The Truth About Animal By-Products in Dog Food


Chickens Awaiting Slaughter | Animal By-Products

Animal by-products — what could be more controversial to dog food shoppers than animal by-products?

These common pet food ingredients are loathed by many. Yet they’re accepted — and even revered by others.

Fans claim animal by-products are nutritionally no different than any other type of meat. And they blame the ingredients’ noted unpopularity on the unsavory mental image they invoke.

Something supporters like to refer to as “the yuck factor”.1

Critics, on the other hand, insist these ingredients are nothing more than inedible waste of inferior nutritional value.

What Are Animal By-Products?

Animal by-products are what’s left of a slaughtered animal after the parts intended for human consumption have been removed.

This meat processing scrap (known as offal) is considered inedible by many cultures and includes waste material like:

  • Feet
  • Backs
  • Livers
  • Lungs
  • Heads
  • Brains
  • Spleen
  • Frames
  • Kidneys
  • Stomachs
  • Intestines
  • Undeveloped eggs

But there are exceptions.

Giblets (livers, hearts, gizzards and necks) as well as other organs can still be sold as edible meats as they are — or used to make hot dogs, bologna and sausage.

Unfit for Human Consumption
OK for Dog Food?

However, what makes some by-products edible (and others not) isn’t just a matter of what they are but how they’re handled after slaughter.

For example, giblets not refrigerated immediately after slaughter but stored for up to 24 hours in a hot offal2 trailer cannot be sold for human consumption.

Yet they can still be legally used for making pet food.

Likewise, dead-on-arrival animals or other condemned parts3 that have been declared inedible and unfit for human consumption can still be used for making pet food.

Chart of Animal By-Products

Turning Tons of Inedible Waste
into Profitable Products

As you can see from the diagram, there are two primary uses for meat by-products…

  • Canned pet food
  • By-product meals

Inedible by-products not processed into canned pet food can be rendered.

Rendering is a process similar to making stew. Except that the stew is intentionally over-cooked.

With rendering, the idea is to start with a stew of by-products and cook away the water.

Then, skim away the fat and bake the residue.

What you end up with is a concentrated protein powder commonly known as by-product meal.

The Two Grades of By-Product Meal
(and the Only One Suitable for Your Dog)

In the specific cases of chicken or poultry by-product meals, there are two recognized grades…

  • Feed grade by-product meal
  • Pet food grade by-product meal

In an important 2003 study4, pet food grade by-product meal was compared to feed grade by-product meal.

The result? Pet food grade by-product meal was found to be…

  • Higher in protein5
  • Lower in ash
  • More digestible6
  • More consistent7

Bottom line? All things considered, pet food grade by-product meals are superior to feed grade by-product meals.

The Two Ways to Describe Animal By-Product Meals

Based upon the source of their raw materials, there are two ways to identify by-product meals.

  • Named by-product meals
  • Generic by-product meals

Named by-product meals have one thing in common. They all clearly identify the source species of the by-products that was used to make the meal.

These common pet food ingredients can include…

  • Chicken by-product meal
  • Turkey by-product meal
  • Poultry by-product meal
  • Beef by-product meal

And although named by-product meals may not be considered the highest quality ingredients, they can be considered acceptable.

And the One Type You Must Never Trust

On the other hand, generic by-product meals do not identify the source of the meat. Instead, they use vague and non-specific names like…

  • Meat meal
  • Meat and bone meal
  • Meat by-product meal
  • Animal by-product meal

What’s more, generic meat meals can also contain

Because you can never know the source of the meat used to make generic by-product meals, purchase of pet food products containing them should be avoided.

Nutritional Differences… Real or Imagined?

When comparing animal by-product meals with their “regular” meal counterparts, the differences can be nutritionally insignificant.

For example, in the case of rendered ingredients, the digestibility, biological value and amino acid content of both poultry and poultry by-product meals are nearly identical.8

So, if there’s little nutritional difference between the two, why then do some companies use meat by-products… while others don’t?

The Real Reason Dog Food Companies
Use Animal By-Products

There’s one glaring and indisputable reason animal by-products remain so popular with some manufacturers… and not others.

Animal by-products are simply cheaper… notably cheaper than most any other comparable meat product. They’re used for making dog food because they save money. Not because they’re more nutritious.

Why is this important to a pet food shopper?

Although finding animal by-products in a recipe doesn’t guarantee you’ve discovered a good or a bad dog food, their presence must always be considered a reliable clue the food is made with cheaper ingredients.

The Bottom Line

With the sole exception of precisely identified organ meats, two rules will help you more intelligently navigate the confusing world of meat-based dog food ingredients.

First, watch what you spend. Never pay top dollar for any dog food that lists animal by-products on its label.

And lastly, never buy any dog food containing anonymous animal by-products sourced from materials a manufacturer refuses to clearly identify.

Notes and References

  1. M Nestle, “Pet Food Politics: The Chihuahua in the Coal Mine”, University of California Press, Edition 2010
  2. Slaughterhouse waste
  3. Carcasses, parts or organs officially marked unfit for human consumption and intended to be destroyed
  4. W. A. Dozier, III, N. M. Dale and C. R. Dove, “Nutrient Compostion of Feed Grade and Pet Food Grade Poultry By-Product Meal”, University of Georgia, Journal of Applied Poultry Research (2003)
  5. Crude protein 66.1% vs. 58.1%
  6. Average amino acid digestibility coefficient
  7. Batch-to-batch protein variability
  8. Watson, Hillary. “Poultry Meal versus Poultry By-Product Meal“, Dogs in Canada, January 2006
  • Claude Bernard Hublot

    That s the Mac Donald version…but the companies have to put it on the bag….what about all vaccins and medication inside the bodies….

  • Claude Bernard Hublot

    Go to
    Holistic Dog and Cat food
    Made in America,no recalls,fresh ,delivered at your door

    best Regards
    Claude Hublot

  • Kathleen

    I agree with you even though I would throw up to do it, AS LONG AS no diseased animals were allowed, and no animal dead long enough to start deteriorating. And, believe I am an animal lover and spoil my dogs all the time!! But, honestly people can get pretty rediculous, it’s economically AND environmentally responsible to use everything you can.

  • Pamela Joyce Silva

    I can so relate to that, living in the belt myself. I am fortunate that my social security supports myself and my animals. Plus many of my friends animals and rescues. if you need help, get on the internet, use the library’s if you have to, and go look up “organizations that help citizens with low income or the elderly to help their pets. They exist, believe me. But if that is hard for you, look up the nearest rescue group and keep calling until you find one that can help you. Hang in there.

  • Pamela Joyce Silva

    Oh, yes, indeed it is something some of them do do if a “client” comes in and ask for it, even if they don’t agree with it. And, yes, I know for sure.

  • RDH1988

    What do you suggest they do?

  • Claude Bernard Hublot

    Helloooo wake up people what should the food industry do
    With all the meat? And the cheaper the pet food the more sh#$% you will have…
    I know a very good company, always fresh, no recalls made in America and delivery at your door, please take a look at
    We are breeders and we use it for dogs and cats

  • Jemima Eva

    Hi was looking for all this information on google about dog food products from many days.This article is really awesome.I will be your regular followers of this also running a blog about boxer dog info.i would really appreciate if you also visit my blog and suggest what is best for my blog.Boxer dog information

  • Rebecca Crossfield Kruetzfeldt

    Killing an animal in a shelter because of space is in fact murder! Euthanasia is defined as the painless killing of a patient suffering from an incurable and painful disease or in an irreversible coma. The animals who are being murdered are not suffering from a disease, or even sick. When healthy dogs and cats are killed in shelters because of lack of space it’s murder! There is no way around that!

  • LabsRawesome

    I think the op was referring to healthy shelter animals that are euthanized because of overcrowding, or lack of a home. They were calling that murder.

  • MacKenzie Bennett

    It’s not necessarily fair to call euthanasia murder. At times it’s the only option to follow. Please understand that euthanizing is not something vet’s do to make a quick buck or because they’re lazy and don’t want to do work to cure a pet. It sounds ignorant to balantly name it murder.

  • theBCnut

    1. The small amount of grains in a rodents stomach are nothing compares to a single teaspoon of grain inclusive kibbles.

    2. The grains in a rodent stomach automatically come with the digestive enzymes needed to digest them since that is what the rodent was doing.

    3. Cats often don’t eat the stomach and intestines of the rodents they eat.

  • catdog232014

    Grains aren’t part of a biological diet? really… Ok well I beg to differ and here’s why – That the cat who killed/ate that mouse who ate those grains that are/where being digested in its stomach, that the cat probably ate, and you don’t think that biologically significate to the carnivore doing the eating? Interesting. its no wonder people are so confused about nutrition labels in general.

