In 2001, the US Food and Drug Administration (FDA) approved
a petition broadening the use of irradiation of animal feeds to
include petfoods, treats and chews. That same year, the
Association of American Feed Control Officials (AAFCO) accepted
the feed term "natural" and established guidelines concerning
its use on petfood labels.
Because these two independent matters were in development
during the same period, the AAFCO definition fails to address
whether an irradiated product is considered natural. A recent
letter from FDA to the chair of the AAFCO Pet Food Committee
opines it currently does not.
What is irradiation?
Under FDA regulations, ionizing radiation can be from either
of two origins:
The former are the result of energy shifts in orbiting
electrons of molecules, while the latter come from energy
shifts within the nuclei of atoms. Other than their origins,
though, the two types of radiation are virtually
indistinguishable from each other, as the range of wavelengths
used to define one versus the other largely overlap.
In neither case does the food incorporate or come in direct
contact with radioactive material, nor is there a chemically
synthetic step to the process.
The approved purpose of irradiation of petfoods is for
microbial disinfection, control or elimination. While not
intended as a replacement for other appropriate sanitation
measures, it gives the manufacturer another weapon in the
arsenal against potential microbial contamination. Irradiation
may be more suitable for some types of pet products compared to
others, but considering the heightened concern regarding
petfood safety today, all manufacturers should consider it a
potential means to address safety issues.
Natural or not?
There are many different ways to interpret "natural," which
led to wide misuse of the term on petfood labels in the past.
To help provide consistency in meaning and a basis to uniformly
interpret use of the term, AAFCO defined it to differentiate
products and ingredients in terms of their sources and
processing methods. For example, natural products or
ingredients must be of animal, plant or mined sources but can
be ground, cooked, dried, rendered, purified, extracted,
hydrolyzed or even fermented.
The key factor in determining the applicability of the term
is that anything that is manufactured by means of chemical
synthesis or contains a chemically synthetic substance is not
natural (at least not without further qualification, such as
with a petfood containing synthetic vitamins but otherwise
meeting the definition).
Of course, not all people would necessarily agree with this
definition. For example, many consumers would not consider
chicken meal, wheat middlings, sugar or salt to be natural, but
those ingredients are natural under AAFCO. On the other hand,
because the bulk of commercial ascorbic acid (vitamin C) used
in petfoods is chemically synthesized, this source would not be
natural, despite the fact that vitamin C occurs in nature as
Aside from these perceived discrepancies, the AAFCO
definition as it exists today is the only basis by which the
matter of irradiation can be rationally discussed.
Why is FDA concerned?
In its letter to AAFCO, FDA rightly notes that irradiation
is not the same as heat processing, rendering or other
processes allowed under the natural definition. It ponders
whether purification could apply to irradiation, but frankly, I
do not believe that was the intent when the definition was
Rather, the process most likely was not mentioned because
irradiation was not approved for use in petfoods while the
definition was being developed. Unfortunately, the list of
processes is not preceded by "such as" or similar phraseology
that would allow for tacit extension of the list when
appropriate. Thus, FDA concludes that irradiation effectively
nullifies characterization of a product with the term "natural"
as currently defined.
While irradiation may not be expressly named among the
allowed processes for natural products or ingredients, the
intent of irradiation is the same as some of the processes that
are allowed, which ultimately is to help ensure microbial
safety of the finished product. Essentially, heat is another
form of radiation (infrared).
Also, ionizing radiation cannot be characterized as, nor
does it result in, chemical synthesis, the key part of the
natural definition. In my opinion, then, irradiation should be
included among the processes allowed.
Let consumers decide?
Under current FDA regulations, the labels of irradiated
petfoods must bear a Radura symbol, accompanied by the words
"treated by irradiation" or "treated with radiation." FDA notes
in its letter that few consumers may think of irradiation as
natural. That may be true, but the same could be said of other
processes or ingredients currently allowed under the natural
Regardless, as long as the label discloses that the product
has been irradiated as required under the regulations, it
should be up to consumers to decide whether use of the term
natural to describe that same product is inconsistent. They can
then make their purchasing decisions accordingly.
I would encourage amendment of the AAFCO definition for
natural to include irradiation for sake of clarity. In the
interim, I hope state feed control officials look at the spirit
of the definition and opt not to enforce label changes that
could, in fact, compromise the safety of petfoods.
Public meetings invited comments and provided updates
The mid-year meeting addressed several regulatory matters affecting petfoods
It gives more direct control to CVM in establishing and maintaining ingredient definitions
The intent was to educate regulators and industry about the Model Pet Food Regulations
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