Animal & Veterinary
CVM Offers Advice on Raw Meat Diets
FDA Veterinarian Newsletter May/June 2004 Volume XIX, No 3
Commercially prepared raw meat diets for pets, which are gaining in popularity with pet owners and professional animal caretakers, carry an increased risk of bacterial contamination for the animals and their human handlers, and some potential risk of injury to the animal from shards of bones or other hard substances in the meat, the Center for Veterinary Medicine said in a “Guidance for Industry” issued in May 18.
The guidance makes clear that the CVM or the Food and Drug Administration does not support the use of raw meat diets, saying in the guidance that raw meat diets for animals are not “consistent with the goal of protecting the public from significant health risks, particularly when such products are brought into the home and/or used to feed domestic pets.”
CVM officials decided that the issue of raw meat diets needed to be addressed when they saw an increasing trend toward use of raw meat diets for companion animals, such as dogs, as well as non-companion, captive animals.
CVM presented its non-binding recommendation in Guidance for Industry #122, “Manufacture and Labeling of Raw Meat Foods for Companion and Captive Noncompanion Carnivores and Omnivores.” It is available on the CVM’s website.
In the guidance document, CVM said that objective data about the risks from the use of commercially prepared raw meat diets is limited, but by reviewing data on risks to consumers from foodborne pathogens, including those from raw foods, CVM concluded that the risks are significant enough that consumers and others using commercially prepared raw meat diets for animals should take the precautions offered in the guidance document.
Sources of meat
Depending on the source of the raw meat used in commercially prepared diets, risk of contamination by bacteria or other pathogens can vary, CVM said. The best source is a U.S. Department of Agriculture-inspected slaughter facility, and the best meat is that which has passed USDA inspection for human consumption, the guidance said.
By contrast, raw meat from animals that died from causes other than slaughter at a USDA facility is likely to have higher levels of pathogens. Even meat that is produced at an inspected slaughter plant, but was not approved for human food, and instead approved only for animal feed, is likely to have higher pathogen loads, the guidance said.
CVM also recommended that any other ingredients added to the raw meat diets should be suitable for use in pet diets.
The guidance pointed out that the physical form of the ingredients is important. Bones can cause dental or gastrointestinal injury, it said. Therefore, any bone or hard material contained in the raw meat diet should be ground.
Although CVM does not have any Good Manufacturing Practice (GMP) guidelines for non-medicated feed, such as raw meat diets, the guidance suggests that manufacturers use practices to reduce contamination. For instance, the guidance recommended that manufacturers irradiate the product after it is in its final packaging. It also said that manufacturers should participate in USDA’s voluntary inspection program, practice using the same GMPs as used for human food or develop and use a Hazard Analysis and Critical Control Point program, which identifies points at which hazards can be introduced in the manufacturing process, determines how the hazards can be controlled, and implements processes to monitor the controls.
The guidance recommended that, if the raw meat products are freeze-dried, then they should remain frozen until used to help reduce pathogens.
Just as USDA requires instructions about handling raw meat products destined for human consumption, CVM suggested that raw meat diets for animals also have handling instructions to help the consumer avoid contamination.
Although some commercial animal food manufacturers may assert that raw meat diets are better than other types, “FDA is not aware of scientific evidence to support such claims,” the guidance document said. “Calcium and phosphorus are often deficient in foods based on raw meat, and should be supplemented accordingly,” it said. Large pieces of bone are not readily digested, so even though the diet contains adequate amounts of calcium, the animal may not be getting all it should. Vitamin A can be excessive, causing toxicity over the long term, and other fat soluble vitamins could be excessive or deficient in a raw meat diet, the guidance said.
Neither CVM nor FDA has issued regulations that specify standards for nutritional adequacy of sole source foods, but the Association of American Feed Control Officials has proposed a rule that raw meat diets be formulated to meet AAFCO dog or cat food nutrient profiles, or that the diets pass appropriate feeding trials. For other types of animals, CVM recommended that diets intended to be the sole source of nutrients be formulated according to standards developed by “authoritative scientific review committees knowledgeable in the nutrient requirements of the specific species,” if such information exists.
Also, the guidance said that claims made about raw meat diets must be appropriate and comparative claims about other products must be supported by scientific evidence. In addition, claims that the product is “USDA certified,” “USDA inspected” or “human grade” must be true according criteria spelled out in regulations.