The Pet Food Institute (PFI) was a supporter of the NRC’s efforts to update the canine and feline nutrient requirements, previously published as two separate documents. Unfortunately, and despite significant scientific contributions of many experts from academia and the pet food industry, the NRC has fallen short of its goal of creating a reference document that can be practically used by pet owners, the government, and the pet food industry. One of the areas of great concern to the pet food industry is the flawed concept of safe upper limits (SULs).
SULs are a novel (if inappropriate) idea, first presented in the prepublication version of the guide, which purport to be the maximum level of nutrients an animal should receive before a physiological problem results. The problem with the SUL concept is that it is arbitrary and in many instances just wrong.
An example of how SULs might work in human terms might be that if the SUL for the consumption of hot dogs was two, and you ate three, you would have exceeded the SUL and serious consequences would result. The efforts to apply SULs in this document are variable, with many definitions, fail to reach any level of credibility, and indeed, their use could contribute to the formulation of inadequate diets.
SULs are, unfortunately, just one example of the problems the NRC has failed to correct in the final version of the report. PFI members offered a great deal of input to the prepublication report in the hopes of averting these errors. In addition to SULs, the recommended allowances (minimums) do not correlate with the SULs (maximums) and do not provide consistent data. Also, the analyses of some essential vitamins are not even included.
Finally, and most disturbingly to the rendering industry, is the fact that the new book lists fewer than half of the ingredients found in either of the previous dog (1985) or cat (1986) publications. For producers of animal-based ingredients, this document does a very poor job of discussing nutrient levels of their products, while completely eliminating many major ingredients from the listings. This problem could cause many excellent and broadly available sources of good animal nutrition to be considered inappropriate purely because they “are not listed in the NRC.”
For instance, there are no listings for “meat” or “striated muscle” for beef, lamb, or pork; in fact, there are no listings for any pork ingredient except bacon. Pork ingredients are widely used in the pet food industry and this document gives absolutely no credence to their importance.
Further, proximate analyses for “poultry” ignored the fact, shown in the 1985 dog publication, that there are different analyses for varying stages of poultry used as ingredients, i.e., broilers, hens, or whole birds. There is no listing for chicken by-products, fresh eggs, and many other sources of protein derived from animals.
In addition, the document lists three types of fish, compared to 20 in the 1985 edition for dogs, and never allows that whole fish, fish liver meal, or fish solubles (two kinds, in fact) could be used for dog or cat food.
Though PFI has a great deal of concern with the implications this document holds, we believe it did meet one of its stated goals in that it can be used as a reference on canine and feline nutrition by students and teachers at universities. Nutrient Requirements of Dogs and Cats is a good literature review but, unfortunately, that is all it is. It becomes quite obvious that this publication cannot be compared to the former documents with any degree of reliability, and cannot serve industry professionals in any cogent manner.
PFI and its members had hoped that the NRC would take to heart many of the industry’s concerns with the pre-publication document and make valuable corrections. Since they have chosen to publish as a final report a deficient and confusing publication, it is highly unlikely industry professionals, government regulators, or, even less likely, pet owners will see the report as what it purports to be – that is, the gold standard of information for dog and cat nutrition.
And the rendering industry should be very concerned about negative perceptions of its products that might occur if this document attains any significant level of use.
Tech Topics - August 2006 Render