DNA - so if you can detect one part of dog DNA in a million parts of beef DNA you can detect one gram of dog meat in a ton of meat. But pet food is not made by mixing all the raw ingredients and then processing them all together. Some of it (mostly the better quality ingredients like "real" meat) get ordinary industrial cooking, extrusion and drying. Other components enter the pet food factory in the form of carcase meal with has been through a carcase crusher and both high temperature processed in both its wet and dry state. Carcase meal processing destroys biological macromolecules much more effectively than ordinary industrial cooking - that's why it is used to process carcases. It is very likely that IF there is dog meat in dog food it will have got there via carcase meal and will contain a much smaller fraction of its original DNA than the beef and lamb components that were less rigorously processed. I am not questioning the capability of integrity of the FDA, because an internet press release aimed to allay the misgivings of pet food purchasers is not the place to get into the minutae of how detection limits were estimated.

A detection limit of 7 parts per million does not mean there are 7 in a million chances that a negative sample contains dog, it means that there is a (usually 95% or 99%) probability that it does not contain dog.

My dogs eat dry food that comes in 40 kg sacks - just in case you were wondering whether I am a natural food zealot.

What do they do with the millions of dogs and cats that get slaughtered ? - fertiliser ?

PipedreamFarm said...

try reading up on the latest reseach in this field using the orignal publications

Peter Apps said...

Thanks Pipedreamfarm

The title of the very first hit on the list seems to support me; "Detection of rendered meat and bone meals by PCR is dependent on animal species of origin and DNA extraction method", and in its abstract it says, "These results demonstrate that extraction of DNA from processed animal protein is different for pure ingredients and fortified animal feeds. These results indicate that a method specifically developed using just animal-derived meat and bone meal may not yield a functional assay when used to detect animal tissues in complete animal feed." Cherry picking from the last reference on the same page gives "Moreover many PCR-based methods cannot be used for detection of MBM (meat and bone meal),because the high temperatures involved in the standard rendering process (133 °C ... from 66 to
145 bp). It doesn't give full text for free.

I need to correct a paragraph from my previous post, it should read; "A detection limit of 7 parts per million does not mean there are 7 in a million chances that a negative sample contains dog, it means that there is a (usually 95% or 99%) probability that it does not contain dog at a concentration higher than 7 parts per million".

PBurns said...

As the original post notes, "In science, you do not make extraordinary claims and demand that others prove them wrong. That's what religions do.

"Science is the opposite of religion; it says that extraordinary claims require at least some proof.

"But here, there is NO PROOF.

"None. Zero. Nyet. Empty set. And people have been looking for a loooong time."

All of this is 100% true.

Thousands of employees work in hundreds of dog food factories, and there is not not one incidence of dogs being used in pet food. None.

The statistics on the amount of slaughter house remains available for direct rendering in the U.S. is astounding: more than 150 million head of cattle, calves, hogs, and sheep and more than 55 billion pounds of poultry annually. Dog food makers do not have a hard time buying directly from slaughter houses which is, in fact, what they do for everything but lamb, most of which is imported from Australia and New Zealand.

DNA testing of animal feed is not as dicey as this one article suggests. See >> >> where they note: “The results of this study demonstrated that the DNA forensic kit can be used to extract DNA from animal feed, which can then be used for PCR analysis to detect animal-derived protein present in the feed sample.”

Also see >> where they note: "A rapid PCR-based analytical method for detection of animal-derived materials in complete feed was developed. Using a commercially available DNA forensic kit for the extraction of DNA from animal feed, a sensitive method was developed that was capable of detecting as little as 0.03% bovine meat and bone meal in complete feed in under 8 h of total assay time. The reduction in assay time was accomplished by reducing the DNA extraction time to 2 h and using the simpler cleanup procedure of the kit. Assay sensitivity can be increased to 0.006% by increasing the DNA extraction time to an overnight incubation of approximately 16 h. Examination of dairy feed samples containing either bovine meat and bone meal, porcine meat and bone meal, or lamb meal at a level of 0.1% (wt/wt basis) suggested that this method may be suitable for regulatory uses. The adoption of this commercially available kit for use with animal feeds yields an assay that is quicker and simpler to perform than a previously validated assay for the detection of animal proteins in animal feed."

But, to get back to it, there is NO evidence that anything by pure slaughter house product has ever been used in dog food.


Five major companies account for over 65 percent of the pet food market in the U.S. These big five companies are Mars, Nestle, Proctor & Gamble, Colgate-Palmolive, and Del Monte. All make foods and care products for humans. Anyone seriously think these companies and others are using dogs to make dog food? Ridiculous. And, as noted, not one shred of evidence suggests they have have.

Peter Apps said...

Hi Patrick

I hope that you do not think that I am arguing that there is dog in dog food. All I am saying is that using analytical chemistry (which is what DNA testing is when you come down to it) it is impossible to prove that something is not present in a sample. The only statement that can be made is that it was not detected using a test with a particular lower limit of detection. When the target analyte is a particular species of meat in a formulated feed the detection limit has to take into account the history of the ingredients, because that history affects the DNA that is actually being measured. In particular; rendering to produce meat and bone meal or carcase meal degrades DNA.

A "not detected" result in analytical chemistry is absence of evidence. The evidence of absence (above a certain concentration) comes from the validation of the method that was used to produce the result.

When there is no evidence at all that there is dog in dog food the only sensible conclusion is that there is no dog in dog food. We agree.

PipedreamFarm said...

Peter, you really should have gotten past the first article which supported your hypothesis and reviewed the other articles which may or may not have supported your hypothesis.

