Category Archives: Politics and Media

Video: “Science Death Experiment” from Dr. Tom Lonsdale

Great title, greater video! Tom Lonsdale is an Australian veterinarian and one of the more recognized names in raw-feeding advocacy. He and his clinic, Bligh Park Pet Health Centre, are working on a study to determine the changes that take place when a dog who has been on a raw food diet starts eating processed food. As of February 2015 I believe we are still awaiting the outcome of the blood panels and a more complete report from Dr. Lonsdale, but this video is a start and worth four minutes of your time — promise. Following is an embedded link to the video, which is on the Bligh Park Pet Health Centre Facebook page. If it doesn’t work here, you can click over to the clinic’s page and watch it. For more from Dr. Lonsdale you can check out his (totally amazing) website, and/or pick up his books, Raw Meaty Bones and Work Wonders



Science Death Experiment, a video from Dr. Tom Lonsdale


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Sensationalism Killed The Cat: The “Consumer Funded Pet Food Test”

On January 4th, 2015 the “Association For Truth In Pet Food” (referred to hereafter as AFTIPF) published a report called The Consumer Funded Pet Food Test. The prolific and popular blog and website “The Truth About Pet Food” (TAPF) — which is linked in personnel and other ways — posted a blog with the same title. When one of my “dog friends” brought it to my attention, at first I thought, “Wow, cool.” Then I took a closer look at the 52 page “report” and I’ll admit to getting kind of angry. I’ll tell you about what made my blood boil, but I’d also like to squeeze out some positive, which comes in Part II. I feel both parts are equally important.

Sensationalism Killed The Cat (image: Old Mother Hubbard's Dog Reads the London Gazette, 1819 -- public domain)

Why would I feel the need to call attention to this on a site mainly about raw feeding? Because feeding commercial foods is the mainstream way to feed pets, and most people come to raw feeding because they realize there’s a problem with commercial foods, not because of the inherent good of a natural diet. The other reason is because every time someone botches a job of discrediting or exposing commercial pet food producers it reflects back ten-fold on every person who has chosen to take back the duty and responsibility for their pets’ nutrition, whether they are vocal about it or not. In an effort to both educate and do my part for the credibility of raw feeders, home cookers, and people who follow a more natural pet care path, I offer the following thoughts.


After my initial run-through of the information presented I was pretty pissed off. Why would I be pissed off about a publication that supports something I know to be true and would like to hear shouted from the mountain tops? It was the way it was handled — the analysis and presentation of the data. Natural pet care and raw feeding are becoming more popular by the day, but credibility and acceptance still have a long way to go. One of the reasons for this is the insufficient response to requests by skeptics for “scientific” examination and analysis of materials and methods chosen in lieu of feeding commercially prepared foods. Part of this really can’t (and arguably doesn’t really need to be) addressed. The fact of the matter is that whether you’re talking about pet food or pharmaceuticals or cell phones, “studies” are funded by the entities that make money off the product or service. There simply isn’t likely to be anyone willing to fund a really truly in-depth study of, say, a raw DIY-style pet food diet, because there’s not really any significant profit to be seen from it. The few tests, studies, and analyses that do get done offer a great service to people looking to the data, if they’re done correctly. When done  incorrectly they cast practitioners of home prepared pet diets in a light of ignorance, and the all-condemning label of “pseudo-science” can get slapped on. It’s kind of humiliating in one way and just plain aggravating in another. The AFTIPF paper is more an example of the latter, in my opinion.


Most of my issues with the AFTIPF report boil down to the fact that they’re not really playing fair, and they’ve made things really confusing on top of it. Whether intentional or not, they’re relying on people extrapolating from what’s presented to fill in the numerous holes that plague this report like a cow brain with a prion disease. If it’s not indeed malicious — or even intentional – there’s still no excuse when you are a high-profile source of info (the TAPF Facebook page boasts just short of 50,000 “likers” as of today). They are encouraging people to go to legislators and authorities with their information as evidence of a problem that needs attention based upon an inadequate report.

To be fair to AFTIPF, they do establish that this is not really a “study” or a “test”, but an “examination” or “snapshot in time” 1 of selected pet foods. I have to question the motivation behind something that looks and sounds like a document representing the scientific method 2 but in its words and tables is anything but. I can’t help but thinking that due to the weak adherence to scientific method this “snapshot” is just overwhelming sensationalism. This insults the intelligence of anyone asked to take the exercise seriously, which includes not only the “advocates” and members of AFTIPF and followers of TAPF, but the legislators they encourage people write to.

“Secrecy was the problem; transparency the obvious cure….”2

In my first drafts of this piece, I used the word “disclosure” for expressing what I view as a problem with the report. I have since realized “transparency” is more accurate. I performed quite a bit of internet searching after viewing the report, and have details that aren’t presented in the final “report”, nor are they actually collected in one document. I will work them in as relevant, but it will remain a point of contention that I had to spend literally hours looking for this information, which wasn’t exactly hidden, but sure not convenient. I doubt senator Whatshisbutt or member of congress Whosherface will make the same effort, and nearest I can tell the whole point of this is to encourage change in legislation. It’s absolutely true that the very same big corporations (and smaller ones, too) who do pet food studies of their own are not transparent in the slightest when it comes to the funding and motivations behind the studies they sponsor, but one of the primary goals of the ATAPF is to mandate transparency by manufacturers and marketing agencies, and leading by example would be a good place to start.

