pet connection

The question came up on Facebook recently as to whether the words “human grade” actually mean anything when it comes to pet food ingredients. The answer, as I discovered when I was writing about pet food labeling in 2009, is yes.

And no.

The first thing to know is that no human or pet food regulations define the terms “human grade,” “human quality” or similar descriptions, so in that sense they don’t actually “mean” anything. Foods are either edible or inedible for people, and those terms do have legal definitions per the U. S. Department of Agriculture.

“Edible” means that a food has been handled continuously under process controls established by law or rule, including documentation that the product has not been exposed to anything that would make it unfit for human consumption. Foods considered edible for people must also be manufactured in compliance with certain Food and Drug Administration regulations and state and local requirements for manufacturing facilities that produce food for people. Any foods or products that do not meet the above standards are “inedible.”

When it comes to the terms “human grade” or “human quality,” FDA spokeswoman Laura Alvey says the definition is self-evident:

“namely that the item is ‘edible,’ in legal terms, for people.”

Edible ingredients can become inedible in two ways: by being mixed with other ingredients that are not edible for people, or by being processed in a way that does not comply with the regulations for manufacturing, packing or holding human food as spelled out in Title 21 of the Code of Federal Regulations (21 CFR) Part 110 [21 CFR 110].

By those standards, only foods that are produced in USDA-inspected plants for human foods qualify as “human grade.” So a pet food could conceivably contain organic, locally grown, grass-fed beef from cows that lived a happy life and were humanely slaughtered, but if it was not processed in a particular type of facility or in a particular way, then it is not considered edible.

No matter how great the ingredients, using the terms “human grade” or “human quality” when the above conditions are not met is considered to be false and misleading labeling.

“Most pet foods are manufactured from inedible ingredients in plants that do not comply with continuous process controls to establish the final product as human edible,” says Dave Syverson, a representative for the Association of American Feed Control Officials. “If the pet food is manufactured in a plant that is using edible standard process controls entirely and all the ingredients used to make the food are edible because they were produced and handled using edible standard process controls entirely, then it is generally not considered to be false and misleading if the product displays the term ‘human grade.’”

Some pet foods are made to those exacting standards, and First Amendment rights to commercial free speech allow them to claim the product to be “human-grade.” I am aware of two of them: The Honest Kitchen (full disclosure: a PetConnection sponsor) and Bravo Raw Diet. Further disclosure: I occasionally feed both of those foods.

The takeaway: Just because a food claims to contain human-grade ingredients doesn’t mean it actually meets the standards for that designation. If a pet food makes those claims either on its labeling, on its website or in its marketing materials, call the company (all labels must contain contact information, by the way) and get the skinny on where its ingredients come from, how they’re handled, and in what type of facility they’re manufactured.

Photo credit: Steak, bigstockphoto

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