In the scientific method one does not ignore data that does not support the hypothesis; the hypothesis is adjusted to account for all data.

PipedreamFarm said...

Peter, you asked how euthanized pets are disposed of if not rendered. Here is MD the most likley disposal method is incineration.

Peter Apps said...

Hi Pipedreamfarm

I am not advancing an hypothesis, I am simply stating the facts about analytical detection limits and what a "not detected" result means.

In the simplest possible terms it comes down to "you cannot prove a negative".

PBurns said...

Irving Copi, the author of Introduction to Logic writes:

"In some circumstances it can be safely assumed that if a certain event had occurred, evidence of it could be discovered by qualified investigators. In such circumstances it is perfectly reasonable to take the absence of proof of its occurrence as positive proof of its non-occurrence."

PipedreamFarm said...

I understand better than you think what "not detected" means since my job involves the development, manufacturing, and lot testing of clinical diagnostic test kits.

Peter Apps said...

Hi Patrick

This is taking us rather far from dogs. The rationale behind measured limits of detection and quantitation is that they render assumptions, in the sense that Copi uses it here, unnecessary. It is possible to state that the concentration (or mass fraction, or mole fraction which is what DNA analysis measures) is within certain limits with a defined level of confidence. The results apply only to the samples that were actually analysed; assumptions come in only when those specific results are generalized to a larger population.

The FDA results are evidence that there is no dog in dog food, but they are not particularly strong evidence because of the issues we have been discussing. The absence of witness testimony or photographs, the easy and cheap availability of abbatoir by-products, the high risk to market share of producers that use dog-derived products, all of which you have listed, and the regulated incineration of dead cats and dogs (thanks Pipedreamfarm)are far stronger evidence that there is no dog in dog food.

PipedreamFarm said...

I disagree that the FDA data is weak evidence in determining whether or not there is dog in dog food. Their measured data would be given higher value in scientific circles, regulatory environment, and likely in a court of law than the other evidence you find more compelling. Otherwise the EU and USA would never have required lab tests for herbivore protein in finished herbivore feeds.

Peter Apps said...

Hi Pipedreamfarm

If we are to brandish our CVs at one another; I have 28 years in analytical chemistry, including 9 years in a residues and contaminants lab and three years in a national metrology laboratory.

Which takes us even further away from dogs.

PBurns said...

Dogs licktheir own assholes and eat their own feces, but we test the hell out of food and have standards.

Not particularly high standards, but standards.

For example, the standard for ground pepper is 950 bug parts per 100 grams, while the standard for sage is 2,000 insect parts per 100 grams. See >>

The standard for 100 gram of chocolate is 3 rodent hairs.

Red fish and Ocean Perch are not supposed to have more than 3% of the fillets contain 1 or more copepods accompanied by pus pockets.

Canned mushrooms should not average more tham 20 maggots per 100 gram can. >>

But the same FDA that looks (and disqualifies) foods for not meeting these standards could find NO dog or cat in dog food.

FDA manufacturing standards are, in fact, pretty high even if inspections are too rare. The Drug Controller General of India. for example, says he thinks nearly all Indian pharmacy companies would fail an FDA inspection, and, in fact, many are. Ranbaxy was only the first. And, as PipedreamFarm notes, when FDA fails you, you are in a lot of trouble in court and in the press.

PipedreamFarm said...

As a member of a national lab, if you were to present data to a regulatory body (or a scientific conference) which would carry more weight as to there being no evidence to support the use of rendered pets in animal feeds:
Lab tests from the FDA showing values below detection limits or a newspaper article stating that the local rendering plan no longer accepts dead pets?

The point of the post was to refute the claims that dead pets routinely end up in rendering plans and therefore in finished feeds.

PipedreamFarm said...

Phenobarbital has been found in finished animal feeds and has been used as evidence that euthanized animals are being used to make those feeds.

If the measured phenobarbital (determined to not degrade during rendering-published results) came from euthanized pets what would be the expected amount of mtDNA in the finished feeds (taking into account the degradation due to the sterilization processes in rendering)?

The FDA scientists have implied that amount of mtDNA would be detectable with their test methods.

Peter Apps said...

Before the tsunami of criticism hits the land and washes the discussion away, can we just review what I have and have not claimed and or stated.

Have I claimed that the FDA measurement result is in any way inaccurate ? - No.

Have I impugned the general quality of the FDA's investigatory and regulatory work ? - No.

Have I claimed that there are dog carcasses in dog food ? - No.

On the balance of evidence do I think that there might be dog carcasses in dog food ? No.

Did I read Patrick's original post ? - Yes, and do I need Pipedreamfarm to summarize it for me ? - No.

If any analytical result that failed to detect a given substance at a stated concentration was claimed as proof that the substance was absent from: 1) that particular sample or 2) the larger body of material from which the sample was drawn the claim would be rejected by any informed analyst or regulatory body.

Does the FDA Veterinarians Newsletter that was linked from the OP conclude that there is no dog or cat in dog food ? - No. What it concludes is " The results of this study demonstrated a lack of correlation between species identity and the presence of pentobarbital in dog food. They also provide evidence against the presumption that euthanized pets are routinely rendered and used in pet food."

If the FDA had definite evidence that there is no dog in dog food, would they state it clearly and unequivocally ? Surely yes.

It is interesting that the presence of pentobarbital correlates with the presence of animal fat - because fat is the animal product with the lowest content of DNA.

Can I re-iterate the point that I was originally trying to make - which is that people who have convinced themselves that the big companies who make pet food are adding dead dogs and cats to it are never going to be argued out of their point of view by evidence, because they were never argued into their point of view by evidence. It is now very plain that that I should have stated it more explicitly.