The copyright on the report is attributed to one Association For Truth In Pet Food. They have a webpage 3 that explains their goals 4 and other aspects of the association. The only thing that is explained about the method in the actual report is that some entity called “INTI Services” (which I’m going to have to guess was this entity:, since no actual information was provided in the report) was involved in choosing labs and sending samples. Aside from the vague “consumer funded” mention and repeated referrals to budgetary limitations 5, there is no information about the funding procedure or allocation of funds in the actual report. On the AFTIPF site, however, the following was stated in a blog post update that preceded the actual report 6:

We raised a total of $15,920.00 – through the online Indiegogo campaign and through personal donations sent directly to Association for Truth in Pet Food. Less the fees charged by Indiegogo website ($628.20), our testing budget was $15,291.80 prior to any expense.

Products purchases totaled [sic] $319.40. Our net testing budget – $14,972.40. The full net testing budget has been spent.


The second failing of this “report” is the small sample size and the lack of adhesion to the scientific method. Only 12 foods total were used in the TAPF test. These 12 brands span cat and dog foods, a variety of retailers, and several of the main players in commercial pet food for a total 5 parent companies of subsidiary pet food brands, and two independent pet food companies. The report does include complete information about each sample including lot numbers, expiry dates, and point of purchase, among other things. Here’s a condensed version of the information about the food used in the “snapshot”*:

Cat Food (Canned)

  • Royal Canin Veterinary Diet (Mars)
  • Fancy Feast (Nestlé Purina)
  • Science Diet (Hill’s – a Colgate-Palmolive subsidiary)

Cat Food (Kibble)

  • Meow Mix (Big Heart, formerly DelMonte)
  • Friskies (Nestlé Purina)
  • Wellness (WellPet, a subsidiary of Berwind)

Dog Food (Canned)

  • Hill’s Prescription Diet (Hill’s – a Colgate-Palmolive subsidiary)
  • Vital – a “sausage” of soft food, not actually canned (FreshPet)
  • Cesar (Mars)

Dog Food (Kibble)

  • Blue Freedom Grain Free (Blue Buffalo)
  • Beneful Original (Nestlé Purina)
  • Ol’ Roy – semi-moist (Walmart, manufacturer is actually Mars 7)

* additional company info not present in original publication added

There is no explanation as to what criteria were used in choosing the sample foods. Funding limitations are mentioned throughout the report, presumably to explain or defend the small sample size and decision to only perform the test for mycological contamination on three-quarters of the total samples chosen. I don’t mean to belittle an honest effort, but for a project that apparently merited 52 pages of analysis and is supposed to be the foundation of a demand to legislators to change pet food regulation I’d expect a little bit more. Suffice it to say, the bigger the picture you want to paint the more paint you’re going to need, and if you’re painting a scene and want it to be true to life you’re also going to need a lot of colors. For an explanation of the significance of sample size in scientific method these websites are both good: and for a more in-depth one,


You’ll see throughout the report that there are claims made without references, and quotes that are lacking citation. This is a big no-no in analytical writing regardless of intent or subject. In this case it detracts from the effectiveness of the report, too. (Just because I can’t let it go: It would also help to choose sources to quote that weren’t so atrociously written as the FDA’s Bad Bug Book based on the quote that starts off page 2 of the report. It’s a grammatical doozy!)8 Then there is the case of just plain head-scratcher writing. I am left unsure of whether the report writer is trying to manipulate the readership, or whether it’s just poor skills and big mistakes. Take for example Section 2 of the report that starts on page 7 of the PDF file: Mycotoxin Analysis Report. The following paragraphs introduce the section and all punctuation and spelling is accurate to the document:

Mycotoxins are a toxic substance produced by a fungus and especially a mold – grains are prone to mycotoxin mold growth. High levels of mycotoxin can cause pet death. Existing studies of mycotoxin contamination in pet food have shown that day to day consumption of small amounts of mycotoxin can result in “chronic diseases such as liver and kidney fibrosis, infections resulting from immonosuppression and cancer.” Experts suggest chronic diseases are “often overlooked” as caused from long term consumption of lesser amounts of mycotoxin. Mycotoxin levels of pet foods and/or pet food ingredients are regulated by the FDA. Our budget allowed for eight of the 12 pet foods to be tested for mycotoxin contamination; we tested for 37 different mycotoxin in each of the eight pet foods. Each result is issued a ‘Risk Equivalent Quality’. Developed by an industry mycotoxin analytical laboratory (Alltech), the Risk Equivalent Quantity is representative of the overall risk to a species when considering all mycotoxin present in a food/feed sample. Each result also provides comment to the risk of mycotoxin found for the animal, provided by the INTI Scientists that oversaw The Pet Food Test.

