Make Believe Dog Food Company – I Highly Recommend Their Product!

What’s a good food to feed your dog in light of everything we’ve learned from the massive pet food recalls of 2007? I don’t know. But if I could find one, it might look like this:

My Make Believe Dog Food Co. isn’t waiting around for Country of Origin Labeling (COOL) to become law. They know consumers want COOL now, even if it’s not mandated. They know pet owners are tired of manufacturers and their sinister deceptions by advertising they “buy from U.S. sources” when in reality the “U.S. source” purchases its ingredients from overseas which the pet food manufacturer knows, or should know. MBDF Co. is accurately listing the country where its meats, grains and vegetables are grown and raised right on the label.

MBDF Co. uses only quality ingredients obtained from local, sustainable farming sources whenever possible. They list these ingredients by their easily recognizable household names such as rice, green beans, chicken, etc. They don’t go for the AAFCO loopholes which allow the inclusion of low quality, dirty ingredients in pet food. In fact, they don’t go for AAFCO at all. They follow the NRC’s recommended guidelines in regard to formulating a balanced canine diet, not the guidelines AAFCO made up themselves after discarding the long standing NRC recommendations. And yes, they do feeding trials like the NRC recommends – not just cheap chemical analysis like AAFCO allows. And all this information is detailed on their website because they know consumers are interested and more than capable of understanding the science behind canine nutrition.

MBDF Co. doesn’t do business with Menu Foods or any of the other profit-is-everything/dead-pets-are-nothing manufacturing facilities. They process their own foods in their own facilities in accordance with FDA standards such that their pet food could actually be safely consumed by people (if some such persons so desired). The name, address and phone number of the company’s plant is printed right on the label so in case of a pet food recall (and another massive recall is inevitable IMO), consumers don’t have to worry and guess where and by whom the food in their pantry was made. If questions arise, consumers can call or e-mail the company and they will respond in a timely manner with accurate information – not sales spin, not we-can’t-tell-you-that-because-it’s-proprietary-information BS – just honest answers. They know it’s smart business to give customers what they want: the truth.

I expect MBDF to cost significantly more than the market average because I know what’s in the average pet food – cheap, dirty ingredients. I understand it costs more to buy clean, sustainably farmed ingredients and to avoid all the penny saving loopholes afforded by AAFCO. But good food for my pets and peace of mind for myself are well worth the expense.

Make Believe Dog Food Co – where are you?!

He Said, She Said – FDA vs. Evanger’s

Update on April 29, 2008:  Over on the Itchmo Forums, a consumer posted a response from the FDA on the back and forth between Evanger’s and the FDA.

Original post:

On April 24, 2008 FDA issued a press release stating in part:

The U.S. Food and Drug Administration issued an order requiring that Evanger’s Dog & Cat Food Co., Inc., in Wheeling, Ill., obtain an emergency permit from the FDA before its canned pet food products enter interstate commerce.

A recent inspection revealed significant deviations from prescribed documentation of processes, equipment, and recordkeeping in the production of the company’s thermally processed low acid canned food (LACF) products. These problems could result in under-processed pet foods, which can allow the survival and growth of Clostridium botulinum (C. botulinum), a bacterium that causes botulism in some animals as well as in humans.

Pet owners who feed Evanger’s or any of the companies Evanger’s cans for, would seem to have reason to be concerned.

But then –

On April 25, 2008 Evanger’s responded with a release on its website, stating in part:

Contrary to a news release issued by the FDA Thursday, April 24, 2008, Evanger’s continues to make and distribute its products with FDA approval. Evanger’s is working closely with the FDA and already has addressed many of the FDA’s questions. Evanger’s expects to have the few remaining FDA queries fully satisfied shortly.

No Evanger’s product has been recalled, nor is there any indication that any Evanger’s product is under-processed, unsafe, or contaminated in any way.

And the owners, Joel and Holly Sher, made the rounds to the pet blogs, posting comments that the FDA release is “highly inaccurate”.

So –

What’s a pet owner to do? Believe the FDA whose track record on protecting consumers (and their pets) leaves something to be desired? Believe the owners of the pet food company who obviously would like you to buy their products? This is a dilemma pet owners should not have to face. Evanger’s does not work for me so I can’t influence their behavior except with my wallet. But the FDA does work for me. And I want an FDA with enough funding, qualified staff, and enforcement powers (not to mention a complete overhaul so that even the appearance of the agency’s “fondness” for big business is eradicated) that can do its job right. I want an FDA that protects me and my pets and has a good record of doing so. I want an FDA that has gotten it right enough times for me to have confidence that if they say X, I can believe X.

