There are a number of concerns surrounding the World Small Animal Veterinary Association (WSAVA), including its failure to address or provide adequate security to anyone who recommends pet food using its criteria.
What is the manufacturer of your pet food?
Pet food companies are encouraged to employ a qualified nutritionist on a full-time basis, as well as to provide credentials of the nutritionist. Why is this relevant? According to WSPA and similar organizations, the presence of a nutritionist on a full-time staff guarantees safe and nutritionally adequate food; however, this may not be the same as the nutritionist formulating and/or validating the food. In the event that the nutritionist works in sales, marketing, or education, creating brochures and presentations for the company, what is the value of having that individual on staff when it comes to nutrition?
A question such as, “Who developed the pet food currently available in the marketplace?” is quite different from “Do you employ a full-time nutritionist?” The answer will likely vary depending on the manner in which it is posed. In fact, it is common for companies with large portfolios to not have nutritionists formulating everything from concept to retail.
Furthermore, having a board-certified nutritionist serve as an advisor for the company does not mean much. As for the pet food that you are currently selling in the market, what you really want to know is whether it was developed by a qualified nutritionist from concept to delivery. You should also inquire, “Are all of your pet foods available today in the market the same way?”
A nutritionist on staff who does not work on the formulation of the product is irrelevant and can be misleading. Asking a company whether they have a nutritionist on staff is irrelevant.
Pet Food Nutrients
WSAVA does not include this question in its criteria, despite the fact that all pet food companies should be able to answer the question. People (including WSAVA members) should not be afraid to ask pet food companies, “What is your typical third-party analysis for all your foods?” This should be one of the criteria that people should not be afraid to ask. There are many businesses that cannot meet the criteria. This is because most of them do not conduct nutritional analyses of their final products before they enter the marketplace, or at least not all of their products. Due to the low barriers to entry, pet food is not required to meet this requirement.
For a pet food company to meet the nutritional criteria, it is only necessary to provide an in-depth nutritional analysis for one formula in its portfolio. As we live in a world of open-access journals and websites, WSAVA should ask the question, “Do you provide all of your pet foods with a comprehensive nutrient analysis on your website?”
Furthermore, WSAVA should inquire about the quality of the pet foods on their website by asking, "Do you provide digestibility results for all your products?" In this way, you will have a better understanding of the nutrient content of all the foods and the availability of those nutrients. Particularly relevant is this aspect of kibble food, which can contain 60 to 90% crude protein.
It is not proprietary to analyze nutritional data and conduct digestibility studies on pet food. If they were, people could not conduct their own digestibility studies and send their pet food to a third-party laboratory. A formula is proprietary; a nutrient analysis and digestibility analysis are not - they are two very different things. Any company that informs you otherwise either has a significant knowledge gap or has a problem with transparency. The owners and veterinarians of pet food have a right to know what nutrients are in the food, where they can be found, and whether the food is digestible.
How are your pet foods made?
It has been widely taught to consumers, retailers, and veterinarians that pet food manufacturers own their manufacturing facilities. This is inaccurate and creates the illusion of safety.
As a result of vitamin D toxicity in canned dog foods manufactured by Hill's Pet Nutrition's manufacturing facility in Topeka, Kansas, three recalls were issued in January 2019 (an initial recall and two subsequent recalls). Hill's received a warning letter from the Food and Drug Administration (FDA) in November 2019. It said the problem was due to Hill's failure to get a certificate of analysis after it got the vitamin premix from its supplier. This was due to its failure to test, failure to evaluate against the formula, and failure to reject excess vitamin D from the vitamin premix.
Even though these steps were in Hill's food safety plan, FDA couldn't make sure they were working since the company wasn't following its own written procedures. There was no mention of the root cause for not following them (e.g., complacency, cost savings, not waiting for the analysis, etc.).
A lot of pet food companies, like Evanger's Pet Foods, own their facilities and manufacture their own food, as well as businesses. The businesses, and are plagued with quality control, sourcing, and legal problems. How about the pentobarbital problems? Clearly, owning the facility didn't prevent those from happening.
Quality Control And Food Safety
In addition to thinking that hiring a nutritionist full-time means better food, WSAVA also believes that companies with quality control measures ought to be recommended. As we've seen from the recalls, that theory is wrong and the fox is watching the hen house.
What's the point of the procedures if you don't follow them? FDA actually asked Hill that question! If they asked WSAVA, “Do you have third-party certifications for food safety and quality control?” they would get a whole different answer. For proper quality control and food safety procedures and documentation, there are tons of third-party organizations that audit and provide certifications. Furthermore, companies have to audit themselves every year or bi-annually to make sure they're following the rules.
Co-manufacturers are actually required to go through a third-party food safety audit (or two) every year. Certifications are revoked if a company doesn't meet the requirements. You don't have to trust that the pet food manufacturer or company is doing what it's supposed to be doing; rather, you just need to ask if they're a member of an active association or certification program. The websites of many companies that possess third-party certifications (e.g., SQF, ISO, etc.) prominently display them. Contact a consultant if you want more info about sqf certifications.
The FDA website lists recall from companies who own their manufacturing facilities, ironically the majority of them come from firms that own their plants. Let me know if your company owns its facilities!
Have there been any studies conducted on pet food?
Does WSAVA publish the results of studies in peer-reviewed journals? WSAVA implies that manufacturers who publish and conduct research in peer-evaluated journals have some superiority. However, they seem to forget that research and peer-evaluated papers do not always equally good science. It is not uncommon for companies to support research both for self-interest (e.g., product development) and also for proprietary reasons. The veterinarian and the consumer do not have access to all data and results.
A conflict of interest can also be a factor to consider when companies publish meaningless studies and inadequate data that do not benefit the companion animal nutrition community. As long as a pet food company is doing due diligence via analysis, and food safety and has an individual or team behind the formulation, doing research is not a disqualifier for pet food.
Recommendations For Pet Food Need To Be Overhauled
In 2013, WSAVA published recommendations for selecting pet foods that may have been of some value, but now is the right time for a fresh look. There should be a greater focus on transparency as a whole, not on a select few “industry partners” who aren’t as transparent as you might think when you rephrase the questions.
Furthermore, if these are true “recommendations” based on important criteria for pet food, shouldn’t the entire Hill’s canned dog line implicated in the vitamin D recall be taken off the WSAVA recommended list? When WSAVA updates its recommended guidelines based on my recommendations, it should consider involving people who do not stand a financial benefit from pet food sales or academic research funds.
However, some people are puzzled as to why Nestle Purina and Mars Pet care both contribute to multiple levels, versus just their parent company, when it is more transparent in that it provides a list of its industry partners and ranks them according to their contributions; however, this does make WSAVA more transparent.
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