On my first read thru, I clicked on the phrase “existing studies”, which is hyperlinked to this URL in the original: I noticed that it took me to a blog post written by Susan Thixton herself (the progenitor of the various “Truth In Pet Food” efforts), posted on the Truth About Pet Food site. It is simply a list of quotations from a single source, which, from what I can gather, is not so much a “study” as a “risk assessment” published in the International Journal of Food Microbiology in 2007. I kept reading past the uncited quotation (which includes a spelling error — one can’t be sure if it’s from the original source or a mistake in the copy), and went on to the third paragraph where they mention that they only had enough in the budget to test a portion of the sample.

That first time around I totally missed the weird wording regarding the lab and analysis portion, and read that Alltech did the testing and analysis using their “Risk Equivalent Quantity” rating system. On a subsequent read-through I realized that’s not actually what the words say! Not even close. For one, you’ll notice that the first reference says, “Risk Equivalent QUALITY”, whereas the second uses the correct “Risk Equivalent QUANTITY”, [emphases mine] at least as far as the Alltech-developed term. Looking past what I assumed was simply an error, the context implies that Alltech had something to do with this “snapshot” and the testing, but does not explicitly state that. A bit more internet searching reveals that Alltech probably was involved with the testing, as the excerpt above mentions “37 different mycotoxin [sic] in each of the 8 pet foods”, which would lead me to believe that they probably made use of Alltech’s trademarked 37+ system for detecting mycotoxin contamination. Then it gets really ridiculous: Each of the 8 tested foods is assigned a “Mycotoxin Risk Equivalent QUALITY” number [emphasis mine]. As of this writing, I have spent multiple hours trying to make heads or tails of AFTIPF’s intentions and the results, and I keep coming up with more questions than answers, like, “Did this INTC Services make up a ‘Risk Equivalent Quality’ scale that’s different than Alltech’s ‘Risk Equivalent Quantity’ scale? What is it based on? Who could overlook such a huge mistake?” This report was either poorly put together and/or is manipulating language. At best this report was carelessly formulated and not proofed before publication. At worst AFTIPF is guilty of the exact same things they’re accusing the pet food manufacturers of.


I would be remiss not to call attention to another aspect of this report that really gets my goat, and that is in the “Guaranteed Analysis” section of the report. The main part of the AFTIPF’s statement of goals is “truthful and accurate labeling”.9 In fact, there is no mention of improving pet food standards at all. The standard that every pet food company is bound to is put forth by the AAFCO (Association of American Feed Control Officials). It’s not adequate and it’s not even enforced 10, but those are other issues. A set of guidelines for feeding dogs and cats created by the NRC (National Research Council) is also available. This particular set of guidelines generally holds foods to a higher standard, but also acknowledges different nutrient requirements than the AAFCO. In short, the various associations and councils can’t even agree on what a dog or cat needs in the first place. Talk about confusing.

That’s not really the point here, though, at least not yet. The point is, that in the tables of data analysis put forth by the AFTIPF, there are columns for the agreed upon AAFCO one 11 but there is also an expectation that foods meet the NRC guidelines, lest be stamped with a red indicator. This simply isn’t good form. If the AFTIPF is demanding transparency and honesty in labeling, the objective would be to make sure foods are in compliance with the current terms, not meeting a standard they don’t claim to. One thing at a time. I don’t think demanding that pet food companies hold themselves and their products to higher standards is unreasonable in the slightest, however when making outright demands and using as elaborate a system of illumination the most efficient would be to follow in line with the original request.


Sensationalism Killed The Cat (image: origin unknown, public domain)

So the report wasn’t handled very well. It wasn’t a total waste of time, energy, and money, though. There are some really valid things we can learn from this “snapshot”, even through the flaws. Many years ago I concluded that I do not want to rely on the industry to feed my animals at all. This decision was based on exactly the things this report helps show: The nutritive values are questionable and the quality is also questionable.


The first thing this “snapshot” shows very clearly is that the guaranteed minimum/maximums are exactly that. They are absolutely no more (or less) by definition. The ‘guaranteed analysis’ is not numbers with a margin of error, it’s clear lines drawn with values guaranteed to fall on a particular side of a specific amount. When it comes to a pet food company’s guarantee to the consumer versus the testing performed by AFTIPF, only one food (Ol’ Roy/Walmart/Mars) was actually outside of the guarantee on a value for the minimums of protein and fat, and maximum of fiber.12 The ranges that were within the guarantees still displayed huge discrepancies, though.

Pet food companies meeting their own guarantees is only part of the issue, of course. When it comes to business ethics there’s little more — if any — but when it comes to the health of your pet one can’t be feeding sub-par food just because someone says it’s OK. This is where the NRC comparisons in the AFTIPF “snapshot” can be helpful. Getting values (e.g., percentages, parts-per-million, dry-matter, as-fed) to align for accurate comparisons is difficult (see the appendix at the bottom of the page for a related aside). The AFTIPF does not buck the trend of confusing and possibly inaccurate methods when it comes to this either, but the NRC guideline figures showed in the report do illustrate that the commercial foods were not only pretty wildly variant when it comes to the AAFCO guidelines, but when measured against a more comprehensive scale the foods were revealed in many cases to contain higher amounts of minerals than the NRC considers healthy. (Especially in the case of minerals, more does not mean better.)


