AAFCO & NRC Standards
There is a lot of talk lately of how raw feeding, especially “ratio diets”, are somehow deficient in certain nutrients and that everyone needs to be feeding according to AAFCO or NRC standards. This is misleading and sadly unfair to an entire community of raw feeders.
The raw diet was designed for carnivores by an expert called Mother Nature whose history is as long as evolution. Prey Model Raw is based on the average ratios of prey found in the wild. The ratios will vary of course depending on the animal but for simplicity we meet within the average ratio of 80/10/10- 80% muscle meat (this includes muscular organs), 10% bone, and 10% secreting organs (5% of which must be liver) with the addition of fish and eggs.
Being our dogs and cats aren't in the wild and therefore don’t have to fend for themselves, this is when we come into play to provide them with the best nutrition possible. How? With variety! Our companions ancestors would consume 3-4 whole prey sources but typically not on a daily basis. We however, can provide this many proteins and more (whether that’s in the form of whole prey or “Frankenprey”) balanced daily or on a weekly basis to further provide a nutritionally complete diet.
According to those that push AAFCO and NRC standards claim that no matter the variety the diet has it’s still nutrient deficient and somehow manage to have a “one size fits all recipe”. Following these standards actually could be harming your companion and could put high quality raw food companies out of business.
Let’s go over who these two organizations are...
The Association of American Feed Control Officials (AAFCO) is an organization responsible for providing the standards and recommendations for both companion animal and livestock feeds. However, AAFCO does not test pet food samples to see that they meet their label guarantee nor do they test raw foods. It’s up to the pet food manufacturer to responsibly make the pet food according to AAFCO standards. In fact, the guaranteed analysis of the food and whether or not it truly meets AAFCO standards may never be verified by a regulatory authority.
Currently there are three statements pet foods can have on their label that’s AAFCO approved. These statements are:
1. “Animal feeding tests using AAFCO procedures substantiate this product provides complete and balanced nutrition for all life stages of dogs and cats.” This means the company chose to conduct feeding trials on their food. Presently, only eight dogs are required to be in an AAFCO feeding trial and only six have to complete it for that trial to qualify. These trials are only run for 26 weeks and only 4 values -hemoglobin, packed cell volume, serum alkaline phosphatase (SAP) and serum albumin are evaluated. There is no full blood chemistry panel, no complete blood count and no urinalysis required. Before and after the trial a veterinarian will examine the dogs and look for clinical signs of nutritional disease, but unless a food is obviously mis-formulated, it’s highly unlikely the dog will develop clinical signs of a problem within this short period of time. According to David Dzanis of the FDA, “Especially in the maintenance trials, subtle chronic nutrient deficiencies or excesses can be overlooked.”
2. “This product is formulated to meet the nutritional levels established by the AAFCO Dog and Cat Food Nutrient Profiles for All Life Stages (or for growth).” Rather than doing feed trials these manufacturers choose to formulate their food to meet AAFCO nutritional panels.
3. “This product is intended for intermittent or supplemental feeding only.” This means the food does not meet AAFCO nutrient profiles. You'll notice a lot of commercial raw foods display this on their label. If raw food manufacturers were forced to produce food that meets AAFCO standards like kibble manufactures they would be causing more harm than good. However, having this on their label does not mean they’re nutritionally inadequate. The AAFCO fully admits that raw foods just aren’t feasible to be applied to their standards “...the majority of complete pet food products are not raw. They have been heat-treated during manufacturing to prevent microbial contamination. Pet food manufacturing plants often have limits regarding the receiving, storing and use of ingredients that make most raw ingredients impractical.” By this statement alone, the AAFCO is irrelevant to raw food and raw food principles.
By definition The National Research Council (NRC) produces reports that shape policies, inform public opinion, and advance the pursuit of science, engineering, and medicine.
Problems with the NRC's Requirements:
It may not be based off actual fresh food ingredients
It’s 14 years outdated. The first edition was in the 80’s and the current was published in 2006 (it’s currently 2020 at the time this article was written)
There's a huge conflict of interest
While the NRC requirements *claim* to be based on the bioavailability and digestibility of nutrients that are unprocessed there are sections that suggest otherwise. Such as this statement on the opening page of the 2006 Nutrient Requirements for Dogs and Cats …
“This edition contains the latest data on requirements that are based on the utilization of nutrients in ingredients commonly produced and commercially available in dog and cat foods rather than only on purified diets.”
What does “purified diets” mean? “Purified diets use refined ingredients such as casein, sucrose, cornstarch, and cellulose. These human food grade ingredients have relatively simple chemical compositions (predominantly one nutrient classification) and this feature is important for manipulating individual nutrients for research purposes.”
The 1985 and 1986 edition of Nutrient Requirements for Dogs and Cats were based on “purified” human grade ingredients.
The 2006 version however was not based on human food grade ingredients. The 2006 NRC requirements are based on the “utilization of nutrients in ingredients commonly produced and commercially available”. Common ingredients such as genetically modified grains (GMO’s) and rendered meat meals including those sourced from dead, diseased, dying, and disabled animals.
Who funded the NRC’s research?
The 2006 edition of Nutrient Requirement of Dogs and Cats was funded by the FDA, the National Institute of Health (NIH) and….. the Pet Food Institute (PFI). The NRC considers those that hire the institution to perform a study as “sponsors”. In this case the NRC entered into a ‘private contract’ between sponsors FDA, NIH and PFI.