For now, I will continue to grocery shop with caution and prepare my pets’ food at home. Because the FDA I want and the FDA I have seem to be far, far apart.

FDA Sets Date for Public Meeting on Pet Foods

From the CVM Update:

The Food and Drug Administration (FDA) is announcing a public meeting to obtain input from stakeholder groups, including, but not limited to, the Association of American Feed Control Officials (AAFCO), veterinary medical associations, animal health organizations, and pet food manufacturers, on the development of standards for pet food, including ingredient standards and definitions, processing standards, and updated labeling standards. Establishment by regulation of such standards for pet food was mandated by the FDA Amendments Act of 2007 (FDAAA).

The public meeting will be held on May 13, 2008, from 8:00 am – 4:30 pm.

The public meeting will be held at The Gaithersburg Holiday Inn, 2 Montgomery Village Avenue, Gaithersburg, MD 20877.

If you wish to attend: Pre-registration is recommended although if space allows, they will accept walk-in registrations. When you pre-register, you can let them know if you wish to make a public comment at the meeting. They also have alternate methods for accepting public comments in the CVM Update.

Buried on this page:

FDA is sponsoring an additional public
meeting as part of its Animal Feed
Safety System (AFSS) initiative on
May 14, 2008, at the same location
as the May 13, 2008, FDAAA public meeting.
The AFSS is a system that FDA is
developing to minimize the risk to
animals and public health through the
use of risk-based, preventive, and
comprehensive animal feed control measures.
I'm not sure that "risk-based" and "comprehensive"
They haven't so far.

And referring to the May 13 meeting on pet foods,
asks on this same page:

Should a Nutrition Facts box, similar to
the format that appears on human food
labels, replace the current Guaranteed
Analysis that currently appears on pet
food labels? If so, how could this Nutrition
Facts box be made to clearly distinguish it
from human food labeling?
We know that the pet food industry insiders
against the idea of printing calorie
on pet foods. But is FDA really
going to make
it so easy for them to get out
of providing this
simple information by implying
that people will
Dog Chow for Hot Pockets
just because of
the Nutrition Facts on the label?
Dog help us...

Report: Nutro Pet Foods Making Pets Sick

Lisa Wade McCormick from ConsumerAffairs.Com has posted an article compiling reports from owners in many states whose pets became ill after eating Nutro brand foods.

Nutro’s products for dogs include varieties under the following names:

  • Nutro Max
  • Nutro Natural Choice
  • Nutro Ultra

Nutro’s products for cats include varieties under these names:

  • Nutro Max Cat
  • Nutro Natural Choice Complete Care

As always: if your pet is ill, seek prompt care from your Veterinarian.

AAFCO – The Pet Food Industry Fails to Regulate Itself

The National Research Council (NRC) has traditionally set the standard for nutrient requirements for dogs and cats with their publications. The NRC recommends feeding trials in order to determine if a food is truly “complete and balanced”. I don’t have a degree in animal nutrition but that makes sense to me. How else can it be determined that a pet food is nutritionally adequate unless it is actually fed to pets over a period of time and the health of those pets monitored? The Association of American Feed Control Officials (AAFCO) has another idea: chemical analysis.

In the early 1990’s, AAFCO dropped the NRC guidelines and established their own nutrient profiles based on the formulas of 3 generic pet foods with which they conducted feed trials. The idea being that as long as pet food manufacturers followed one of those 3 formulas, there would be no need for more feed trials. What was so wrong with the NRC requirements? To my mind, nothing. I use them myself. By disavowing the NRC standards, AAFCO could ignore the very expensive recommendation for feed trials and simply give a Nutritional Adequacy stamp to any food which passed their chemical analysis.

Again, I’m a layman but does chemical analysis tell us how biologically available any nutrients are for pets? Or how digestible they are? I don’t see how that information could be determined in the absence of feed trials. For example, chemical analysis tells us that cereals, the main ingredient in most pet foods, have many nutrients. It does not tell us however that pets are unable to fully utilize the nutrients in cereals. These nutrients are biologically unavailable to pets. And since cereals make up the main part of commercial diets, it is at best misleading for AAFCO to label these foods as “complete and balanced”.

