In April 2018, I wrote an article titled: Pet food transparency: buzzword, urban legend or reality? I meant it when I said that, “Transparency should be exactly what it means: transparency”. I believe that pet owners want and need to be educated so they can become advocates for their own pets. Especially, when it comes to asking, “what food should I feed my pet?” Even more so following the DCM fiasco that has ensued and continues to this very day because of lack of transparency for simple things like nutrient content and digestibility.
When Jim and I started Guardian Pet Food Company in 2017, which you now know for our NOBL food bars and treats, we set forth to establish new standards for the industry by supplying basic questions consumers, retailers, and veterinarians should ask pet food companies—regardless of size and how long they have been around.
Seek Answers To These Key Questions:
Who formulated the food in the marketplace?
Do you perform 3rd party nutrient analysis?
Do you perform 3rd party digestibility?
Does your manufacturing facility (owned or not) have a third certification for quality control and food safety?
Where do the calories come from?
Who Formulated Your Food?
Retailers, veterinarians, and consumers typically will ask, “do you employ a full-time nutritionist?” Why? Some organizations and groups will have you believe that simply having a “nutritionist” as a full-time staff means that the food is going to be safe and recommendable; however, if the nutritionists works in the sales and marketing group making brochures and presentations for the company then what is the value of having that person on staff?
Asking the question, “Who formulated the food in the marketplace?” is very different than “Do you employ a full-time nutritionist?” As a result, you will likely get a different answer based on how the question is asked.
Also, having a board-certified nutritionist as an “advisor” does not mean anything either. What you really want to know is, “did a qualified nutritionist formulate the food from concept to delivery of the finished product that is on the shelf in the marketplace today?” This gives transparency into who is truly behind the product. If a company has a nutritionist on staff and that person was not involved in the formulation then the question, “do you employ a full-time nutritionist?” is irrelevant and can be misleading. For the record, I formulated our products and oversaw the formulations from concept to what you see on the shelves today. If you want to learn more about my background and credentials, view my LinkedIn profile.
3rd Party Nutrient Analysis
People should not be afraid to ask pet food companies, “What is your 3rd party typical analysis for ALL your foods?” All pet food companies should be able to answer this question. Why? If they cannot answer the question, then the food should not be in the marketplace. Unfortunately, many companies simply use least-cost formulation software like Concept5. In short, this computer program utilizes ingredient analysis information supplied by the pet food company and formulates for “targeted” nutrition using a least-cost algorithm. Said differently, how can I deliver the targeted nutrition the least expensive way?
Unfortunately, many companies take this targeted or theoretical nutrient profile and do not verify it via 3rd party nutrient analysis following actual production. It is an unfortunate reality in the industry because the actual nutrient value of a product and how it is metabolized can vary greatly than what a computer predicts. Many companies may tell you their nutrient analysis is “proprietary”. However, it is likely an excuse to hide that they do not have the data and never it sent it out for nutrient analysis of complete AAFCO profile.
If it was truly proprietary, then people would not be able to simply send the food to an analytical lab and get the answers themselves (~$2500 plus the cost of food for the analysis). Formulas are considered proprietary, nutrient analysis is not – they are two different things!
Side note, nutrient analysis for launching foods IS NOT a requirement for selling a product by the FDA or AAFCO. It is simply the right thing to do! That is why we supply this information about ALL our foods in the marketplace on our website. We analyze them during development, launch, and after launching the product. That is why we provide our information as “typical” analysis not targeted. It should not be a onetime occurrence before launch. Most companies when asked for an AAFCO profile analysis will provide a targeted (computer algorithm) analysis, not the typical or nothing at all.
3rd Party Digestibility
People should also be able to ask a company, “what is your 3rd party digestibility of all of your formulas?” Again, all companies should have this information if they are doing their due diligence in assuring proper nutrition in ALL their foods.
This goes beyond how much poop do I scoop question. Digestibility study results are an important indicator of ingredient and food quality. If you do not have this basic information, then knowing the nutrient analysis of food is irrelevant. For example, if there is enough protein in the food; but the digestibility of protein is low then the requirements of the animal may not be met. But, your grass will be lush and green!
Unfortunately, many companies may also call this information “proprietary”. Once again for ~$2500 and the cost of food for testing, anyone can send and get results from a third-party testing facility in less than two weeks (hardly proprietary).
Did you know that crude protein digestibility for kibble can range from 64 to 91%? Maybe that is why the company does not want to share the data.
