By:  Susan Thixton

It was news to me.  It seems pet food companies can “regrind” previous batches of kibble and add it back into new batches of pet food.  And Pet Parents are none the wiser.

About a week ago I received an email from TruthaboutPetFood.com friend and content contributor Dr. Cathy Alinovi DVM.  She asked me if I’d ever heard of “regrind” in pet food.  It was nothing I’d heard of before, but it piqued my interest (and caused my mind to race with all sorts of unsettling thoughts).  It seems a friend of a friend of Dr. Cathy works for a popular pet food manufacturer.  In casual conversation, the friend shared with Dr. Cathy that “regrind” is the process of ‘regrinding’ previously made kibble into another batch of kibble.  She was told that they are allowed to add up to 5% for organic pet food and up to 15% for all other types of pet food.  AND she was told that it didn’t matter what flavor or type of pet food the regrind was or what flavor or type of pet food the regrind is added to.  I was shocked (still am).

So…I took the question to the guru of all things animal feed, Dr. Gary Pusillo.  I asked…
I have a question I’m hoping you know about.  A pet food manufacturing insider recently shared information about ‘regrind’.  I was told that pet food manufacturers are allowed to regrind batches and put back into a new batch of pet food.  They told me up to 5% of regrind is allowed in organic foods and up to 15% is allowed in other pet foods.  Do you know of this?

And here’s what he told me…
“In my many years of investigating claims concerning animal feeds, I have learned to read what the company policy is regarding  GMP’s (Good Manufacturing Practices) and feed quality assurance programs, and then spend some time in the facility watching what actually is practiced.

Companies should have a written “Production Variance Procedure” to ensure that the proper investigation and corrective actions occur in regard to bulk and bag variation from theoretical yield. Quality conscious manufacturers have very precise allowable variances associated with specific batch sizes . Some manufacturers have gone a step further and assign variation values to type of product, packaging, and batch size .

I have been involved in litigation were the animal feed being produced exceeded its tolerance variation because another ingredient was “leaking” into the mixing system; errors in weighing bulk ingredients, valve and switching malfunction, operator error and employees trying to cover up mistakes.

If a discrepancy has been found to be due to contamination, all product from the batch must be appropriately labeled and quarantined; it must not be put back into future batches.

Extruded products often have variations associated with product quality in the first few minutes of the initial product extrusion and prior to the final batch processing. Some manufacturers have procedures to isolate beginning and ending product runs so that they can be “added back” into another batch of the same product.

It is not uncommon to see animal feed manufacturers which store ingredients at an elevated level above a mixer, extruder or other processing equipment. The operator can stand above the mixer and dump hand added ingredients in the machine, as required by the formulation.”

(See…he IS the guru of all things animal feed!)

Next, I took this question to a trusted pet food manufacturer (who will remain nameless).  Here’s what I was told…
“When the extruder first comes on, it takes several minutes to get everything working exactly the way the kibble is supposed to look. On some start-ups, you might waste as much as a ton of food to get the moisture and shape right.

I am sure some plants will dry this material and will regrind a small percentage and put back into the same diet. Some, also may have a recovery system that actually might return the initial product right back into the extruder during the same production run. This type of equipment is available. This will help improve yield.

Also, some companies will sell this start up material to hog farmers or other animals that are allowed to eat animal protein like chickens.”

I also took the same ‘regrind’ questions to AAFCO (American Association of Feed Control Officials).  Here’s what else I learned…
Neil Lanning (State of Washington Department of Agriculture) told me…
Susan:

“I cannot speak for AAFCO on this but in the State of Washington, and our rules are based on 2002 AAFCO Model regulations, we allow companies to rework livestock feed.  I do not know of any reason why we would not allow pet food to be reworked. The ingredient list still needs to be accurate and they must still meet guarantees.   I suspect the percentages you were told are company policy and not regulatory driven – but I certainly do not know all of the different states regulations.

I am not aware of anyone reworking any material that has left the manufacturing plant.