  • Lisa Slater

    The difference between grains and carrots is obvious. First off, many grains are highly indigestible for both dogs and cats due to the fact that they aren’t natural to their biological diets. Carrots are used for carbs and fibre, and have no similarities to grains whatsoever. It’s comparing apples and oranges. As for by products, if a lion ate an animal in the wild, it would eat it’s meat, cartilage, some bones and organ meats. It doesn’t typically go for feet, beaks, and other obvious inedible parts of the animal. I study pet nutrition for my job. It’s great to find a dog or cat food that uses organs and cartilage, it’s super healthy. But the vast majority of the SOURCES for those things are sketchy and disgusting, at least in the pet food world. That’s why a food like Acana or Orijen is a great choice- they have branded what they do the “Whole Prey” concept. They use meat, cartilage, organs and bone in their recipes, but they source it ethically and so that its human grade. 98% of pet food companies outsource the manufacturing of their foods. And THATS where the problems start.

  • Trish Kobielski Hibberd

    Not to mention that these by-products are heated to such high temps, a wild animal wouldn’t touch them ever…

  • Natalie Gabaldon

    Clearly you should understand that wild undomesticated animals have higher tolerance and digestive systems, especially vultures who actually prosper on rotting flesh. Dogs that we have domesticated over thousands of years have become much more sensitive in a sense to intake meats that may have trace amounts of the euthanasia anesthetics used or overly rotten flesh…As I’m sure it would not kill our pets, over the years it must damage their bodies wear and tear internally.

  • Krista Mirci

    Meat meal is NOT,

  • Nightmare-Rex

    what do you do if no animal shelter around? we cant afford high quality food for our cats becuase we are dirt poor. live atleasy 70 miles from a shelter and human services are crap, bible belt is the WORST place to get any help for anything, ironic they goto church and say help others but then the moment out of church the first question is always… got money?

  • Brenda McKay

    This is a igreat information. It gives a more clear break down of by-products. You see some by-products are good for Cats and Ferrets. Liver, hearts and neck. Now from the description of food quality for Pet Companies the AAFCO (USA) and PFAC (Canada) do have a list that company are to follow. “What in pet Food”. I do not know if a Food inspector goes to Pet Companies to check on the quality or how often. I know even for human food I do not think the food inspectors go very often. The biggest inspection is in the importing/exporting to a Country. Thank you for this information. As for dead on arrival, road kill the pet companies are not to use that meat based on the info from AAFCO and PFAC.

  • Amy Rose

    Disgusting that any company can legally use rotting meat, and absolutely shocking that any company or nation would tolerate putting abandoned, murdered shelter pets into the food chain!!! Not just for obvious reasons, but some of the poison used to “euthanize” (keep calling it that) cannot be destroyed by the cooking process. Also amazing the lengths people will go to just to convince themselves that process grains (worse, artificial and inappropriate FILLERS or COLORING) are fine in pet food so they can go off and spend those extra bucks on shopping trips, ciggies or other self-indulgences. Such fillers are used SOLELY so pet companies can rake in a profit on people’s ignorance and lack of respect for their pet family members. Put the time in and research ingredients, stop being a blind consumer stocking up on cruddy supermarket brand food. I feel sorry for any pet owned by such a person. Here’s another difference about by-product — chances are that your pet wouldn’t touch gone-off rotting meat in its non-processed form. Once the pet food companies are done with it it’s been dressed up to smell like something good but it’s more like the quality of what’s in your cat’s litter box. My cats are 2 years old each, and have no health concerns, clean teeth, muscle, and play like they’re still kittens. Also, did someone seriously compare pets to vultures? Just wow. So glad anyone can acquire a pet these days.

  • Crazy4dogs

    Or they could use better, more biologically appropriate ingredients and pocket less profit.

  • DogFoodie

    OK? Objection. Non-responsive.

  • RadRadRudy

    “Even some of the super-costly veterinary and prescription products contain these low-cost meat ingredients. Why the extra cost?”

    Prescription veterinary diets are formulated for specific needs and ingredient requirements. For diabetes, kidney, or liver disease, the amount of protein, fat, and carbohydrates in the diet must be carefully controlled to manage both proper nutrition and disease abatement. It’s expensive because formulating a diet to those specific needs requires more work than just grinding up some meat and cooking it into kibble format. The foods have to have regular laboratory checks to ensure that they fit the necessary constraints to ensure proper formulations of amino acid content, etc.

  • RadRadRudy

    Not only that, but the Vitamin A in kidneys is more bioavailable to animals than the vitamin supplements added to “by-product free” dog foods. In order to meet the standards of vitamin, mineral, and nutritional requirements, many “organic” and “natural” pet food companies have to add those vitamins at the very end. Isn’t it more natural to eat those vitamins directly from the source even if they sound unpleasant to our human ears? Yes, of course. Veterinary nutritionists know this well and the research supports it. Companies like Blue Buffalo thrive on marketing, but the truth is that animals can’t survive on just animal muscle; animals require a diverse source of nutrients to thrive and that includes most parts of a chicken, cow, etc. Remember, many human societies such as Native Americans are lauded because culturally they did not “waste” any parts of the beasts they killed.

  • Vicky Wolf

    I was thinking the same thing at first, but I realize that the dogs are not animals created by nature, they were created by men. In nature predator animals kill animals that live in nature as well, which are much healthier so their organs won’t be unhealthy. Animals raised in farms on the other hand are full of GMOs and many times are sick and poorly handled. We are not there to see what these by-products truly consist of so why feed it to a family member?

  • Just Sayin!

    this video shows an AAFCO official admitting that regular pets are incorporated into the rendering process

  • theBCnut

    As far as by-products go, there isn’t a person here that wouldn’t feed their dog a healthy organ, but by choosing to go the route of calling it by-products instead of labeling the individual organs, they are allowed to follow practices that allow all kinds of unsavory things into the food, including expired meats. Generic ingredients can be really bad quality stuff. That’s not to say that dog food companies that actually list the individual ingredients can’t find ways to put nasty stuff in their food. They can, they are just less likely to.
    As far as grains go, if your dog doesn’t have any health problems, then grains are just another carb and it doesn’t matter. If your dog has any inflamatory disease going on or food sensitivity, then grains can be inflamatory and they MAY need to be avoided. The biggest issue is that dogs were not meant to eat diets that are soooo high in carbs and that goes for any high carb diet, but the worst offenders are usually grain inclusive because they are the cheap foods.

  • deelight821

    If an animal is wild (like lions and cheetahs etc) and they make a kill, don’t they eat just about everything? Including some of the things that are called “by-products” when talking about pet foods? And whatever is left after the big wild carnivores finish is pretty well cleaned up by vultures, who seem to thrive on it. so, I just don’t get what the big deal is if those by-products are part of pet food. I;m not too sure about the grain, but what’s the difference between grain and carrots and fruit that are listed in some of the “good” pet foods?

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  • Shawna

    I sure will!! :0)

  • keleee

    Shawna, Thanks and I’m sorry I didn’t have the story right. If you know of anyone in need pass it on 🙂

  • Shawna

    Hi Kelly,

    That is wonderful information.. I didn’t know that..

    My post was a little misleading – I don’t actually “need” assistance. I feed my dogs a high quality raw diet – mostly organic but not always “free range”. Shameless was able to feed her pup organic AND free range. Unfortunately her post is not showing so you were not able to read my post in context. BUT, I will definitely keep your information in mind…

    Thank you!!!

    PS — That was SO very kind of you to help out your friend like that!!!!

  • keleee

    If you have an animal shelter nearby and tell them you can’t afford organic food for your dog and he or she has allergies they will give it to you for free. If you don’t drive they will even drop it off. They have contracts with Petco etc. and get all the dog food that is nearing it’s expiration date for free. Petco also donates so much to shelters in the area. I have a friend who’s dog was on Beneful and her skin was a mess. She had hot spots all over her. I bought her a bag of Castor and Pollux/ Organix and within a week her skin was almost healed! He went to the shelter and is now getting Organix for Brandy for free. Just thought this might help…
    Kelly 🙂

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  • Shawna

    I was researching for another article but came across this and thought it was appropriate for our previous discussion. This paper does specifically say “moist heat processing” and I have no idea if “moist heat processing” is the form of processing in kibbled foods??

    “Lysine is an essential amino acid that can be particularly sensitive to the conditions of moist-heat processing (3). These conditions favor the formation of Maillard reaction products, and lysine is commonly involved in these reactions. The epsilon amino group of lysine reacts with the carbonyl groups of reducing sugars and forms a product complex that cannot be digested or absorbed in a form usable by the animal (4). Because of its specific susceptibility to this type of processing damage, lysine shows a decreased bioavailability relative to that of other amino acids (5).

    The results of this study indicate that the lower growth rate of kittens fed heated casein reflects a decreased bioavailability of lysine in heated casein resulting from heat-processing damage. We conclude that the growth assay method is a satisfactory method for estimating amino acid bioavailability in the kitten. Using this method to estimate bioavailability of other amino acids may help us to better understand the effects of various processing procedures on overall nutrient bioavailability of commercial feline diets.”

  • Shawna

    I’m obviously having issues with spelling today… Her little body and all my friends know.