AAFCO Speaks for Themselves

From AAFCO’s website Q & A:

Regarding the use of downer cattle and other such animals in pet food, AAFCO says meat by-products may include “materials from animals which died by means other than slaughter” – which I interpret as animals who may have been too sick and/or diseased to survive the trip to the slaughterhouse – and are ok for use in pet food as long as the materials have been rendered according to “regulations to destroy any potential microorganisms”. In other words, AAFCO says your pet food may contain bits and bobs from animals suffering from cancer, BSE (Mad Cow Disease), or any other unknown lethal illness or condition. And the carcass from said animal may have been rendered some days after the animal actually died. Yum.

Regarding the wholesomeness of pet food ingredients, AAFCO subtly reminds consumers that it’s “Buyer beware” out there, stating that even though a food is AAFCO certified as complete and balanced, “the specific nutrients may be assembled from a variety of ingredients. If consumers have a preference for certain ingredients, they should review the ingredient list to
determine if their preferences are being met.” In other words, if you don’t study the ingredients list on every bag or can of pet food you purchase, don’t blame AAFCO if it turns out you’re feeding your pet icky stuff. Tip: The healthful looking whole foods often pictured on the front of the bag or in the television commercials do not necessarily represent the ingredients used to manufacture the food inside the bag.

I’m leaving this question and answer intact as I think it illustrates the double speak and spin AAFCO seems to be so fond of:

7. Does most of the protein come from scrap and byproducts left over from human meat processing?
The animal proteins used in feeds are frequently, but not exclusively derived from the production of human food.

Couldn’t they simply have answered YES?

In summary, is the AAFCO Nutritional Adequacy statement on a pet food label actually worth anything? “The nutritional adequacy statement, the ingredient list and feeding directions will provide the consumer with the best estimate of the nutritional value and correct use of the product.” Yes, you read that right: best estimate. As we saw over and again during the massive pet food recall of 2007, companies don’t actually know what ingredients are in their pet foods. The ingredients list on the label, which AAFCO tells us it’s our job to study, is just an estimate. To my mind, AAFCO’s position is: It’s your responsibility as a pet owner to know the ingredients of the food you feed to your pets. And you can’t really know the ingredients because what’s listed on the pet food label is only an “estimate” of what was actually used to make the food. So good luck and don’t blame us if your pet develops health problems and/or dies due to nutritional deficiencies and excesses, or if you just plain fed him toxic food.

From the minutes of AAFCO’s 2007 meeting as posted on their site, it is evident that AAFCO, the Pet Food Institute (PFI), the National Renderers Association (NRA) and other industry insiders are extremely resistant to the request of Veterinarian groups to include calorie statements on pet foods. Wouldn’t calorie statements be helpful to consumers? Many people are already familiar with studying and comparing calorie statements on human food labels so it would be easy for them to transfer this knowledge to pet food labels. And it would give consumers another tool with which to compare products by revealing one more bit of information. Further, since obesity in pets is such a widespread problem, calorie statements on labels would allow consumers to more accurately calculate how much food to feed rather than relying on the currently printed vague guidelines for feeding amounts. So why are pet food industry insiders so resistant to this request? Could it possibly be related to:

The costs involved in determining caloric content?
The potential for owners to feed less of their products once they know the actual calories being fed?
The possibility that owners may abandon their previously purchased brands in favor of brands better suited to their pets’ needs according to the calorie statements?
The possibility that some owners may abandon commercial pet foods in favor of a home prepared diet consisting of ingredients and calories completely determined and controlled by the owner?

According to the Food and Drug Administration, “AAFCO has no legal mandate“. Well, maybe they should.

Recommended Reading: Home-Prepared Dog & Cat Diets – The Healthful Alternative by Donald Strombeck, DVM, PhD

Downloadable pdf pamphlet from the NRC on canine nutrient requirements

Downloadable pdf pamphlet from the NRC on feline nutrient requirements

Flatcoats and Malignant Histiocytosis

This is a photo I took today of Randi. She is a 5 year old Flatcoated Retriever. Today would have been her mama’s (Jackson) 13th birthday. Sadly, I had to put Jackson to sleep when she was 10 as she was suffering from an aggressive tumor (Malignant Histiocytosis) on the side of her head. The cancer, common in Flatcoats, had not spread to her lungs and she appeared to be in excellent physical and mental condition otherwise. I remember saying to Billy when I found the tumor, “I don’t think I can spare her”. I still don’t.

Jackson’s mama Tina was 11 when I had to put her to sleep due to an aggressive tumor (Malignant Histiocytosis) she had on her leg. It was too soon. I remember when my Vet got the lab results back and told me she had looked up MH in a veterinary reference book. “They called it the Flatcoat Cancer,” she said. Tina outlived her dam and two of her littermates (none owned by me) and for all of them, it was too soon.