Neil”

And AAFCO President Chad Linton (West Virginia Department of Agriculture) told me…
“Susan,
Sorry to be slow in returning your email, but I had sent this question to several pet food companies for clarification with no return. This term is the first that I have heard of it put in this particular context, but I know as a general feed practice, this happens often.  The term that I am familiar with is called  “rerun”.  It is just the practice of taking an ingredient that has been used to clean the system of one particular product with another ingredient to make another product.  The industry term is call sequencing.  I assume that any complete feed if it isn’t used, isn’t adulterated, or otherwise unusable, can be put back into the system.  It seems to be a sensible and reasonable practice in a plant to keep costs down and reducing waste, otherwise this product would be landfilled or sent to other means of the food chain, at a cost to the business.

I do not know of any sections in our Official Publication that addresses such practices.  This seems to be a company policy issue, not an AAFCO issue.  If the product is not adulterated, has the same ingredients, stays within the same guaranteed analysis, I see no reason why a firm can’t do this practice, at any percentages.

I will continue to try and reach the pet food companies and my pet food committee about this question, and when I receive an answer back from them, I will be sure to forward it onto to you.  If I can do anything else, please let me know.  If you would like to talk to me about, feel free to call me at the number listed below.

Chad S. Linton
Assistant Director
West Virginia Department of Agriculture
Regulatory and Environmental Affairs Division
1900 Kanawha Blvd.; East
Charleston, WV 25305″

First – Many Thanks to Dr. Gary Pusillo, pet food friend, Neil Lanning and Chad Linton for answering my questions!

So, here’s some of my concerns…I received an email recently from a concerned pet parent.  She wrote me asking what could be done about pet food manufacturers changing their formulas without notifying pet parents.  “I would think most food processors don’t understand that changes really are difficult for cats to take if we don’t do it gradually. By the time us as customers realize there is a recipe change we have a sick cat. I have 2 cats w/bladder issues and have to be really careful what I feed and to watch for bladder inflammation and blood in the urine. This can be triggered by food changes, as you know. Also when they change their recipes they might be changing how it will affect the pH of the urine in the bladder.

I bring this up because cat food companies are notorious for changing their recipes and telling no one. I have to watch carefully what I feed because of my cats bladder issues but if I don’t know they’ve made a change I’m lost as to figure what triggered a relapse.”

Now just imagine if there was a 15% regrind of a pet food with different ingredients in her current pet food.  Her cats get sick.  The pet food company tells her there was no ingredient change – which would be an honest answer to the direct question did you change your formula?  But what wasn’t mentioned or perhaps even known by the pet food customer service representative, was the food contained 15% of a different variety in regrind.  Ingredients were changed due to regrind.

What if a ‘grain free’ dog food or cat food – which the pet parent paid premium price for – contained 15% regrind of a grain included food?  What if the first few minutes of the extrusion process produced a food that wasn’t the right mix?  Such as too few or too many vitamin and mineral content?  Would 15% of this regrind cause a problem with the next batch?  Oh my mind wanders to many alarming possibilities.

Dr. Gary Pusillo pointed out the steps that quality minded manufacturers go through to assure the quality and safety of their foods, but what I can’t help but wonder is what happens with manufacturers that have a higher concern of profit than quality?

We do not have certain knowledge/information that any regrind could be a problem for our pets; it could be that regrind is a non-issue.  The problem is – because regrind is not (has not been) common knowledge to pet parents, because we just don’t know for certain what exactly is reground and put back into another batch, because of an unlimited amount of other possibilities, the unknown IS the problem.

And remember…the Pet Food Industry denied me admission to a pet food workshop and trade event (I have to assume it wasn’t just me – I’m assuming they would deny any pet food safety advocate admission as well).  When are they going to understand that pet food unknowns can’t stay unknown forever.  When are they going to understand that pet parents aren’t going to just crawl back into the pet food cave they so politely kept us in for decades?  Those days are long gone.

 

Wishing you and your pet the best,

Susan Thixton