  • Shawna


    I’m SOOOO jealous!!! I can and do get organic for my fur-kids whenever available but the only one in my family that gets free range regularly is my grand daughter.. He little body is still developing so, only the best for her 🙂

    All my friends, co-workers etc no I raw feed and several of them hunt so I do get free range venison (organs and meat) fairly regularly. Actually picking some up from a rescue friend this coming Sunday….

  • ShamelessRawFoodie

    Shawna – Interesting JOURNAL OF ANIMAL SCIENCE document you found. Makes me want to find some raw free-range pork lung and pork liver for my dog. My farm (Non-local, but they deliver throughout the state) has grass-fed beef organs always available, so I’ll ask about raw pork organs.

  • Shawna

    THANKS Gordon!! Much appreciated 🙂

  • Gordon

    Shawna – I think I love you!, lol. Got to go now. My shift is finishing.

  • Shawna

    Last post got too long so breaking up into two.

    Thank you very much, Aimee, for bringing the taurine misinformation to my attention. Because cysteine is one of the precursors to taurine in dogs and cysteine is damaged by heat – I assumed (and have read articles stating) the same was true with taurine.. Apparently that is not the case. This is a 60 page “Petition” on the USDA’s website ALL about taurine. Very interesting. I only made it to page 30 however. I found it interesting to read that certain foods (barley, rice bran) have been “implicated in lowering circulating taurine”.

    “Dietary requirements for taurine are also greater for high-moisture processed pet foods (e.g., cans, pouches). Heat treatment does not destroy taurine; rather, its loss is thought to be due to an increased taurine degradation by intestinal bacteria and/or loss through increased bile acid conjugation. Vegetable proteins and grains have very low to non-detectable levels of taurine. Some have even been implicated in lowering circulating taurine (e.g., rice bran, barley, isolated soy protein). Given these challenges and ingredient options, synthetic taurine (2-aminoethanesulfonic acid) is often required. (Aldrich, 2008)

    Whereas heat processing may indeed explain some of the difference, this is not believed to be related to de creased absorption of dietary taurine but rather to an increased excretion of tauroconjugated bile acids (Hickman et al. 1990). Further, based on recent reports, it is now believed that when canned diets are fed there is an increase in taurine degradation by the intestinal flora.

    From an evolutionary standpoint, taurine was plentiful in the diet of a true carnivore, as high concentrations of taurine are found in muscle tissue. However, as most domesticated felines normally do not consume living prey, they are at risk to become taurine-deficient if not adequately supplied in the diet. (Spitze, Wong, Rogers and Fascetti, 2003)

    Most animal tissues contain high concentrations of taurine, particularly muscle, viscera and brain, whereas higher plants contain no measurable taurine.(Spitze, Wong, Rogers and Fascetti, 2003)”

    I did find this one assay discussing raw by-products versus “rendered” by-product meals.

    “Formulating companion animal diets that contain high-quality protein sources is an extremely important
    part of good nutrition. These series of bioassays were conducted using broiler chicks and roosters to determine the protein quality of various raw and rendered animal by-product meals. Raw animal by-products tended to have excellent protein quality, whereas, rendered animal meals tended to have medium to poor protein quality.

  • Shawna


    I agree with all you say about BV.. Soy can be better utilized when combined. However, wouldn’t that combination create even more unusable AA unless done very carefully?

    I agree that raw diets have been found to increase BUN. However, I don’t know what they were compared to (I haven’t read the study). If compared to a low or lower protein kibble then this would be expected. I do know that only “high quality” proteins are suggested for patients with kidney disease. And, that reducing the protein is not advisable until symptoms warrant.. My Audrey has lived, quite healthfully, for 5 years with the disease on a raw, high protein diet.

    You wrote “<> I would think the biological value of a quality by product like kidneys and liver would be very comparable to meat. Considering what passes as meat in commercial foods, I’d think the by product may be the better deal in some cases.”

    Again, couldn’t agree with you more. However, I’m not sure of the quality of the by-products used. I mentioned, in a comment to Richard, that I feed these same foods (kidneys, liver, brains, gizzards and hearts – as well as chicken and turkey necks and beef bones for knawing on) to my dogs. I purchase these from my local grocery store.. If these are sold at the standard grocery store, in specialty grocery stores and to the commercial raw manufacturers — then what ends up in kibble? My concern is not that they are used but rather the quality of what is used. I’m sure there can be a huge difference from batch to batch and brand to brand.?

  • Gordon

    Dr. aimee – You’re starting to make more sense in some of your posts content above, :p

  • Gordon

    Shawna – I’m not surprised that your dog’s kidney disease has been able to cease its progress by way of an evolutionary diet in raw as Nature intended. Good for you and your dog! 🙂

  • aimee

    I’m assuming you are referring to biological value (BV) of different protein sources. BV is a quirky measurement. You could take two protein sources each with a poor BV feed them together and get a high combined BV as long as the AA profiles complement each other.

    Any protein in excess of needs no matter what the BV will be used for energy and the N excreted. The study by Dodds Winn and Bartges documented higher BUN levels in dogs on high protein raw meat based diets vs. those on commercial food for this reason.

    Since by products and meat meals vary greatly in composition it would seem that the BV may also vary. The study I provided does list full AA profiles and measured digestibility of each AA individually for each of the different test diets. From that raw data you may be able to calculate out the information you are looking for. I don’t offhand know of any controlled study comparing fresh meat to commercial except for the Winn study which compared raw ground rabbit to a commercial diet. The growth curves of the kittens were the same no matter which diet was consumed.

    You wrote “Eggs have a bioavailabilty of 100% while soy is something like 56% — 44% of the protein (amino acids) in soy is wasted.” Not necessarily if complemented with another protein source that supplys the rate limiting AA’s.

    <<>> I would think the biological value of a quality by product like kidneys and liver would be very comparable to meat. Considering what passes as meat in commercial foods, I’d think the by product may be the better deal in some cases.

    Just semantics here, but my understanding is that heat can cause cross linking of AA that may not otherwise occur rendering them no longer susceptible to proteases so digestibility can decrease. Additionally some AA’s are more likely to participate in Maillard reactions. I believe Lysine does this.

    Taurine is a free AA and as such can be lost in “drippings” when meat is cooked or ground. It isn’t damaged in any way by heat BUT it is how the other components of the diet are altered that changes the way it can be utilized. The process is a bit complicated and took a good bit of research to elucidate. The end result is that Taurine must be added back in cat diets.

  • Mike S -Mike S. –
    I agree with all points so far, including your suggestion to look at the bigger picture –

    -who wants their dog to ingest pentobarbital in their food on a daily basis?

    -who wants to gamble that there might or might not be some toxic “denaturing” chemicals present in the “food” they feed their dog.

    -what does the presence of pentobarbital in an animal say about the quality of the protein source to begin with?

    Along the lines of looking at the ‘bigger’ picture perhaps it might be wise to greet the recommendations of the ‘experts’ with a large degree of skepticism. These ‘experts’ not only allow this to go on but continuously try to tell us it’s acceptable, or help those involved cover it up. After all, these things we are discussing are not secrets to AAFCO, the FDA, or the pet food industry giants or local officials who ‘regulate’ these things.

    When I began to examine the dog foods that came into our store that I was recommending to my family of customers and found discrepancies or misleading marketing practices it made me look at the bigger picture behind the initial ‘lie’ or problem. My thinking was if a company is putting out intentionally misleading information or is attempting to deceive in one area then what else is it willing to do? Unfortunately I was so disappointed with what I found that we decided to make our own dog food in an effort to actually know what was in the food and what was not. As you said, “What does the presence of sodium pentobarbital say to you about the source of this meat?”…and along those lines “what does the presence of this overall situation” say about this industry in general?

    The presence of pentobarbital, the ‘denaturing’ chemicals, or the Ethoxyquin is just the ‘smoke’…and where there’s smoke…there’s usually fire. So the fact that so much is being glossed over or presented as though it’s not really serious means that these men, whether they be disguised as AAFCO members or FDA officials or local regulatory officials are all very complicit as far as I’m concerned. Does anyone really think for one moment that they are blissfully unaware of what is actually going on in this industry? It’s a sad state of affairs and the final conclusion that I came to is that if we want to be certain that we are doing the best for our dogs (and our families) then we had better take matters into our own hands and stop relying on AAFCO, the FDA, or the ‘officials’ at ANY level to keep us safe.

    I know it seems self serving to say that all these conditions are why we created Brothers Complete, but that IS why we decided to do it. We wanted to have a food to recommend that was as close to what it ‘should’ be as was humanly possible and that we controlled as much as was possible. Can even I be absolutely certain that someone along the supply line is not cheating in what they supply us or lying to us?…no I cannot…but I can promise that I will do everything in my power to try to ensure that it is what I say it is and if I find out differently at ANY point along the way, I WILL take whatever steps are necessary to remedy it.