I look at Randi today and see how vibrant she appears and I am reminded how much she looks like Jackson and Tina. I see no reason why she, or any Flatcoat, can’t live to be 18. Save for the Malignant Histiocytosis, my dogs never seem to have anything wrong with them when I have to put them to sleep. If we could eliminate this apparently genetically linked cancer so common in the breed, who knows how long they would live? We might live to regret it – hahaha!

Read more about Malignant Histiocytosis here.

Read about how closed registries (such as the AKC) affect genetic health in dog breeds here.

FDA Wonders if Pet Foods Could be Made Safer

Veterinary Practice News has an article about the FDA looking into expanding the use of third party certification programs for food products, including pet foods.

“The FDA would like to know what domestic and foreign third-party programs for suppliers are in use by U.S. companies and, significantly, how do these programs ensure independence and avoid the conflicts of interest inherent in accepting fees from the very companies seeking certification.”

The FDA needs the public to advise them on this? They don’t already know? O yeah and that conflict of interest thing didn’t seem to serve the public too well during the pet food recall of 2007 – hello AAFCO?

“It would also like to know if existing certification programs already ensure compliance with FDA requirements and, if not, how the programs would need to be modified to ensure compliance. Many of the existing programs are designed to meet foreign government requirements, which may or may not meet U.S. standards.”

Just having a guess – I’ll go with “may not“.

“The government also wants to know what’s preventing the majority of U.S. firms from participating in existing certification programs.”

Since I’m guessing, here’s a few ideas –

  • Because they are not legally required to do so
  • Because there are no significant legal or financial consequences for companies who sell tainted pet foods (which is probably why they keep doing it)
  • Because we can’t pass County of Origin Labeling across the board which allows sneaky manufacturers to respond to the inquiring public with smarmy answers like “Sorry, we can’t tell you where our product ingredients are sourced from and/or made – that’s proprietary information.”

Full article here including information on how you can submit your comments to the FDA if you are so inclined.

Open Letter Regarding Senator Williams and SC Shelter Requests Help

These are the questions I will be mailing to the appropriate parties concerning the Kent Williams GSD case. Anyone is welcome to copy these questions into his/her own letter:

  • Did Senator Williams violate the laws of Marion County and/or the State of South Carolina when he failed to spay a female German Shepherd whom he adopted from the Marion County Animal Shelter – his local shelter – in 2007?
  • Did Senator Williams pay his local shelter’s adoption fee, which he must have known the shelter relied upon for desperately needed funding, when he adopted this German Shepherd? Did Senator Williams pay the adoption fees for any other dogs he adopted from his local shelter?
  • Did Senator Williams violate the laws of Marion County and/or the State of South Carolina when he repeatedly allowed this German Shepherd Dog to run at large?
  • Was this dog vaccinated against Rabies? If not, did Senator Williams violate the laws of Marion County and/or the State of South Carolina when he failed to vaccinate this German Shepherd Dog against Rabies?
  • Did Senator Williams exercise due diligence in preventing unwanted breeding with the female German Shepherd whom he knew was not spayed? Did he provide safe and humane confinement for the dog when she was not directly supervised by a responsible person?
  • Did Senator Williams, faced with the imminent birth of puppies from his pregnant German Shepherd Dog, behave in a responsible manner when he called Animal Control in March 2008, asking them to pick the dog up and return her to his local shelter which the Senator must have known had deplorable conditions inappropriate for the birth of puppies and a policy of euthanizing homeless pets?

The South Carolina Code of Laws regarding dogs can be read here and regarding Rabies vaccination here.


Just received this in my inbox:


Please help this overcrowded shelter!
Oconee County Animal Control is rescue friendly.

Please save one today!

Oconee County Animal Control
321 Camp Road
Walhalla, SC 29691


Hours of Operation
10am to 5PM

There were also photos and descriptions of a number of really sweet looking dogs who need homes but I’ll let you search for yourself if interested. This is their website:

More on Marion County Shame

South Carolina State Senator Kent Williams violated state and county laws when he failed to spay a German Shepherd bitch he adopted from the Marion County Animal Shelter – a kill shelter – last year. He said he intended to breed her but when she was bred (presumably to an unknown sire she encountered while roaming the streets) he waited until just before she was ready to whelp before having animal control pick her up and bring her back to the kill shelter in March 2008. The Senator has not been charged to my knowledge.