Despite the preceding criticisms of the analyzing and reporting on mycotoxic activity, the fact that eight foods were tested for mycotoxins and every single one showed the presence of them is not insignificant. What was a bit of a surprise to me was the fact that the grain-free kibble showed a mycotoxin content — ergot and fusonisins specifically, which are mycotoxins pretty specific to grains. The content was quite low, but one has to wonder whether even that level came from being the first bag of food off the same equipment as grain-inclusive food, or if something is not on the up-and-up. Of course this was only one sample among likely thousands produced in a short period of time. Wherever the various mycotoxic content came from in the tested foods, unlike, say, some bacteria, there is no ‘acceptable’ mycotoxin level in food. There might be “expected”, but not acceptable. This factor is easier to control the closer you get to the source of your food and its preparation.


What has to be one of the biggest myths about commercially prepared pet food is that it’s free of bacteria and other microorganisms. It does make a bit of sense that would be the case, considering it’s highly processed and sealed up tight – even canned! Raw food and other homemade diets come under a lot of criticism for the natural load of microorganisms they carry. The truth is, though —  as supported by this “snapshot” — is that commercial foods are in no way even close to sterile, either. Bacteria is part of life. It is all around us, on us, and in us all the time. Some are good, some are bad. When the ‘good guys’ and ‘bad guys’ are kept in check and in balance, and there are no extenuating circumstances (i.e., disease causing abnormally high risk to health given normal exposure), bacteria that one finds associated with the average non-commercial diet pose no health threat. It’s not that bacteria is absent, it’s that it’s normal. Another lesson we can take away from the AFTIPF report is that not only will you probably find bacteria in commercially processed food, period, you very well could find potentially dangerous bacteria not necessarily natural to biologically appropriate foods.

On the flip-side of the bacteria coin, there was a surprising outlier in among the 12 samples – the FreshPet soft food packaged in a plastic “sausage”. According to this study NO bacteria were found at all! One might wonder at the fact that there seemed to be no bacterial load at all — even the good kinds. Presumably this food is processed at such a high temperature, or utilizes processes that are so effective, not a single bacterium could survive. Surely there’s also no active enzymatic activity or other microbiological “vitality”. With processes capable of killing every microorganism, one has to wonder about the denaturing of proteins and alterations of nutrients in general.


I believe firmly that making verbal demands only goes so far. The real “speaker” is money. If you want a product, a company, or an entire industry to change its policies and practices, nothing speaks so well as where your dollar is spent. When it comes to the actual health of your animals, a person also has to do what is right, not necessarily what appeals to them. If you know commercial foods aren’t adequate or even dangerous, you need to come up with an alternative while you work on a solution. It doesn’t help your pet to condemn pet food companies, all the while supporting them with your money and your actions because you like feeding food you pour out of a bag or gloop out of a can. Given the nature of Pack Lunch, of course my solution — and one I think is appropriate for others — is a homemade raw diet. Supporting independent local pet food stores is also very important for your various pet needs, especially if you do choose to feed commercially prepared foods and treats. Smaller companies where owners and managers actually interact with their customers are in a position to be acutely aware of food/treat/supply quality issues, and are a link between consumer and producer. Companies who actually listen to these observations and enact changes do exist, and hopefully will become the rule instead of the exception going into the future.


(1) Thixton, Sue. The Consumer Funded Pet Food Test. PDF file, page 1. The Association For Truth In Pet Food, 2015. Accessed January 5th, 2015,




(5) Thixton, Sue. The Consumer Funded Pet Food Test. PDF file. The Association For Truth In Pet Food, 2015. Accessed January 5th, 2015,



(8) Thixton, Sue. The Consumer Funded Pet Food Test. PDF file, page 40. The Association For Truth In Pet Food, 2015. Accessed January 5th, 2015,


(10) From the AAFCO website page

AAFCO has no statutory authority to regulate pet products.

Rather, enforcement of violations is the purview of the state feed control officials, so companies must comply with each state’s requirements. While most states follow AAFCO model regulations, exact language and interpretation may differ between states. While these documents offer guidance that are helpful in the vast majority of states, it is the responsibility of the manufacturer to ensure compliance with individual state requirements.

Did you know?

AAFCO does not regulate, test, approve or certify pet foods in any way.

AAFCO establishes the nutritional standards for complete and balanced pet foods, and it is the pet food company’s responsibility to formulate their products according to the appropriate AAFCO standard.

It is the state feed control official’s responsibility in regulating pet food to ensure that the laws and rules established for the protection of companion animals and their custodians are complied with so that only unadulterated, correctly and uniformly labeled pet food products are distributed in the marketplace and a structure for orderly commerce.


(12) According to the table on page 33 of the report, the value for the guaranteed minimum was “7” and the actual content of the food was “4.97”, with “5” being the minimum for compliance with AAFCO recommendations.




ATIPF web pages that cover the The Consumer Funded Pet Food Test in order of date published:

Sites relevant to food testing:

NRC guidelines info:



The following is a lightly edited transcript of a conversation a friend, devoted raw feeder, and devout follower of the scientific method and I had when we were both examining the ATIPF report. It includes quotes of relevant source material related to amounts and limits of minerals recommended for dogs by the NRC.