    I can only change myself and I can only create change by starting with myself, my family and my work. This is our work and we are trying to make a change for the better. I more than probably anyone here can totally understand why dog food manufacturers are met with so much skepticism. I do not hold a grudge against anyone who is skeptical – I am skeptical with them. But like everyone here – I am here to try to help our furry friends FIRST and foremost…we must start somewhere.

  • melissa

    Oh wonderful! Looks like they are trying to play the “green” card as well…afterall, they are saving the environment from “hundreds of tons” of dead pets that would otherwise end up in the landfill. Since everything is cooked and rendered together, I would find it highly unlikely that pet animal remains are kept seperate. How nasty,

  • Shameless and Michelle

    The major problem was a super tired Richard trying to use an iPad which won’t allow me to go back to reread what I wrote when my fingers were moving faster than my brain but also sometimes missing the mark. It is true that the mystery letters ‘rut FHA iAds’ were supposed to be ‘euthanized’ and instead of the o in dog I accidentally hit the i key beside the o key. I was trying to type too fast to get it done before I fell asleep, but in the future I might be better off waiting until morning.

  • ShamelessRawFoodie

    Michelle – I also wondered about Richard’s ‘rut FHA iAds’ and figured that his iPad must have really done a number on the word ‘euthanized’. Also weird how ‘dog’ became ‘dig’. :=)

  • Michelle

    Richard, lol your step dad was a valet. I’m still trying to figure out what a rut FHA iADS is / are? You are right, I was wondering what was up with you, until I read your second post.

  • Michelle

    Shameless, yes! I agree that those two statements seem very contradictory. Also, they only mention dry dog food, what about canned? Would canned contain higher levels? Looks like LA county admitted to sending dogs and cats off to the render. BUT THEY DON’T END UP IN PET FOOD. WINK. WINK. Disposal (Rendering) of Deceased Animals from
    Los Angeles County Animal Shelters
    The disposal of deceased animals from County shelters is an emotional and often misunderstood process. This information is provided to answer the majority of questions regarding the disposal of shelter animals.
    What happens to the bodies of the animals that are euthanized at County shelters? Deceased animals are picked up by D&D Disposal, also known as West Coast Rendering, located in Vernon, Calif. The remains are rendered into animal by-products. D&D processes hundreds of tons of animal carcasses, tissues and by-products that would otherwise end up in landfills.
    What in involved in the rendering process? Rendering is a means of recycling animal remains. The remains are placed in large vats and heated to a high temperature in excess of 265 degrees Fahrenheit, at which point they become sterile and free of pathogens. Then a series of mechanical process occur that separate the fat, liquid, and proteins into separate collection systems.
    The majority of rendered materials are remains of cattle, hogs, poultry, and sheep – the parts that cannot be sold for meat, leather, or other products. Other animal remains, such as butcher scraps, restaurant grease, fish, zoo animals, marine life, and animals from shelters are rendered as well.

  • ShamelessRawFoodie

    Shawna – I agree, it’s best to avoid toxins as much as is possible. And yes, it certainly is the cumulative effect of these toxins that can result in long-term health problems. A massive toxic dose can cause instant harm or death. But tiny trickles of toxins can result in serious harm that isn’t quickly noticeable. Who wants that? Not me!

  • Hi Everyone… I’d tend to be less concerned with the presence of barbiturates in a meat meal ingredient as I’d be with what its presence implies about the condition of an animal that required it to be euthanized in the first place.

    Think about it. What does the presence of sodium pentobarbital say to you about the source of this meat? What could possibly cause anyone to defend any ingredient that could include such a drug? Does this still sound like a legitimate (healthy) component for making (human or pet) food?

  • Shawna

    “Raw Real Organic and drug free foods are looking better and better huh Shawna?”

    SOOOO true Gordon!!! Glad I’ve been feeding this way for a long time!!!!! My youngest pup was born with kidney disease and turned 5 last June.. I do my best to keep the toxins in foods as well as the environment (that I have control over) as limited as possible… She’s 5 and disease has not progressed so think I’m doing pretty darn good with her :)…

  • Gordon

    Raw Real Organic and drug free foods are looking better and better huh Shawna?

    Dr. aimee – You’re an angel compared with Dr. Brennen McKenzie. What do you think of his literature? Apparently, there is absolutely nothing to be concerned with regard to artificial preservatives, colouring, grains – all types, generic meats etc etc in dog food. Makes you look like an angel, lol.

  • Shawna


    I thought you were serious!! I read with lower jaw nearly hanging to the floor. Til the last sentence… Phew 🙂

  • Shawna

    Hi Aimee,

    I think that was actually Shameless you quote..

    Often times even “tiny amounts” of an ingested substance can accumulate and cause problems down the road. Monosodium glutamate and aspartame are prime examples. Not only the asparatic acid in aspartame but also the methanol.. Symptoms can show up long after even small amounts are ingested on a regular basis.. I don’t KNOW if this holds true with pentobarbitol but I don’t plan on letting my dogs be test subjects :)… Ethoxiquin is another — small amounts over time caused liver and kidney disease. Ethoxiquin is still allowed in foods.

    The study you site is interesting however, it discusses digestibility versus bioavailability.. They are now in the process (last I heard) of “hydrolyzing” (enzymatically breaking down) feathers to use as a protein source for livestock (and eventually pet foods so I’ve read). If enough enzymes are present, any protein can be broken down to amino acids and digested through the walls of the digestive tract (in the study they refer to the ileum) and into the bloodstream. Once in the bloodstream, however, things are very different. Soy, as an example, has all the necessary amino acids for human health and is very digestible. But, soy amino acids are not highly bioavailable — used by the cells of the body. Much of the amino acids from the protein in soy becomes waste product in the blood for the kidneys to filter out. Eggs have a bioavailabilty of 100% while soy is something like 56% — 44% of the protein (amino acids) in soy is wasted. By-products are in the same category as soy — digested well enough but not utilized on a cellular level. It really doesn’t matter how many amino acids are digested if the cells of the body can not use them.

    I would agree that temperatures play a big role — several amino acids are damaged by heat.. Since amino acids are used synergistically by the body, damage to some amino acids would prevent others still healthy from being utilized. Taurine is so damaged that it MUST be added back in to cat foods to prevent heart disease. Proteins are actually not as important as the amino acids that make up those proteins..

  • aimee

    Hi Shawna,

    Here is a link to an article comparing fresh to rendered ingredients. The full text is available. There was not a significant difference between the protein digestion of rendered meat and bone meal and fresh beef but there was a difference between fresh poultry and poultry by product meal. The authors suggested this may have been due do a difference in composition of the two products or the rendering process itself.

    I’d think that there could be a lot of variability here depending on the composition of the ingredients compared and also on the temperatures used during rendering.

    Shawna wrote “How is it “highly unlikely a dog consuming dry dog food will experience any adverse affects from exposures to the low levels of pentobarbital”, but “Scavenging animals may ingest the pentobarbital and become ill or die”.
    These 2 statements seem contradictory !?!?!?

    This is the age old “solution to pollution is dilution” The tiny amounts present in commercial food are broken down by the body vs a one time large ingestion causing toxicity.

    Not that I’d want pentobarbital in my dog’s food…. but realistically we take in a lot of unwanted chemicals on a daily basis. Anymore seems like everything is polluted and diluted…as Shameless pointed out!

    Seems the best way to avoid pentobarbital is to avoid those generic meal meals and fats presumably from independent renderers who accept a variety of “raw material”

  • ShamelessRawFoodie

    Yessireee Gordon – All the low-level pentobarbital is surely safe, because government says so…….. just like fluoride mass-medication in tap water, and formaldehyde additive in cattle feed. Synthetic hormones, antibiotics, pesticides, fungicides – No problem! Those of us who refuse to be hoodwinked…… well, I’m thankful. Unfortunate for the masses… a lie told often enough becomes the truth!

    Professional Perspectives – Fluoride and Medical Ethics
    “… fluoridation is neither safe nor effective.”
    FREE to view this week August 7 through 13 – Fluoride Awareness Week
    More info –

    Food Additive Regulations Amended – Formaldehyde
    In the November 21, 2003, Federal Register, the FDA announced that the Agency is amending the food additive regulations to provide for the safe use of formaldehyde to improve the handling characteristics of canola and soybean oilseeds and/or meals in feed for beef and dairy cattle, and to provide a description of the food additive. This action is in response to a food additive petition filed by Rumentek Industries Pty Ltd.#

  • Gordon

    Shawna – Small traces of pentobarbital will be just fine. It won’t hurt your dog. Dogs, will, you know, just evolve and become pentobarbital dependent and it will eventually become a necessary and beneficial nutrient for dogs. Just ask Dr. Brennen McKenzie, lol. Sorry, I just can’t help myself.

  • Shawna

    The US Fish and Wildlife Services disagrees with the FDA about the small amount not being an issue…

    “Rendering is not an acceptable way to dispose of a pentobarbital-tainted carcass. The drug residues are not destroyed in the rendering process, so the tissues and by-products may contain poison and must not be used for animal feed….

