REGULATORY DEFINITIONS

There is frequent confusion regarding the marketing terms and the regulatory purview they may fall under. Terms used in product promotional materials or on labels, such as natural, organic, human grade, premium, gourmet, and holistic often do not have officially recognized definitions (Box 13-1). Consumers (and veterinarians) often are left with the impression that any such language is standardized or regulated in some way, but that is not always the case.

The Association of American Feed Control Officials (AAFCO) defines a natural feed or ingredient as one that is:

derived solely from plant, animal or mined sources, either in its unprocessed state or having been subject to physical processing, heat processing, rendering, purification, extraction, hydrolysis, enzymolysis or fermentation, but not having been produced by or subject to a chemically synthetic process and not containing any additives or processing aids that are chemically synthetic except in amounts as might occur unavoidably in good manufacturing practices.²

The term natural should be used only to describe products for which all of the ingredients and components of ingredients meet this definition. An exception is made to allow the use of chemically synthesized vitamins, minerals, or other trace nutrients; however, a disclaimer must be present to inform the consumer that these supplemented nutrients are not natural.

The term organic refers to the conditions under which the ingredients used in products, and the product itself, were produced, and must be consistent with regulations developed by the United States Department of Agriculture (USDA). Current regulations covering organic products do not apply to pet foods; however, the USDA is developing regulations for organic labeling of pet foods. The USDA Organic Pet Food Task Force issued a report in 2006 outlining some of their proposed regulatory changes.³ The Task Force recommended that product composition requirements for organic pet food be similar to those for livestock, but that labeling categories be the same as for processed human food. These require a minimum of 70 per cent organic ingredients for the use of the claim “made with organic,” and at least 95 per cent organic content for the use of the claim “organic.” All products labeled as “made with organic ingredients” or “organic” must exclude ingredients that are genetically engineered, are produced using sludge or irradiation, or contain synthetic substances not on the National List of Allowed and Prohibited Substances as defined by the National Organic Standards Board (advisory to the federal Secretary of Agriculture). They also can not contain sulfites, nitrates or nitrites, or organic and nonorganic forms of the same ingredients. In addition, products labeled “organic” can not contain nonorganic ingredients when organic sources are available.

Another term that is gaining use is human grade. Currently, there is no official definition or regulation regarding the use of this term. According to AAFCO, this means that the term is not allowed.⁴ However, there is no legal prohibition, and the term continues to be applied widely to a variety of pet foods. In 2007, one pet food company was denied the right to sell their product in the state of Ohio due to the use of the term human food grade.⁵ The Ohio State Department of Agriculture argued that the term was misleading and refused to grant a license to the company. The company followed with a lawsuit, which eventually sided in their favor due to the argument that the company had the constitutional right to make truthful statements about the quality of its pet food product on the label. So, despite the unclear and likely variable and inconsistent interpretation of the term, its use is gaining popularity as more pet owners are selecting foods with improved safety and quality, whether these qualities are true or perceived.

Other descriptors used commonly include premium, super premium, gourmet, and holistic. These terms are used solely as marketing tools, and have no official definitions. Products labeled as such can have widely variable nutritional profiles, micronutrient concentrations, and ingredient types. They are not required to be of superior quality in any way or to contain different nutrient levels than other products. The term holistic often has been used to describe various commercially available and home-cooked diets, but appears to be used primarily as a marketing term, as the philosophical concept of holism is not only linked intrinsically to the individual as a whole, but also is descriptive of a manner of thinking or approach to a problem, rather than being applicable to substances. The application of classical holism becomes imprecise when applied to populations with varied characteristics. Nutritional science, while often observational, involves hierarchical theories and relies on the testing of hypotheses, precise measurements, and linear logistical constructs. Some aspects of the science of nutrition are based on the application of concepts established in small numbers of animals to the study or treatment of a population, while other facets, especially clinical nutrition, involve the consideration of the individual animal’s needs, comorbid conditions, lifestyle, and many other individual factors. Because most diets are formulated to satisfy average or expected needs within a particular population, only individual nutritional management plans that are part of a larger and more cohesive medical prevention and treatment strategy, rather than the diets themselves, can be considered truly holistic in nature.