MS: So, I checked my text from the NRC for the Nutrient Requirements of Dogs and Cats. They do not provide values for the safe upper limit for calcium for adult dogs. It states that the research has shown that excess calcium can be detrimental in growing puppies and large breed dogs such as Great Danes where excess calcium can cause skeletal lesions and malformations. Their recommendation is to only be worried about the SUL of calcium for small breed puppies and very large breed dogs. I don’t have access to the source they refer to, but some of the other information about that source states that, although excess calcium (above 2% RA) can have adverse affects, moderate to high calcium levels may be protective against calcium oxalate precipitates. Calcium in meals may bind with oxalates in the gut decreasing the risk.

The bigger worry in the ca:ph balance is having too much phosphorus.

AE: Regarding the Ca : Ph thing (actually, no in their ‘snapshot’ I don’t think they make a connection to ratio, it’s just about amounts), this is part of what makes me actually angry instead of totally indifferent about this. The way the whole thing reads to me is that TAPF implies that the foods and the marketing make claims that they use the NRC guidelines, which they most certainly DO NOT. They comply with the AAFCO ‘standards’ (*giggle-snort*), and unless I missed something (possible), every food they tested was within range of minimums and maximums they state. Some were way more off than others, but any conscientious pet food consumer should know that mins and maxes are just that. They do not give a +/- range, it’s MIN and MAX. If they give a minimum of 23% protein as a max, 30% is totally acceptable. Good? Maybe not. That info doesn’t really have any place in a “snapshot” that is giving the illusion of non-bias and method standards, though. This information could actually be SO COOL if it was approached with a more casual attitude — one that fits what they actually did. There are lessons to be taken away from the sampling, just not the ones they’re presenting. Makes me feel like defending the pet food companies. Sheesh!

MS: Yeah, I was thinking the same thing. Also, at least with the NRC, they state the min/recommended/Safe upper limit values in terms of weight per dry matter, not percentages. For example. The minimum amount of calcium would be 2.0g per kg DM and the recommended allowance would be 4.0g per kg DM. That is a 200% difference between the minimum amount needed to stay alive and the recommended allowance to maintain health (no SUL was defined). I am not sure what they mean when they say that min. is .6% and max is 2.5% based on DM, unless they are looking at the entire nutritional content of a serving of food (i.e., all nutrients combined to equal 100%). It seems they are basing the percentages off of this other document, “Mineral Tolerances of Animals” which I guess I am going to see if I can track down a copy in the [university] library just to satisfy my curiosity.

MS: ok., I found the publication mineral tolerances of animals that is cited in their report. It automatically references the source, but regarding the percentages issue, it states, “Mineral exposure is commonly reported in several different ways. Expressing exposure as an amount per day (e.g., mg mineral consumed/day or mg/kg BW/day) is very precise and especially useful when intake is variable, such as the case when the mineral is delivered in water or in a freechoice supplement. Expressing exposure as a proportion of the feed or water (e.g., percent or mg/kg of feed) has many obvious practical advantages in feed formulation and government regulation. These two methods of expression can be interconverted when the rate of consumption is known. To the extent possible, tables in this report express exposure as the concentration in feed or water.”

So, it appears that is where the percentages are coming from. Let me read more and see what else I come up with.

Mineral Tolerance of Animals (2nd Revised Edition). Washington, DC, USA: National Academies Press, 2005. ProQuest ebrary. Web. 7 January 2015.

Copyright © 2005. National Academies Press. All rights reserved.

MS: Not sure I buy into the idea that levels can be safe for animals, but not humans. Another good reason to source your meat and ask the right questions. If the food is made for dogs (e.g., premade raw), these levels may exceed recommended limits of those provided for humans.

“Even at dietary levels that are apparently safe for animals, some minerals accumulate in their tissues to concentrations that are unsafe for human consumption. Liver, kidney, and spleen are the tissues of maximal accumulation of cadmium, lead, and mercury and limit the dietary concentrations that can be safely fed to animals destined for human consumption. Organic forms of selenium and mercury accumulate in all tissues, including muscle. Health issues related to high levels of these minerals in human foods have been considered in detail by many national and international committees, and their recommendations are referenced in this report. Levels of cadmium, lead, and mercury in the feeds consumed by animals are normally regulated based on concerns related to human health. The recommendations for maximum tolerable levels of these minerals in this report are based solely on indexes of animal health and productivity and would likely result in food products that exceed recommendations for humans.”

Mineral Tolerance of Animals (2nd Revised Edition). Washington, DC, USA: National Academies Press, 2005. ProQuest ebrary. Web. 7 January 2015.

Copyright © 2005. National Academies Press. All rights reserved.

MS: here is the criteria for the ranges. The report cites the min/max tolerable levels.