    All pentobarbital-euthanized carcasses should be prominently tagged with one or more highly-visible “POISON” warning labels. Bagged animals should have a label affixed to the carcass itself and also attached to the outside of the bag.”

    I wondered if dairy cattle and veal calves would be euthanized — found several articles stating yes. One stated that as many as 25% of dairy cattle are euthanized.

  • melissa

    It would not be “regular practice” to euthanize cattle via injection. Most times, even today, if a farm animal goes “down” the method of disposition is shooting. However, where then does the phenobarbitol come from?

    My guess would be horses. Not sure what they do today since many regulations have changed, but up until several years ago, if your pet horse was euthanized by the vet, you called a “rendering plant” and they would come take away the body. Unfortuently most people do not have the equiptment to bury a horse and the cost of rental is prohibitive-Not sure if they still do this or not as I have never had the need for such service nor would I ever have considered it.

  • Shameless and Michelle

    My step dad was NOT a Valet but rather a Vet. or Veterinarian. This program on iMac ends up replacing words, or in this case an abbreviation, is does not recognize with words it does, and I was typing late at night on my iPad so didn’t proof read it. It does come up with some interesting words at times. Anyone reading that post above must be wondering what the devil I was thinking. Actually, I wonder that at times myself.

  • R.Hankins

    Is there a blood test to check to see if your dog has pentobarbital in their system? If they do, can anything be done to clear it? ( other than possibly changing dog food.)

  • Shameless and Michelle

    There has been pentobarbital in the food chain for a long time now. My step dad was a valet for 50 years and years ago he told me of an experience he had when he stayed after the clinic closed and had a dig to euthamize. I think it was an old Yellow Lab and he gave it more pentobarbital than he thought was necessary to be certain the dog would die painlessly.bye had his back to the table when he heard a commotion behind him only to turn around and see the dig that should have been dead trying to stand up. This was 35 years ago and the Vets were the ones who finally said there was a problem because the dogs were developing an immunity to pentobarbital which could only happen if they were ingesting it over generations. So the question as to whiter or not they are using rut FHA iAds dogs, cats, and other animals in dog food is not really a question of if but rather which ones.

  • ShamelessRawFoodie

    Good question Michelle – I wouldn’t have thought it was a regular practice to euthanize cattle! But my quick research seems to indicate otherwise. Here is one of many government documents I found on a google search:
    Disposal (Rendering) of Deceased Animals from Los Angeles County Animal Shelters
    Animal Rendering Fact Sheet
    April 8, 2004

    Middle of page 2:
    Is the euthanasia agent, sodium pentobarbital, found in pet food?
    Sodium pentobarbital (pentobarbital) is not completely degraded during the rendering process, and minute portions may be found in pet food. However, the FDA/CVM’s 2002 study stated, “the pentobarbital residues are entering pet foods from euthanized, rendered cattle or even horses.”
    Additionally, the levels of pentobarbital residue were found to be so low that the CVM concluded that “it is highly unlikely a dog consuming dry dog food will experience any adverse affects from exposures to the low levels of pentobarbital.”

    Bottom of page 2:
    What alternatives to the rendering process are available for animal disposal? Right now, there are none. It is less safe to bury euthanized animals in landfills because the sodium pentobarbital is still present in their bodies. Scavenging animals may ingest the pentobarbital and become ill or die (recently, a number of bald eagles were found to have died from this source in the U.S.).

    How is it “highly unlikely a dog consuming dry dog food will experience any adverse affects from exposures to the low levels of pentobarbital”, but “Scavenging animals may ingest the pentobarbital and become ill or die”.
    These 2 statements seem contradictory !?!?!?

  • Michelle

    Shameless, do you think it would be a regular practice to euthanize cows? Wouldn’t it be cheaper to just slaughter them? I’m sure that euthanized animals end up in dog food though. So gross. I took my 2 dogs to the lake today, for some reason as I threw their balls into the water, for them to retrieve, and watched as they happily ran, splashed, and swam with some of their doggie friends, I found myself thinking about all the dogs, and other animals that, at that very same moment, were locked up in cages, being “experimented” on or being used in research….. made me really sad.

  • Shawna


    “Guess your medications kicked in by the time you read my comments LOL. Only kidding.”

    Game point goes to Sandi.. Balls in Shawna’s court.. What will she do??? Hee hee hee hee hee

    Gotta leave for a funeral. I sound so non-chalant —- the parent of a co-worker. Didn’t really know but going for support…. 🙁

    Have a great night!

  • Shawna

    GREAT find Shameless,

    This led me to think — if beef “meal” could contain euthanized beef then surely, as I suspect, other meals could contain 4D.

    Per Wikipedia
    “Because meat can be rid of infectious agents through the rendering process, “4D” animals (dead, dying, diseased or disabled) are allowable chicken meal ingredients. While not always present, the possible inclusion of these ingredients makes chicken meal always considered unfit for human consumption.”

    MANY of the super premiums use “meals”.. Boy am I glad I feed raw 🙂

  • ShamelessRawFoodie

    Thanks Shawna for the FDA link which substantiates that a named meat source (BEEF) can include euthanized animals. I copied one of the Nutro test results below.
    Dog Food Survey Results – Survey #1, Qualitative Analyses for Pentobarbital Residue
    Dry dog food samples purchased in Laurel, MD, area, March – June 1998
    The ingredients Meat and Bone Meal (MBM), Beef and Bone Meal (BBM), Animal Fat (AF), and Animal Digest (AD) are rendered or hydrolyzed from animal sources that could include euthanized animals.
    Rendered ingredients (position in ingredient list) Beef Meal (1)
    Confirmed for the presence of pentobarbital? yes
    Brand Name – Nutro
    Formulation Name – Premium
    Lot Number – 10:19 2AR7JJ

  • Shawna writes: “How is it that you manage to crack me up to the point of tears on a fairly consistant basis!!!”

    Guess your medications kicked in by the time you read my comments LOL. Only kidding.

    I doubt very much others will be more active. Remember, acting as your agent, I get 10% of what you earn :).

    I know you’ll enjoy Mike’s group. Mike is working on improving his website. If you have any suggestions, Mike is open to them.

    I just have to figure out a way to get Mike to put together a team & be involved in attending the AAFCO meetings. Check out Sandi August 6, 2011 at 9:49 am

    It’s hard most of the time to remember where comments were posted on which brand or article, so don’t feel bad if you can’t find what you wrote. RE: AAFCO, I’m keeping the comments on Richard’s page. BTW, I met Richard in person at his store in Ft. Lauderdale, Fla. I was at The Doggy Store years ago. This time I met his whole family. He’s a great guy and extremely knowledgeable. I know you’ll both hit it off.

  • Shawna


    THANKS 🙂 How is it that you manage to crack me up to the point of tears on a fairly consistant basis!!! 🙂

    Thanks for that awesome vote of confidence!!!

    I read your “you know where” post 😉 Hoping my absense will encourage others to be more active… Time will tell… Talk more soon I’m sure!!

  • We are all very lucky to have Shawna join us (Shawna – I just posted you know where).

    If Shawna ever needs a letter of recommendation, she won’t be hard pressed. If she doesn’t know the answer, Sherlock will find the answer, believe me. You can trust what she writes!!!

  • Shawna

    Mary Lou,

    That is soooo very kind of you!! Thank you so very much for the kind welcome 🙂

    Mike has done a wonderful job with this site and I look forward to reading more of his reviews.. And replying when I have an opinion 🙂

  • Mary Lou

    Shawna ~

    Sooo happy to see you on here. I hope you become a mainstay! : )

  • Shawna


    Great information — THANKS a bunch!!

  • Shawna


    Thank you so very much for your kind welcome… And, PLEASE, don’t feel even a tiny “bit silly”.. You provided GREAT information!!

    I would dearly love to talk more in private 🙂 Give me a moment or two to look up your food/s ingredient list and guaranteed analysis and then I will email you.

    My email starts out [email protected]……

    Looking very much forward to talking more privately!


  • aimee

    Shawna wrote “They do not identify which ingredients however contain 4d — imo, named as well as non-named meat sources can include 4d tissues..”

    That is the same conclusion I came to. Some AAFCO ingredient definitions specify that the material comes from slaughtered animals so by definition that ingredient can not contain 4D. In general it seems that fresh products, both meat and by product specify material from slaughtered animals.

    In regards to what needs to be denatured the regulations are hard to follow. There are provisions for the removal of product without denaturing if it is labeled and transported to a facility that will render it, or to a facility that only makes inedible product. This combined with large integrated processing plants which render on site would seem to make using a denaturant unnecessary in a lot of circumstances. But when a denaturant is used for animal food a colorant instead of a toxicant is used. This seems most commonly done when 4D is salvaged as raw meat for animal food.

  • Shawna

    I feel a bit silly having giving you advise on nutrition when it appears you are a wealth of knowledge on the topic. I would really love to chat with you personally in more detail if you are open to that. I totally agree that whole, raw food (with some supplements) is the absolute best thing for a dog. However, in years of trying to educate and convince dog owners that come to our store for dog food that this is so, I find that the vast majority of people just won’t go there for one reason or another. We still try but as a pragmatists my family and I wanted to design the best possible dry food for the dogs that won’t get raw, although we still try to get them to at least feed one meal a day raw and the other kibble.

