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September 19, 2008: Pfpsa.org responds to recent statements by Nutro. For decades, the National Research Council (NRC) was the recognized authority on pet nutrition. Its recommendations were based on comprehensive scientific studies conducted over the course of years of extensive, in depth research. It is unclear how, or exactly when, AAFCO, which evolved as a feed manufacturer’s lobbying organization, usurped the authority of the National Research Council to make recommendations on the dietary needs of companion animals. In fact, based on communications with an official at AAFCO, AAFCO largely adopted NRC recommendations in its recommended formulations for dietary supplements in pet food. However, pfpsa.org, having carefully examined those recommendations, believes the manner in which those recommendations were calculated are inherently flawed as they are based exclusively on the dry matter content of the food. Moisture content in pet food varies between roughly 10% and 80%, which makes the dry matter content irrelevant to “as fed” values. Nutro claims: “In order for a food to provide all the essential nutrition for a pet, it must exceed the minimum requirements for all essential nutrients.” The claim is inherently foolish. More is not better. In numerous studies conducted in recent years, it has been found that overdosing on various supplements is not only unnecessary for good health, but depending on the substance, may pose extremely dangerous health hazards. Take vitamin D for example. At recommended levels, it is a necessary element for good health. At high levels, it is used commercially as rat poison. Over supplementation of pet food becomes an even more critical consideration than it is with people, as pets typically receive all their nutrition from a single source - the pet food they eat every day. Where the variety of a human’s diet lessens the likelihood of chronic exposure to over supplementation of a substance, a pet may be chronically exposed for years on end as a result of being exposed to the same food, which is their sole source of nutrition. The National Research Council sets the daily requirement for copper at 1.5 mg for a 33 pound dog, and zinc at 15 mg. See link. Nutro claims: “In addition to meeting a dog's nutritional requirements, many Nutro™ products incorporate the scientific knowledge of the WALTHAM Centre for Pet Nutrition which has researched the role of key nutrients in delivering optimal skin and coat health and consequently have levels of zinc, copper and other nutrients that are higher than industry minimums. These nutrients serve as key drivers in maintaining skin and coat health and help to make Nutro™ products nutritionally sound.” Pfpsa.org would again point out that the recommended daily allowance of zinc in a human diet is 15 mg. Assuming an average person weighs 150 pounds, based on body weight, the 15 mg of zinc recommended by NRC for a 33 pound dog factors in additional zinc requirements by 4.5 times. The NRC copper recommendation for a 33 pound dog is 1.5mg. Based on recommended feeding guidelines for dry dog food, a 33 pound dog would consume approximately one pound of food a day. On that basis, one pound of the dry dog food tested by pfpsa.org comes in at 180 mg zinc and 7.6 mg copper in one sample, and 116 mg zinc and 9.9 mg copper in the other. That works out to 8 to 12 times the NRC recommendation for zinc, and 5 to 7 times the NRC recommendation for copper. Nutro states: “The report is correct in stating that there is a small minority of dogs that are sensitive to copper.” Indeed. That being the case, where is the warning on Nutro dog food that the massive doses of copper in its products are potentially lethal to certain dog breeds? Citing AAFCO’s 2008 Official Publication, at page 134: “New data and practical experience supported an increase in the minimum level for zinc to 120 mg/kg DM (14). A maximum level of 1000 mg/kg DM reflected the maximum tolerance level recommended for swine rations. (12)” Footnote (14) refers to a single publication, which apparently is not in conformity with decades of previous research. AAFCO offers no rational for basing maximum levels on the tolerance levels in pigs, which are notoriously resistant to many toxic substances, including zinc. With the exception of turkeys and pigs, zinc is toxic at levels well below 1000 ppm in as fed diets for most species. (see link) The World Health Organization describes zinc poisoning incidents in humans. From the link: “high concentrations of zinc.. have been linked with effects such as severe abdominal cramping, diarrhea, tenesmus, bloody stools, nausea, and vomiting... The amount of zinc ingested was estimated to be approximately 325–650 mg.” Nutro states: “The most notable information in the posting, and the subject of its title, "Expert Finds Unexplained Pet Deaths 'Not Consistent,'" are the findings of Dr. Steven Hansen, a veterinary toxicologist at the ASPCA. Dr. Hansen conducted an in-depth review of the complaints against Nutro and concluded that the complaints appear to be random, non-pet food related health issues.” As a major recipient of pet food company largess, one might reasonably question if there is a conflict of interest when it comes to the ASPCA’s honesty in reporting problems with their pet food company benefactors' products. These are the complaints as reported to Consumer Affairs. You be the judge. How many of them are fully consistent with the symptoms of zinc toxicity as reported by the World Health Organization? And, if 325 mg of zinc produces these symptoms in a 150 pound human, what does 180 mg do to a 33 pound dog? Nutro states: “The claims regarding the safety of Nutro pet food in a recent report posted on the Pet Food Product Safety Alliance website are unfounded.” The Pet Food Products Safety Alliance makes every conceivable effort to carefully research and carefully document, from credible sources, statements posted to the site. We base our reports on well documented facts, and not on pseudo science compiled by industry lobbyists and/or their patrons. Again, you be the judge. At the very least Nutro openly admits it has no problem with providing massive doses of copper to pets it knows it could kill. What if the pet it kills is yours? Maybe it doesn’t matter to Nutro, but it is certain to matter to you. While Nutro may view a shiny coat as desirable on sick, dead or dying pets - whether well founded or not - the Pet Food Products Safety Alliance does not share that view. |