“The “maximum tolerable level” (MTL) of a mineral is defined as the dietary level that, when fed for a defined period of time, will not impair animal health and performance. Tolerable mineral levels are typically distinguished from toxic levels by experiments that add incremental amounts of a mineral to the diet or the water and measure the impact on performance and pathological signs of toxicosis. The duration of exposure to the test mineral markedly influences the level that causes toxicosis. Long-term and multigenerational studies are usually most informative, but, in practice, short-term studies are most commonly conducted. The committee considered three exposure durations: a single dose, acute exposure, and chronic exposure. A single dose is defined as exposure due to the consumption of a single meal or by a single gauge of the mineral. Acute exposure is defined as an intake of 10 days or less. Chronic exposure is set as an exposure of 10 days or more. However, in making recommendations, emphasis was given to the studies that had the longest durations of exposure. A “toxic level” is defined as the minimal level that, when fed for a defined period, impairs animal health or performance (rate of production of milk, meat, or eggs; growth rate; reproductive capacity; disease resistance).”

Mineral Tolerance of Animals (2nd Revised Edition). Washington, DC, USA: National Academies Press, 2005. ProQuest ebrary. Web. 7 January 2015.

Copyright © 2005. National Academies Press. All rights reserved.




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AVMA Policy on Raw Feeding

Note: After the passing of the proposed resolution in August 2012 this article was expanded and updated and replaces “Proposed AVMA Resolution Regarding Raw Feeding”

In August of 2012 the American Veterinary Medical Association (AVMA) voted in a policy which creates an official stance on raw feeding: They’re against it. The AVMA, whose membership exceeds 81,000 North American veterinarians (likely including yours), have not had a policy outlining how association members are to approach the subject of raw feeding….. until now.

The AVMA Policy On Raw Feeding (image: Natty eats chicken)

Read the policy here:

The news of this new policy is being met with mixed reactions from the raw feeding community, and it seems divided between two main camps: People who don’t think this will have any meaningful impact, and those who see this as having the potential to affect personal liberties and compromise the quality of vet care available to raw feeders.

The AVMA is a professional association with a long history, solid reputation, and a big voice in matters of North American veterinary issues. While they do not have any direct control over legislation regarding pet care, their influence is significant and widespread. Quoted directly from their website: Hundreds of veterinarian members participate in the development of scientifically sound policies that guide decisions from local municipalities all the way up to the federal government. The AVMA provides guidelines for the practice of veterinary medicine in the United States. (

It will remain to be seen exactly how veterinarians who are part of the AVMA choose to embody the policy in their everyday practices, or to what extent the AVMA will expect compliance by it’s members. The policy clearly states that vets are to discourage raw feeding, but I’m sure not every AVMA vet who up until August supported and encouraged raw feeding will abandon their belief in the diet choice now. More likely is even fewer vets discussing feeding and nutrition with clients at all. Nutrition is the cornerstone of health, and to ignore the subject in routine vet care is a very scary notion.

The impact this could have on vets who have been “on the fence” about raw feeding but willing to learn from clients will likely be compromised. Availability of raw pet food in the offices of AVMA vets could become scarce or non-existent. While raw feeding has been a touchy subject within veterinary professional associations for years, without an official stance individual practices have not had to fear expulsion from an association that could very well mean losing their practice. I know personally of vets who have been afraid to have their practices associated with lists of “raw friendly” vets for fear of backlash from these professional associations. This policy will cement those fears.

The AVMA is the accrediting body for all North American vet schools. As it stands now nutrition is a very minimal part of vet school curriculum. While on one hand raw feeding can’t take any more of a hit, I think this policy will ensure that no progress is made in this area. Commercial processed food companies are major financial backers of veterinary education. This combined with the short-but-sweet policy pronouncing raw food “officially” unsafe makes for a continued climate in vet school lecture halls and clinics where the subject of species appropriate feeding will remain suppressed.

AVMA Policy on Raw (image: pet food store)

While the AVMA has no direct power to pass laws, the impact of this policy could indeed help to inform legislation and will spread the gross misconception that raw feeding is a public health threat. Referencing this policy from the biggest and most respected association of veterinarians, I think it could become easier to pass laws regarding park access, day-care facilities, kennels, pet food manufacture and sales, and pet licensing in the name of “public health”, and at the expense of our pets’ health and our freedoms.

In a time when recalls of kibbled and canned pet foods happen regularly due to elevated levels of salmonella bacteria, mycotoxins, and other contaminates, one has to wonder why the AVMA has chosen this topic to act on at this time, especially given that they have had no opinion on the various recalls and the companies involved. The claim within the proposed resolution is that it was spurred by the Delta Society (a branch of the Council on Public Health and Regulatory Veterinary Medicine which governs service and therapy animals and other volunteers) resolution last year. The critically thinking pet owner knows that “following the money” usually reveals the issue at heart, and I, for one of many, have to wonder about the pressures of pet food manufacturers for these professional associations and councils to establish policies that will help ensure their bottom line at the expense of animal health.


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Anti-Raw Publicity and Research: Rebuttals

The practice of feeding a raw food diet is gaining exposure every day and an increasing number of pet owners are choosing to feed a diet of raw meats, bones, and organs over processed commercially prepared diets. Those of us who have been feeding raw for a time now know the diet to be healthy, relatively easy to formulate, convenient to feed, as well as better for our environment. We are comfortable with the science behind how carnivores handle the natural bacterial loads on the foods that they eat, and have learned through research and personal experience that if we as humans practice proper handling practices and let common sense prevail that a raw fed dog does not pose a health threat to our families nor the public.