    It’s been a long and winding road but we are committed to making Brothers Complete the absolute best it can be and I think you might be able to help us improve our food even more if you would be willing. If you are interested please email me at [email protected] and give me some contact information so we can chat. If there is any way you think that Brothers Complete dog food might be improved I would absolutely want to hear it.

    Thanks again for such thorough, detailed and well thought out posts. It’s been a real pleasure.

    I sincerely hope you will join us here on DFA more often as it seems you have much to contribute.

  • Shawna

    I also don’t think it is identified which ingredients can use 4d products… It is well known and established that the “bone hole” at meat packing plants also holds diseased tissue that is not fit for human consumption — cancerous tissue as an example.

    The FDA specifies which four ingredients are known to include pentobarbitol — these are beef and bone meal (a named source), meat and bone meal, animal fat and animal digest. I included the FDA link on this in one of my previous comments.

    They do not identify which ingredients however contain 4d — imo, named as well as non-named meat sources can include 4d tissues. In several states they have rendering plants that only process cattle — as an example.

    From the FDA’s website (link at the end)
    “*CVM is aware of the sale of dead, dying, disabled, or diseased (4-D) animals to salvagers for use as animal food. Meat from these carcasses is boned and the meat is packaged or frozen without heat processing. The raw, frozen meat is shipped for use by several industries, including pet food manufacturers, zoos, greyhound kennels, and mink ranches. This meat may present a potential health hazard to the animals that consume it and to the people who handle it.*


    *Uncooked meat derived from 4-D animals is adulterated under Section 402(a)(5) of the Act, and its shipment in interstate commerce for animal food use is subject to appropriate regulatory action.*”

  • Shawna

    OHHHH, they also sell the “stomachs” in grocery stores — for human consumption. White tripe.

  • Shawna


    I’m not sure that is 100% true however I don’t know much about the denaturing process – when used, when not etc.

    “the nature of by products (viscera, lungs) are naturally inedible and so do not require denaturing and the regulations cited”

    Wikipedia says about by-products
    “The non-rendered, clean parts, other than meat, derived from slaughtered mammals. It includes, but is not limited to, lungs, spleen, kidneys, brain, livers, blood, bone, partially defatted low temperature fatty tissue, and stomachs and intestines freed of their contents. It does not include hair, horns, teeth and hoofs. It shall be suitable for use in animal food. If it bears name descriptive of its kind, it must correspond thereto.”

    Notice “kidneys”, “liver” and “brains” — each of these foods I have been able to purchase at my local grocery store for my raw fed dogs — in the human meats. As well as heart, tongue and gizzards.

    I used to purchase a dehydrated “lung” product from Whole Foods Supermarket. One day, after using for a bit, there was a green substance on the food — wasn’t mold but couldn’t identify. So I called the manufacturer and was told it was a product they had to use on meats etc not being used in the human food chain…??? If he was being honest with me then they DO use something on even lungs?? I quit using the product after that… YUCK

  • aimee

    I posted this on another thread and am copying here for people following this thread.

    Shameless cited text from the regulations “unless naturally inedible by humans, be denatured or otherwise identified” the nature of by products (viscera, lungs) are naturally inedible and so do not require denaturing and the regulations cite “otherwise identified” so not everything need be chemically denatured. From another section Shameless cited “9 CFR 314.3 provides that condemned carcasses or carcass parts that are not destroyed by incineration or processed into inedible rendering must be denatured”. So the carcass can simply be rendered without any need for denaturing with chemicals. If denatured “Denaturing is accomplished by the use of crude carbolic acid, or cresylic disinfectant, specified formula, or any other proprietary material approved by the Administrator.#” I think the key here is “any other proprietary material approved by the Administrator.#” The purpose of denaturing is to give the meat an off color or odor.
    I found that if the carcass is to be used for pet food “A different group of denaturants are used on inedible product condemned for human food but salvaged for animal food. This is because the above agents would make the product unfit for even animal food. Animal food denaturants include:-FD&C green color No. 3-FD&C blue color No. 1-FD&C blue color No. 2-Powdered Charcoal-Any compound approved for such use in the “List of Proprietary substances and Nonfood Compounds” book” This is why I posted earlier about meat being denatured with charcoal. Raw meat ground with charcoal is often utilized by the racing greyhound industry.

    Because AAFCO definitions for meat by product, poultry by product, poultry by product meal, chicken by product meal call for tissue from slaughtered animals (animals which passed an ante mortem inspection for humane slaughter for human food) these would not include “euthanized pets (complete with the pentobarbital that was used to put them down), road kill, dead, diseased, dying, etc as well as spoiled or rotting meat from the food industry” as Richard alluded to. Those types of things if present in meals used for pet food would be found in an ingredient such as meat and bone meal which has no specified source in its definition.

    DNA testing has failed to find evidence of euthanized pets in dog food but technically yes it is legal and conceivably could occur.

  • Shawna

    PS — I’m not opposed to the use of named meals in pet foods (most of the super premiums use them as too much whole meat would “gum up” the processing equipment) BUT I would also like to see whole meat sources as well.

    This website does a great job, imo, of discussing the difference between meals and whole meats.

    * More processed than fresh meat, already cooked and dried once before added to kibble “dough” and cooked again.”

  • Shawna

    Quick google search and I find — yes, they do euthanize cattle 🙂

    Thanks Mike and Richard

  • Shawna

    Hi Mike,

    I included this link to the FDA website in the comment section of your article on pentobarbitol in pet foods. You thanked me for the input. 🙂

    “There appear to be associations between rendered or hydrolyzed ingredients and the presence of pentobarbital in dog food. The ingredients Meat and Bone Meal (MBM), Beef and Bone Meal (BBM), Animal Fat (AF), and Animal Digest (AD) are rendered or hydrolyzed from animal sources that could include euthanized animals.”

    Notice “Beef” and Bone Meal (BBM)

  • Shawna

    Hi Richard,

    Meals are “cooked” twice while non-meals are cooked just once. Several amino acids are damaged by heat — tryptophan, lycine, cysteine, methionine and taurine (taurine so badly that it has to be added back in in an effort to prevent heart disease in cats. They now know that dogs are deficient in taurine as well. However they can “make” taurine from other amino acids (cysteine and methionine) so those amino acids are deficient too. Many dog food companies are adding taurine to their brands now as well as their cat foods.

    Along with damage to enzymes — antioxidants, probiotics and other nutrients are damaged as well.. Granted they add them back in but is it enough?? Example — in unprocessed or gently processed foods you will find 8 different forms of vitamin E (alpha, beta, gamma and delta tocopherol and alpha, beta, gamma and delta tocotrienol). To the fat they may add “mixed tocopherols” but to the whole food you usually only see either d-alpha or dl-alpha tocopherol — no other tocopherols and no tocotrienols. ALL forms of vitamin E are quite necessary by the body. They now know that it is one of the tocotrienols (I don’t remember which) which is a better cancer fighter then alpha tocopherol.. What don’t they know yet??

    I’m actully a raw feeder and even in feeding raw I add extra enzymes…. I COMPLETELY agree with their absolute necessity.. In between meals too — they know that proteolytic (sp?) enzymes can help many different health issues (like arthritis).. Good stuff….

    Probiotics are also an ABSOLUTE necessity and even when added to kibble are not enough.. And not just acidopholis.. Certain of the probiotics produce some of the b vitamins while digesting the foods we eat. At least one “per Penn State University” “primes” the neutrophil white blood cells in our bone marrow to be ready when a pathogen invades our bodies. A necessary part of the overall immune system… 🙂 I think there are 14 known probiotics in the dogs digestive tract. Most kibbles are lucky to add 4 of those.

    I also have a problem with the inclusion of omega 3 oils/foods in kibble. They certainly must go rancid long before eaten. Look at a bottle of flaxseed oil intended for human use — it comes in a dark plastic bottle, MUST be stored in the fridge, better quality ones have spouts that allow the oil out but prevent much air from coming in and must be thrown after only a month or two in the fridge.. How possibly could these oils survivie sitting on a shelf for any length of time let alone in a none airtight, often opened bag of kibble that is sometimes free fed?? I don’t see it personally….