Coincidentally (I guess), the Marion County Council held a meeting regarding the dreadful conditions at the shelter around this same time. From the minutes:

Vice Chairwoman Smith requested the Clerk to read the report Committee No. 2, which met on Thursday, March 20, 2008, at 5:30 P.M., at the Marion County Administration Building, with Chairwoman Smith, Mrs. Rogers, and Mr. Shaw, County Administrator and Clerk to Council. The Committee met with four members of the Humane Society, which addressed their concerns in regards to the Marion County Animal Shelter. Mr. Eleanor Kitchens, Ms. Marjorie Byrd, Ms. Pat Koch and Mr. Bob Blue. The organization named a few main priorities for the Marion County Animal Shelter: They are as follows:

1. A dated digital photo identification number for every animal taken in, noting where they were picked up.

2. No wetting of animals during cage cleaning.

3. Heating and cooling in all areas.

4. Standard immunizations on all puppies when old enough.

5. A person in charge who has the background and knowledge to run a shelter.

6. Workers who will do all they can to work with rescue groups so the fewest number of animals are put down.

Mr. Bob Blue told the committee that one of the Human [sic] Society main objectives is to control the animal population of Marion County by offering a cash rebate of $40 to residents who provides proof that their animals were spayed or neutered.
Chairwoman Smith emphasized to the Human [sic] Society members that if they witness any wrongdoing at the shelter to contact Mr. Harper.

Yes Mr. Harper, I believe I will be contacting you.

This story includes a comment from a reader who claims to be a former employee of the shelter where Williams left his pregnant German Shepherd to (quite possibly) die. She describes interactions she had with Williams regarding a previous dog. If the account is accurate, clearly this is not a temporary lapse in judgment type situation with the GSD but rather a pattern of troubling behavior. And the irony of Williams’ Oprah connection is not lost on me. Oprah recently did her part to shed light on the miserable lives of dogs in puppy mills and vowed to adopt all her future dogs from shelters. Too bad she doesn’t make it down to the Marion County Animal Shelter very often – we might see another expose.

There is a lame-o excuse from the Senator here but my favorite quote from him on the subject is this: “As a citizen, I exercised my right to surrender the animal to the shelter.” Senator Williams: Exercise this.

Please let these people know how you feel about this story and request the media to cover it:

Senator Kent M. Williams
602 Gressette Bldg.
Columbia, SC 29201

(803) 212-6008
E-Mail Address:

Marion County Animal Shelter
123 Dog and Cat Ct.
Mullins, SC 29574

(843) 423-8370

Timothy Harper, County Administrator
P.O. Box 183
Marion, SC 29571-0183

(843) 423-3904

(Kent Williams is the Deputy County Administrator)

The State Newspaper – Columbia, SC
Send a story idea:
Send a letter to the editor:

South Carolina Pet News

As I previously blogged, April is South Carolina’s month to encourage owners to get their pets vaccinated for Rabies by offering $3 vaccinations. SC DHEC has a list of clinics by county on their website. South Carolina mandates that pets be revaccinated according to the vaccine’s labeling. That is, if your Vet administers the Rabies vaccine labeled for 3 years, your pet does not require revaccination for 3 years. However if your Vet administers the Rabies vaccine labeled for 1 year, your pet must be revaccinated annually. So before having the Rabies vaccine administered to your pet, ask which vaccine is being used.


SC State Senator Kent Williams of Marion County apparently subscribes to the ‘Do as I say, not as I do’ philosophy. Williams, who “wrote a column published in the Marion Star & Mullins Enterprise in which he admonished pet owners and potential pet owners to be responsible” adopted three dogs from his local kill shelter in 2007. He gave two away to family members (Whaaaaaaa?) and kept the third dog – a German Shepherd bitch – for himself. He left her with an automatic water and food dispenser in some type of enclosure which was apparently easy to escape from – which she did, numerous times. In violation of state and county laws, Williams did not spay the bitch after adoption but instead allowed her to become pregnant. Shortly before she was due to whelp in March of 2008, he gave the county animal control officer a ring and told him to pick the bitch up and return her to the kill shelter. Nice. If you’d like to let Senator Williams know what you think, his contact information is here.


The Williams case comes on the heels of a state agriculture official, James Trexler, resigning amidst charges in connection with horse abuse in SC and GA. That one’s a family affair with Trexler’s mother and brother (a former lawyer, disbarred in 2001) facing charges as well.


SC Senate Bill 833 – a pending piece of legislation regarding the tethering and crating of dogs – has undergone some revisions from its previously vague wording. Read the current version here. I’m not sure exactly what the point of this legislation is as it seems about impossible to prove someone is in violation but what do I know – I’m no politician…