If companies are not performing complete nutrient analysis or 3rd party digestibility on ALL their products before launching them into the marketplace, they are truly doing a disservice to consumers, retailers, and veterinarians. This is setting the pet food industry up for failure again similar to certain groups believing grain-free foods cause DCM resulting from lack of information and transparency for consumers, retailers and veterinarians.
We also provide 3rd party digestibility information for ALL our foods on our website.
3rd Party Food Safety Audits
Many consumers, retailers, and veterinarians have been taught that owning your manufacturing facility equals better quality control and food safety. That is simply not true, here is why:
In In January 2019, Hill's Pet Nutrition issued 3 recalls (initial recall plus 2 significant expansions) tied to vitamin D toxicity in canned dog foods made in their own manufacturing facility in Topeka, KS. In November 2019, Hill’s received an FDA Warning Letter citing the root cause of their issues being a failure to obtain a Certificates of Analysis (COA) upon receipt of the vitamin premix from their supplier, failure to test, failure to evaluate against their specifications, and subsequently failing to reject the vitamin premix containing excess vitamin D, as required by Hill’s food safety plan. Furthermore, the FDA could not verify if the corrective actions would work because Hill’s Pet Nutrition was not following their own written procedures, nor did they identify the root cause in the failure to follow them (i.e. complacency, cost savings, couldn’t wait for analytical results?).
Ironically, the same organization that believes employing a full-time nutritionist equates to a better food also believes that knowing what quality control measures the company has in place warrants a recommendation as well. Well, the last paragraph proves that theory wrong, and its simply asking the fox the watch the hen house. What good are the procedures if you do not follow them?
Now if the organization asked, “do you have a 3rd party certification for quality control procedures and food safety?” then they would get a vastly different answer. Did you know that there are many 3rd party organizations that routinely audit and provide certifications for proper quality control and food safety procedures and documentation? More importantly, they make sure you adhere to them.
In fact, many co-manufacturers go through a 3rd party annual (or biannual) food safety audit similar to programs like Safe Quality Food (SQF) Institute to receive a certification. If they fail to meet their requirements, they lose the certification. In short, the consumer does not have to trust that the pet food company or manufacturer is doing what they are supposed to be doing. Instead, you can simply ask if they are actively credentialed. In fact, many of the companies that do have 3rd party certifications will tout them on their website (i.e. SQF, ISO, etc.).
I wonder how many companies that own their manufacturing facilities have 3rd party certifications? It is not proprietary, ask them! Also, you should ask, “does the company perform a microbial analysis on finished goods to ensure both animal and pet owner safety?” It is well known that microbial contamination of pet foods can also cause illness in humans.
All NOBL products are made in an SQF certified facility in Canada. We test ALL our finished goods for microbes before it leaves it our facility. If the test comes back positive for salmonella, or any other pathogen, we do not ship. This is OUR requirement for manufacturers that make NOBL products.
Where Do The Calories Come From?
Marketing claims can often be very misleading to pet owners. Especially when certain companies toss around terms like “biologically appropriate” and the same company later defends it in court as "nonactionable puffery." Frankly, we at Guardian and makers of NOBL foods believe it is a misleading nutritional statement.
In 2012, Hewson-Hughes et al. performed diet selection studies in 5 breeds of adult dogs (papillon, miniature schnauzer, cocker spaniel, Labrador retriever and St Bernard to determine whether domesticated dogs could regulate macronutrient intake. Using nutritional geometry, they showed that the macronutrient content of the diet was regulated to a protein:fat: carbohydrate ratio of approximately 30%:63%:7% by energy. This ratio was consistent across all the breeds studied regardless of size. So, what does this mean?
The study indicates that when dogs are given the choice to self-select for macronutrients, they are going to select foods which are lower in calories coming from carbohydrates. Why? The answer is simple. Dogs do not have a requirement for carbohydrates. The DO have a requirement for essential amino acids and fatty acids. Additionally, these same protein and fat sources are going to bring other essential nutrients like vitamins and minerals.
Do you know what requires high carbohydrates? Extruders. The extruders that are used to make common kibble are like those used to make household breakfast cereals. High carbohydrate content is required for kibble expansion during processing, for shape and holding the kibble together.
So where am I going with this? Where the calories come from in your pet’s food is important. Instead of you having to guess where the calories are coming from in our products, we provide a graph on all our products including treats on our packaging and website. We believe in transparency and you should not have to try and figure out the math in an aisle at your local pet store.
Most dry foods in the marketplace contain 30% or more carbohydrates.
No one should be afraid to ask the questions I posed above to any pet food company. If they tell you that the information is “proprietary”, then take the quote from the Princess Bride. It all comes down to how transparent that company really wants to be to the consumer.