The post-humorous notes of the Pickwickian Club.

OK, maybe it’s not that bad, but it feels like it sometimes!

Not everyone shares these opinions and experiences, including many in the veterinary and commercial pet food communities. When these people express their reservations and cautions about the perceived dangers of a raw food diet one prevailing commonality is that the authors often do not appear to understand how a proper raw diet is formulated and fed. Other misconceptions and misinformation are often the basis for arguments against feeding raw in these articles and studies.

When such articles come to the attention of myself and other raw feeders who have taken an interest in educating the public about the overwhelmingly positive side of raw feeding we are usually moved to write a rebuttal to the original work to serve as a learning tool.

I thought it would be nice to have a compendium of these rebuttals for easy reference. Following are links to rebuttals. Content is property of the author. In most (if not all) cases the rebuttals are set up in a format where a section of original text is quoted, then the new material presented. The original text is usually in bold face or italics, responses in normal type. Links to the original text are provided where possible.

This is an ongoing project. If you have written a rebuttal of this nature and would like to see it linked here, or know of publicity or a study that you’d like to see challenged please contact me!


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Anti-Raw Rebuttal: Watts, 2008

An article written by Dr. Michael Watts DVM appeared in both the Culpeper News and the Culpeper Star-Exponent on May 18th, 2008. Dr. Watts’ original text appears in bold text, my rebuttal is in regular text.

An online version of the original article from the Star-Exponent webpage can be found at:

Anika Evans, 2008


Dr. Watts Published: May 18, 2008

Q: I am considering feeding my dogs a raw diet. What are your thoughts?

A: The popularity of Internet chat rooms, blogs, and personal web pages has brought increased interest in raw pet foods.

The internet definitely has helped spread awareness about raw food diets, as it does about many, many other issues both veterinary in nature and otherwise.

There are several types of raw diets, all made using uncooked meat, bones, and other ingredients. The diets began as homemade recipes, but their popularity has lead to the availability of commercial raw diets.

Raw diets were not “born” of homecooked diets, though the connection between dog owners who started out preparing home cooked meals and now feed raw cannot be denied. It is very important to note that a proper raw diet is NOT just an uncooked home-prepared meal and vice-versa. The increase of people who recognize the benefits of raw feeding has indeed given rise to a number of commercially prepared raw foods. It should be noted that these premade raw foods range in quality and formulation from very poor to very reasonable.

Proponents of raw pet food focus on the high quality, fresh ingredients used in the food.

Yup, one of the benefits of feeding a non-commercial product is control over quality. The global nature of food production is spreading wider every day, and the nature of commercially prepared processed foods mean that the consumer has no real way of knowing what the sources of the dozens of ingredients are, nor the way in which they were handled. Many dog owners come to raw feeding as a solution to what they see is the problem of lack of legislation, regulation, and enforcement in the commercial pet food industry.

They also generally reflect on the “natural” diet of wolves and other wild animals which do not cook their meals.

Indeed. This is a cornerstone of one approach to formulating a raw diet. Most if not all domestic dogs are descendants of the gray wolf. Modern day wild gray wolves are our dog’s “living ancestors” and given the lack of physiological (not morphological) evolution in the last 15,000 or so that dogs have been dogs it is a great tool to be able use.

Sometimes mention is made of enzymes in raw food that are lost through the cooking process. There is little doubt that most of these diets are nutritionally sound. However, there is considerable doubt about whether these diets represent optimum nutrition.

In order to discuss “optimum nutrition”, a definition of “optimum nutrition” is needed. There have been minimum and maximum nutrient intakes identified by entities like the NRC and AAFCO, but these are not “optimum” amounts. Also required are diets to compare. Dr. Watts is clearly making a differentiation between “nutritionally sound” and “optimum nutrition”, but he is making blanket statements about raw food that doesn’t appear to be based on any actual knowledge of a properly prepared raw diet.

In addition, there is serious concern about the safety of these diets.

Most safety concerns are not based on realistic assessments of risk. They can be easily put at ease with a presentation of scientific facts along with diligence in following proper methods for preparing raw diets and handling raw foods.

Veterinary nutritionists have published libraries of research on the digestive system of dogs and the way they utilize specific nutrients. The profession has also determined optimum requirements for many nutrients in specific breeds, sizes, life stages, and performance levels. For instance, we know precisely the optimum ratio of calcium to phosphorous for joint health in growing large breed dogs. We also know some sources of calcium can be efficiently absorbed by dogs and others cannot.

Which is why many raw feeders use this research to help them formulate their dog’s raw diet and look after their health!

When you feed your dog a reputable premium food labeled for giant breed growth, your pet will benefit from a century of nutritional advances.