HOME-PREPARED DIETS

Home-prepared diets for cats have become increasingly popular. The reasons owners want or need to prepare their cat’s food are many and varied. Cat owners often will express concerns regarding the use of commercial diets for their healthy cats. In addition, owners of cats with health problems may wish to participate in the management of their pet’s condition by providing a home-prepared diet, even if a commercially available diet would be appropriate. These owners may believe that a home-prepared diet is safer, more natural, or more healthful than a commercially available diet. They may wish to avoid certain ingredients (such as grains, chemical preservatives, or by-products) or to include certain ingredients (such as specific protein or fat sources). Other owners wish to feed their cats according to their own philosophical views, and choose home-prepared diets that are vegetarian, organic, natural, or raw. Another reason owners may feed home-prepared diets is that their cat refuses commercially available diets. In some patients, this is a learned behavior, while in others it may be the result of a food aversion secondary to a disease condition (such as chronic kidney disease). Finally, a patient may have a particular combination of diseases for which no suitable commercial diet exists. In these cases, a home-prepared diet can be an appropriate solution.

Although many of the reasons owners wish to avoid traditional commercial diets are the result of misinformation and myths, most owners want to provide healthful diets on which their pets thrive and purposefully do not feed inadequate diets that do not meet basic requirements or that are potentially harmful. Recognizing this, the veterinarian should play an active role in the nutritional management of all patients, even if they are healthy. Encouraging dialogue regarding nutritional needs for individual pets is an opportunity to educate clients regarding commercial pet foods (including testing procedures, ingredient definitions, and marketing strategies) and any issues specific to their pet, as well as the impact of nutrition on any potential disease processes. Animals eating home-prepared diets should be assessed on a regular basis, and the general clinical evaluation should include discussion with the owner regarding fecal quality, appetite, presence of vomiting, and any other abnormalities that have been noted. Every patient also should have a thorough diet history collected at each visit, in addition to a complete physical examination, including skin and coat evaluation, body weight, and body condition score. This helps ensure that potential problems are identified and addressed early. This is particularly important when a home-cooked diet is being fed because the recipe will often “drift.” Drift can occur when supplements are omitted or altered frequently, which may be a result of inconvenience or a lack of understanding regarding the importance of these ingredients. Also, properly formulated home-prepared diets will be more expensive than most commercially available diets, and this can result in recipe changes. Sometimes, owners will substitute ingredients in the original recipe, which can change the nutritional profile substantially. Even a small difference in ingredients can change the nutritional profile of the diet.

Although many recipes for home-prepared cat foods are available on the Internet and in books, the majority of these diets are inadequate when compared to updated recommendations for nutrient intakes using modern ingredient databases and formulation methods. The recipes also tend to have vague instructions, contain errors or omissions in formulation, incorporate potentially problematic ingredients, or feature outdated or otherwise inappropriate strategies for addressing specific disease conditions. One study evaluated recipes available in popular books and compared the analyses to nutrient-intake recommendations established by AAFCO and the National Research Council. Many of these widely available recipes were found to provide less-than-recommended amounts of multiple essential nutrients, including taurine, minerals, and vitamins.⁶ Another issue is that some owners do not follow any particular recipe, do not provide nutritional supplements, or feed their cats solely items that are palatable or convenient. Also, because certain feeding styles have become popular (such as raw diets), additional concerns must be addressed.

Nutritional adequacy is a major concern in regard to home-prepared diets. Providing appropriate levels of essential nutrients is crucial to optimize health and longevity, the foremost goals of individualized nutritional management (Table 13-1). Formulations are inherently imperfect at providing accurate levels of essential nutrients to the individual animal due to limitations in nutrient database information, variation in the nutritional profiles and preparation of the ingredients, limitations of the formulation methodology and/or software, limitations of the current understanding of the nutrient requirements of individual animals, and the inability to assess customized diets for appropriate digestibility and bioavailability of the nutrients. One study that evaluated the nutritional adequacy of home-prepared dog foods by laboratory analysis demonstrated that 35 different diets were below AAFCO recommendations for calcium, vitamins A and E, zinc, copper, and potassium.⁷ Another study utilized computer analysis to assess home-prepared diets that were recommended for the diagnosis and/or treatment of adverse reactions to foods in dogs and cats.⁸ Compared to nutrient intake recommendations at the time, most recipes that were recommended for long-term feeding of adult cats were too low in calcium, iron, taurine, and thiamin, and some also provided inadequate levels of potassium, phosphorus, and sodium. Owners should understand the limitations of any diet they choose to feed, and they should have the tools and guidance available to evaluate resources and recipes effectively, so that informed decisions can be made regarding an appropriate diet for individual animals. This is particularly important when feeding cats with one or more diseases amenable to nutritional management because disease progression or other changes in the clinical picture may warrant changes in the feeding plan.

Table 13-1 Clinical Signs of Vitamin and Mineral Deficiency and Toxicity, Diagnostic Tests, and Dietary Sources*

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