    Your last paragraph I couldn’t agree with more!!! My youngest dog was born with kidney disease (congenital). I was a raw feeder before getting her and she too was placed on raw when she came to me at 9 weeks. At the time her only symptoms were polydipsia (excessive water intake) and polyuria (excessive urination). She is now 5 years old, as of June 28 2011, and her symptoms have not changed in those 5 years… The amino acids in raw foods are so biologically available that little is left to become blood urea nitrogen (BUN) for the kidneys to filter out… There is just no way, as I see it, that the best of the best kibbles would supply the same amino acid profile as the raw she gets. She is on a high protein, raw diet. She takes no medications (except vitamins and glandulars). She has never required veterinary intervention — except checking her bloodwork to determine the progression of her disease etc… BTW—I do feed my dogs (I have 5 of my own and foster — a total of 9 in my home most times, including right now) by-products — I have been able to find cow liver, kidneys, heart and tongue, chicken gizzards, hearts and liver and pig brains at my local grocery store — definitley fit for human consumption (not that I eat them myself however :)… Right now, however I feed commercially prepared raw as I find I don’t have as much time to make sure I am properly preparing their raw meals.. I teach pet nutrition classes at my local dog/cat health food store and am a very active member of Mercola Healthy Pets forum..

    Anyhoo, great dicussion!!! Thanks for your thoughts!! I couldn’t agree more with everything you state — except the amino acids in kibble 🙂

  • You can see how long it takes me to type a response if you realize that in the time it took me in answering Shawna’s 12:02 post there were four posts in between, including 2 by Mike. I should have taken that typing class in high school it seems – the Spanish class didn’t do me nearly as much good as the typing would have.

  • Shawna

    If you are referring to the “whole meats” that are listed on the ingredient labels of dog foods then they must first be turned into “meat meal” before they can be “extruded” (the first heating process) to become kibble (the second heating process). They basically list them as “whole” meat on the label to get them listed closer to the first ingredient spot since the order in which they are listed is by weight, and weighing them wet (before drying) makes them appear to have about 4 times as much meat as they will actually have once they are dried and turned into meat meal.

    Perhaps I am misunderstanding what you are trying to point out though.

    Even if the manufacturer gets their meat supply from a USDA inspected plant and uses only top grade meats the meat MUST be dried and turned into “meal” to be part of the mixed dry ingredients that will then be cooked again in the extruding process that basically binds all the ingredients together into a kibble. Either way if the meat is to become a kibble it seems it must be “cooked” twice.

    Also I’m not aware of the heating process destroying amino acids, although it may do some damage, but usually the main thing destroyed are the enzymes present in raw meat which are destroyed when heated to 118 degrees F. These include the digestive enzymes which I absolutely think are of utmost importance for the long term health of your dog. If the dog food you are using does not include digestive enzymes (almost all kibbles, but one or two, do NOT) then I highly recommend that you add them as supplements to the kibble you use.

    The probiotics that are often listed as included in the kibble must be “encapsulated” to protect them from having the moisture in the kibble from causing them to activate too soon and then dying before the dog ingests them. So, if they are not encapsulated, it would be wise to add them as supplements also.

    I guess my biggest concern with pet grade by-products is that they very likely may include some “denaturing” chemicals, regardless of whether the protein content is similar to named meat meal or not. Then you must decide if you think you can trust the rendering plant to keep the inedible “pet grade” by-products separate from the inedible “feed” grade by-products that include euthanized pets (complete with the pentobarbital that was used to put them down), road kill, dead, diseased, dying, etc as well as spoiled or rotting meat from the food industry. I guess you must ask yourself if you feel confident enough to trust these people, in their highly secretive plants, to do exactly what the regulatory guidelines suggest they do. Actually, even as I propose that question, I realize at some level just how absurd it sounds to me…but perhaps others feel differently.

  • Hi Shawna… I would imagine cattle could be euthanized using the same drug used to euthanize companion animals. However, I would suggest asking a vet for a more reliable answer.

    As far as beef. the FDA and AAFCO require the animal named in a label’s ingredient list to be exactly what it says. Beef. You may be confusing this item with “meat and bone meal”. This is completely different. This is a generic (anonymous) ingredient and can include whatever your mind can imagine.

    By the way, please don’t get the impression I’m favoring animal by-products in my report. For I can assure you, I’m certainly no fan of these lower quality meat ingredients. I’m just pointing out the real reason they’re so popular with certain manufacturers.

  • Shawna

    Thanks Mike!!!!

    In thinking it threw, I believe I answered part of my comment on “beef”. By-products are, my understanding, taken from the “bone hole” at the packing plant and therefore would come from animals that are (intended) for human consumption.. These are the parts/pieces that are not deemed fit for human consumption — euthanized animals would not be in this setting to begin with so not really a factor.

    However, i am still wondering if you know if cattle are euthanized or if the “beef” in beef and bone meal can be from animals other then cattle…

    Again, thanks a bunch!!!

  • Shawna

    One additional little bothersome thought in my head 🙂

    Beef being a named meat source?? The FDA’s website clearly states that “Beef” and bone meal is one of the 4 ingredients that can be contaminated with pentobarbitol… However, I’ve never heard of industry euthanizing cattle. I’m sure I don’t hear everything though..

    IF cattle are euthanized then wouldn’t “beef” by-product meal be as suseptible to the inclusion of pentobarbitol — it is a rendered product after all? OR, is “beef” a generic term that might include — say, horses?

  • Hi Shawna… Your point is well-taken. I’ve corrected that statement to make it more appropriate for the topic. Thanks for the tip.

  • Shawna


    This statement confuses me..
    “When comparing pet food grade animal by-products and whole meats, the differences can be nutritionally insignificant.

    For example, in the case of rendered ingredients, the digestibility, biological value and amino acid content of both poultry and poultry by-product meals are nearly identical.9”

    The study (9) clearly states that poultry “meal” is the food being compared to “poultry by-product meal” NOT “whole meats”. This is what threw me.. It is my understanding that whole meats are by far superior to named “meals” because many amino acids are sensitive to heat and “meals” are heated twice (once to dehydrate and second to form the kibble) while whole meats are heated just the one time – to form the kibble.. Therefore, whole meats should provide a better amino acid profile then either named meals or by-product meals.

    Do you know of any studies comparing “whole meats” to meals or by-product meals?

    Thanks for all you do!

  • melissa


    I was pretty much thinking the same thing. Denatured or decharacterized makes no difference to me- I don’t want it in my dog food(and I am still gagging at the thoughts of this process) I do not believe, Jonathan that decharacterization is simply adding “food coloring” to the inedibles. Food coloring would NOT cause the food to be unusable in the human food chain-however citronella, soap and dye would.

    I think everyone has to make their choices in life, but for me, I am going to have to be more vigilant about being sure that the foods contain NO by products, as I think its too difficult for the average pet owner to find out accurately and honestly who is using what types of by product meals. The other option, as we discussed would seem to be to verify that the foods are made at APHIS EU certified facilities. From everything I heard or read, it would appear that all ingrediants that enter these plants have to be made with human grade components. IF that logic is correct, then all the meals used would have to be named ingrediant and lack by products, hence one should be able to avoid denatured or decharacterized by product crappolla. Also, unlike other “certifications” it appears (from what I have found, if someone else knows differenetly, pls let me know!) that APHIS EU certification is only good for three months-meaning factories are continually reapplying, renewing, and hopefully being reinspected.

  • Jonathan

    I agree that it is most likely impossible for any of us, including me as a manufacturer, to really know which by-products are “denatured” and which are “decharacterized” although one is certainly extremely poisonous, neither process is anything close to healthy.

    According to the formula you kindly posted up above they can use carbolic acid or creosote (both are quite poisonous) to “denature” or one third detergent, one third citronella and one third water with food coloring to “decharacterize”. They don’t just spray a little on the surface either. They must inject it or slice the meat deeply and flood it.

    Now those aren’t odds I like. Two of the three possible processes are very poisonous and the third one is just eating a load of soap, citronella and food die. The problem is just as you have described it – we have no way of knowing when they use the poison and when they just inject it with soap, etc. I can’t say I’d ever put my dog at such a risk.

  • Michelle

    My understanding is that ANY by-product meal (named or generic) is most likely made with enough meat that is classified as INEDIBLE as to require “denaturing”.

    It can be a named meat by-product (such as chicken by-product) and still require denaturing because it is made with meat classified as inedible (for human consumption). The two classifications of inedible by-product meal (either named or generic) are Feed grade or Pet grade, but since both make use of meat classified as “inedible” then they both require “denaturing”.

    My question to Mike S earlier about a third designation for by-product meal that is EDIBLE was superfluous because no one would need to define edible human grade food as anything but a meat meal (such as Chicken meal) since edible grade by-products by definition are considered a meat meal because only nutritious parts of the named meat are included in the definition. It was very early in the morning and I opened my mouth before I drank my coffee and engaged my brain.

  • Michelle

    Jonathan or Richard, Is it just the by product meals that are denatured or decharacterized ? Or is it all named meats that are pet grade?