“Once a project is funded, the National Academies seek nominees for members of consensus study committees from many sources, including the sponsors.”
“Sponsors are typically invited to make presentations to the committee at its first couple of meetings to discuss the sponsors’ expectations for the study. Also, the sponsor is asked to provide as much information relevant to the study as possible.”
As a result, the FDA, NIH and the PFI were allowed to nominate study committee members AND discuss what their expectation is for the study.
Conflict of Interest
According to the NRC...“It is essential that the work of committees of the institution used in the development of reports not be compromised by any significant conflict of interest. For this purpose, the term “conflict of interest” means any financial or other interest which conflicts with the service of the individual because it (1) could significantly impair the individual’s objectivity or (2) could create an unfair competitive advantage for any person or organization.”
Despite saying: “it is essential that the work of committees of the institution used in the development of reports not be compromised by any significant conflict of interest” There’s a few things that could be looked upon otherwise. The 2006 study was partially funded by an organization whose members could certainly benefit from the outcome (the Pet Food Institute and its members). Apart from that some of the board members of the Agriculture and Natural Resources Division ( division of the National Research Council hired to perform the 2006 Nutrient Requirements of Dogs and Cats study) include:
Gail L. Czarnecki-Maulden -senior research nutritionist at Nestle Purina PetCare. She also served on the AAFCO’s Canine and Feline Nutrition Experts Subcommittees.
Gary F. Hartnell -a Senior Fellow of the Monsanto Company. His job is to conduct research on GMO crops in livestock for regulatory, industry and consumer acceptance.
Robbin S. Johnson -Although retired from Cargill (the largest privately held corporation in the United States in terms of revenue) is President of the Cargill Foundation.
Mercedes Vazquez-Anon -Director of animal nutrition research at Novus International, a leading developer of animal health and nutrition programs for the food animal industry.
Gene Hugoson -a Senior Fellow with the Global Initiative for Food Systems Leadership (GIFSL). GIFSL was formed in 2009 by the University of Minnesota in conjunction with Cargill, General Mills and several other major food corporations.
In 2006 the Center for Science in the Public Interest published a very concerning report finding “serious breaches” to conflict of interest.
“Nearly one out of every five scientists appointed to an NAS panel has direct financial ties to companies or industry groups with a direct stake in the outcome of that study….”
“NAS did a poor job of balancing points of view on a majority of the study panels examined. The NAS does not appear to consider information about potential bias or conflicts of interest prior to nominating individuals to a committee. As a result, about half the panels examined had scientists with identifiable biases who were not offset by scientists with alternative points of view…..”
“The NAS provides brief biographies of nominees to its committees on the agency’s website. Such biographies could assist people who were considering commenting on a committee’s composition. However, those biographies are woefully inadequate because, in a majority of cases, they fail to provide crucial data regarding conflicts of interest and points of view…..”
(NAS the National Academy of Science whom the NRC is the working arm of.)
How are the two related?
The AAFCO has used some of the NRC’s recommendations (but not all) and while they have accepted some of these more scientific methods,the AAFCO standards haven’t been reviewed since the 1990s. Originally nutrient standards from the AAFCO were based on NRC requirements until 1995.
What about all the supplements everyone uses to meet these standards?
A lot of these supplements being used are synthetic and can cause a lot more harm than good. Ron Carsten DVM MS (The Benefits of Whole Food Nutrition in Veterinary Medicine,Whole Food Nutrition Journal) states: “Synthetic vitamins and other substances are added (to kibble) in an effort to compensate for this nutrient loss. However, these additives create ongoing metabolic stresses that, coupled with the limited ingredient selection and processing of foods, leads to situations in which cellular nutritional status can be compromised, causing tissue malnutrition.” With a raw diet all of these vitamins are met and in the proper amounts.
You may have seen that the diet is lacking in things like zinc and Vit E however the AAFCO’s requirement for zinc, is based on the low bioavailability of zinc in kibble. Phytates in kibble bind with zinc, making zinc unavailable to the dog. There are no phytates in a PMR diet so this isn’t an issue.
Vitamin E comes in two forms d-alpha or dl-alpha. Only one is found in nature, the other is the mirror image. Synthetic alpha- tocopherols, besides differing chemically in structure, vary in absorption, metabolism, and bioactivity.
“The topic of vitamins (and trace minerals) is actually larger than degree of bioavailability. As an example, how do all the wild canids throughout the eons of history manage to thrive and reproduce without ever consuming the first molecule of micronutrient from a commercial source? …All live well without any vitamins added to their diet. Insight to this situation is gained from research done by pioneer vitamin investigators of the 1920s and 1930s. They could not produce a vitamin deficiency unless feeding a diet high in soluble carbohydrate.” -Dr. Richard Patton author of ‘Ruined By Excess, Perfected By Lack: The Paradox Of Pet Nutrition’
This would include carbohydrates such as oats that are being pushed for the sake of manganese however, manganese is found in plenty of meat sources and there is no definitive proof of just how much our dogs and cats absorb.
Mother Nature didn’t make a mistake with a carnivores diet and if she did, they wouldn't be in existence anymore! There are millions of people feeding a species appropriate raw diet without the use of synthetic supplements or carbohydrates all for the sake of meeting these “one size fits all” standards. Standards created by organizations that’s funded by those with conflicting interests. While “ratio” PMR diets may not fit into the AAFCO or NRC standards that doesn’t mean it’s nutritionally deficient!