  • Sheila

    Just a quick note, perhaps this is off topic, but I am so happy I have access to Farm raised Beef & Lamb & Pork and Chickens and we live on a climate where there is local fruit and veggies 99% of the time. I usually avoid things that are heavily sprayed in the Winter, that come from Mexico and California( since my local Supermarket guy told me that there are 35 different sprays on Celery). I try to by Organic if I can. It is not legal to use pesticides anymore in most of our ARL., here. Most of the livestock is raised without antibiotics, no hormones. As I mentioned before, there were alot of things I grew up eating, but there was no such thing as coloring meats and hormones. Yes, Mike you are right, why should we have to pay more for products that are sub-standard. I won’t use Vet foods, I questioned a Nutritonist from Royal Canin about the Corn being GMO, she avoided the answer and just kept on saying what quality ingredients were in the food including the lung and spleen, cheap readily available by-products. I don’t think we can truly get the right answers, the industry is just too big and only a small percentage of people look at what the ingredients are in the food or where they might come from. I still think my “Aussie land dog”, lived well on chunks of fresh Kangaroo, lamb , Chicken and Rabbit when we lived there 35 yrs. ago. Not many want to take the time to go back to the basics. However, more people are becoming enlightened. I would love to hear the “real truths” from the major players.
    I have become so disillusioned since 2007, I am very happy that we have a website like yours to refer to, then again perhaps ignorance is bliss for some!
    Sorry, I don’t trust AAFCO or NRC either. I guess in the long run, those of us willing, can just do our best, I asked Champion Pet Foods(Orijen & Acana) where there rendered products came from, still waiting for an answer months later and I live in Canada!
    Thanks for listening,

  • Gordon

    I’ve got noting to add to this current debate as you guys are doing a pretty good job of it!

  • Jonathan

    Richard, what I was saying is I found that companies are allowed to “decharacterize” the meat rather than “denature” it. decharacterizing is nothing more than adding food color to the meat so that it can be readily identified as “not fit for human consumption”. I’m starting to think there are even more “levels” of inedible by-product meals, such as the difference between by-product meals that have been denatured as opposed to those that have been simply been decharacterized. The trouble is, how would any of us little people know?

  • Jonathan

    Creosote is so poisonous that in the north they treat telephone ploes with it and they last for 100 years in the ground. I personally can not trust that ANY by-products are NOT denatured after Mike’s helpful article. It makes it very clear that ALL “byproducts” are going to be sourced from enough “inedible” byproducts (even if some of the makeup of the by-products are not rotten, diseased, road kill, etc.) that they must be “denatured”. By helping clear up the marketing fog here Mike has helped me see that my initial concern when looking for a protein source was ligitimate in that all inedible by-products are going to be “denatured” with a toxic substance.

    The argument that the proponents of by-products have always touted has been that they are nutritionally equivalent. I heard it over and over in the pet food industry when looking for food sources. Mike has shown that two grades of by-products are different in quality and protein content…but even the pet grade by-products are not something I think should be fed to an animal given that both grades of by-products (Feed grade and Pet grade) are “denatured”. Emphasizing protein seems somewhat inconsequential when you think that the protein can be laced with creosote. It’s great that the protein might be equivalent to a quality meat but not when it’s treated with something like creosote.

    To me it’s just another slight-of-hand the pet food industry plays by getting you to look at the protein content while they spray it with a poison behind your back. When I see these kinds of “legitimate” practices that are harmful to pets I’m not surprised people are so suspicious of dog food manufacturers – and when the “officials”, whose job it should be to protect the consumer, make it convenient to hide the truth it doesn’t add any credibility to the industry either.

    A very wise person once said, “The truth shall set you free” and truer words have never been spoken. It’s really all we have to combat what often times seems like a conspiracy orchistrated by big money and Big Business/Gov. I guess since big business and the FDA is willing to poison people with any number of “legal” substances we shouldn’t be too surprised they are willing to poison our dogs.

  • Jonathan

    Richard, I have spent some time trying to figure that out. All the government regulations are very vague. They say that unfit for human consumption meats must be denatured or decharacterized. The latter is simply adding dye to the meat. But one of the two actions is required for transport of these products, so they are doing something with denatured meats…

  • Mike S

    So are both the official grades of by-product meals then treated with a “denaturing” chemical?

  • Mike S

    Thanks. That does make sense.

  • Hi Richard… The word “edible” refers strictly to foods appropriate for human consumption. My statement that there are only 2 officially recognized grades of by-product meals is correct. There’s no such thing as an edible by-products meal. No rendered meals are suitable for human consumption.

    However, before rendering, animal by-products can be either edible or inedible. Like all human grade food, edible by-products can be used to make either human or pet food. However, inedible by-products can only be used to produce animal and pet feeds. Hope this helps.

  • Hi Mike S

    I guess the people that are using the Edible grade By-products are also mixing them with the muscle meat, etc. so they actually can just refer to is as “Chicken meal” instead of “Chicken by-product meal” So I guess it doesn’t really come up in actual practice….so as Ruth used to say on Saturday Night Live…Never Mind.

  • Hi Mike

    Your very helpful diagram does clearly show the 3 levels of animal by-products. Two under “Inedible” (Feed grade and Pet grade) and one under “Edible” (Pet Food)

    I just wonder if the statement…

    “In the specific cases of chicken or poultry by-product meals, there are two recognized grades…
    * Feed grade by-product meal
    * Pet food grade by-product meal”

    …might be more clear if it reiterated what your diagram shows, which is three grades (the third grade being the EDIBLE by-products) – or at least qualified these two as, “In the specific cases of INEDIBLE chicken or poultry by-product meals, there are two recognized grades…”

    Perhaps it is just my own, sometimes excessive, desire to explain details – but regardless I do appreciate that you have spent the time and effort required to do the homework and put this topic on the table. It’s certainly an important part of helping dog owners get better food into their pets…so once again – Well Done!

  • Hi Richard… Although I didn’t specifically name edible by-products, they are implied where I recognize “edible” products when I state , “Giblets (livers, hearts, gizzards and necks) as well as other organs can be sold as edible meats or used generically to make hot dogs, bologna and sausage.”

    There’s nothing stopping these same higher quality by-products from being used to make pet food. For a clearer picture of this, look at the diagram I created to illustrate this fact. Note pet food is also listed as an edible animal by-product.

  • Jonathan

    Seems you and I were on the same page. I didn’t see your post until I posted mine. We probably started writing at the same time but I’m more verbose and probably a much slower typist.

  • Mike S

    In the following part of your report you mention two grades of by-product meal:

    ….”The Two Grades of By-Product Meal
    (and the Only One Suitable for Your Dog)
    In the specific cases of chicken or poultry by-product meals, there are two recognized grades…
    Feed grade by-product meal
    Pet food grade by-product meal”….

    Are you only referring to the two grades of “inedible” by-products (Feed grade and Pet food grade) as opposed to the possible third grade which would be “edible” by-products turned into pet food – which you do differentiate in your helpful diagram?

    With this further distinction would it not be possible to consider there are 3 grades of by-product meal?:
    1) Inedible by-products turned into generic meat meal
    2) Inedible by-products turned into named meat meal
    3) EDIBLE by-products turned into named meat meal

    I realize that we, as manufacturers, are not allowed to put that distinction on the label but that distinction does exist in reality and is yet another step up in quality (and cost) that is available to the small part of the industry that chooses it.

    One of the main reasons Brothers Complete chooses “EDIBLE named meat meal” over “Inedible named meat meal” is that meat meal that is “inedible” must be “denatured” by spraying with toxic materials (like creosote) and edible named meat meal does not.

    While the protein, etc. content of the “Inedible NAMED meat meal” may be similar to the “Edible NAMED meat meal” I feel the inclusion of the toxic substances to “denature” the inedible product makes the nutrient comparison secondary to the problem of spraying the food with toxic substances.

  • Jonathan

    What about the denaturing of meat by-products? Wouldn’t denatured meats be worse than anything with the crap they add to them? I though that was was the main reason to avoid by-products.

    “(1) The following agents are prescribed for denaturing carcasses, parts thereof, meat or meat food products which are affected with any condition that would result in their condemnation and disposal under part 314 of this subchapter if they were at an official establishment: Crude carbolic acid; cresylic disinfectant; a formula consisting of 1 part FD&C green No. 3 coloring, 40 parts water, 40 parts liquid detergent, and 40 parts oil of citronella, or other proprietary substance approved by the Administrator in specific cases.3”

  • Mary Lou

    Wake up, people ~ please!! Now I know why I have never been able to stomach a hot dog! Do you really want your best friend eating by-products?! My morning coffee is turning bitter.

  • Mike

    Well done! Nice job collecting data to give everyone a starting point for what promises to be a lively discussion.

  • Hi Sheila… As I conclude in this article, the primary reason generic animal by-products are used to make dog food is because they’re cheaper. Not because they’re more nutritious. And they are a sign of a cheaper product. Why do so many expensive foods contain animal and plant by-products? Even some of the super-costly veterinary and prescription products contain these low-cost meat ingredients. Why the extra cost?

  • Sheila

    Well, that said, I come from European stock and we grew up eating boiled Chicken feet, unhatched eggs, giblets, hearts, beef lung, liver etc. Perhaps it was better for us because my mother used to buy the Chickens live and do the “cleaning herself”. Lung was a delicacy. I lived to tell the story, I am 72 yrs. old., however I don’t think I would feed any of this to myself or my pets today unless I knew where it came from.