There has been no “nutritional advance” in the last century. Nutrition has always been the same, either we understand how to provide it or we don’t. Yes, there have been advances in the  understanding of biology and physiology. Technological advances cannot be denied. However, what has been accomplished in the last century when it comes to feeding dogs is having figured out the minimum requirements for maintaining the lives of companion animals using substandard and unnatural ingredients. This is hardly about “optimum nutrition”. Advances in processing and packaging techniques have meant that we can get away with feeding prepared foods that can be made on a larger and cheaper scale now than ever before.

If you grind beef bones and mix into a recipe from the Internet, you may not be providing optimal nutrition.

Maybe you are, maybe you’re not! It depends on this “recipe” and what makes up the balance of the diet. This example is quite obviously one that Dr. Watts made up off the top of his head which is not rooted in knowledge of practicality nor common practice by raw feeders. Any raw feeder who grinds the food they feed will tell you that you can’t grind beef bone with any standard household grinder. Grinders with the capability of grinding up bone from larger animals like cows, bison, pigs, or even lambs require heavy duty industrial strength grinders that cost thousands of dollars.

Dogs fed raw diet frequently have small pieces of bone visible in their stool. How much calcium was absorbed? How much phosphorous? Will this batch be the same as the last?

Yes, some dogs will pass small pieces of bone in their stool, especially when they first start eating a whole foods diet. I don’t really see the relevancy of this observation. Anyone will tell you that food can be poorly absorbed even as part of a finely ground homogeneous sludge, as processed foods are. The question about “batches” again reveals that Dr. Watts doesn’t really understand raw feeding. While some raw feeders do make up ground mixes, many don’t at all, and most realize the necessity of feeding a diet which does NOT consist of the same meal day after day to avoid the very problem of deficiencies and excesses that they would be risking with a diet of the same “recipe” over a long period of time.

The life expectancy of dogs has doubled in the past 50 years in large part due to improved nutrition.

I’d really like to see supporting documents which back up this statement. I don’t debate that the life expectancy of dogs has increased as well as the quality of life for many, but this is more likely due to their status as companion animals and their roles in our households than the shift to processed foods as Dr. Watts implies. Many advocates for raw food diets discuss this issue in various texts including Dr. Tom Lonsdale DVM, Dr. Ian Billinghurst DVM, and Carissa Keuhn on her well known website The Many Myths of Rawfeeding.

Being fed like a wolf may not be an optimal way to eat.

Granted, it may not, but it very well may be. This is a pretty non-committal statement!

Wolves live very different lives and generally die considerably earlier than our pets.

They are wild animals subject to any manner of threats in the wild that our dogs are not, nevermind the fact that dogs receive regular veterinary care.

The enzymes required for digestion are all produced by the body and do not need to be provided in a raw source.

This can be argued. Dr. Martin Goldstein, DVM discusses this in his book, “The Nature Of Animal Healing”. Yes, the body does manufacture digestive enzymes, but there is evidence that eating processed foods where the natural enzymatic content has been denatured by heat puts an unnatural strain on the body and the organs that produce digestive enzymes.

In fact, since enzymes are proteins, most will be simply broken down by the saliva, stomach acid, and other secretions of the digestive tract.

This statement WAY oversimplifies the issue.

There is also considerable concern for the safety of raw diets.

As has been mentioned…

Several recent studies from different sources have cultured potentially pathologic bacteria from 30 to 90 percent of raw dog foods.

I believe the word Dr. Watts intended to use is pathogenic, not “pathologic”.

OF COURSE there’s been bacteria cultured from raw meat dog food. IT’S RAW MEAT!!! There isn’t a single educated raw feeder out there who will deny the potential for the existence of pathogenic bacteria on the foods they feed.

Citing these sources at the end of the article would have been helpful. Given that I don’t have sources I’m going to venture a guess that one of these “many” sources is a study done by Rita Finley et al. The CJVM has made the articles available online and I’ve had the opportunity to read thru that one. I find that study to be FULL of faults and no testament to support the argument that raw food is hazardous.

While most dogs do not get sick from these germs, some do. The bacteria are particularly dangerous for puppies, old dogs, sick pets, or those on certain medications.

Or in other words immunologically suppressed dogs. Adult dogs most susceptible to infection caused by normal loads of bacteria found in one’s environment (including on the food one eats) are chronically ill dogs. One way to avoid chronic illness and disease is to eat a healthy diet — a raw diet.

Another recent study found 30 percent of dogs fed raw diets have positive fecal cultures for these same dangerous organisms.

The implication here is that this is bad. The way a dog’s body safely deals with high bacterial loads entering it’s system is to quickly and efficiently send the bacteria through the system before it can take up residence and colonize. We have to remember that whether a dog is raw fed or not it’s going to encounter high bacterial loads doing what a dog does — sniffing it’s surroundings, checking out other dogs, grooming itself with it’s mouth. Any dog that has the opportunity to “ground score” edible items like decaying food or another animal’s feces is going to shed the bacteria these items carry in its own feces.

This study dispels the myth that a dog’s stomach acid kills all the bacteria in the food.

Good, because it’s just a myth!

It also raises concern for children, elderly people, or immune-compromised individuals who come into contact with dogs that shed these bacteria in their feces.

There’s an easy solution to this “problem” — it’s called common sense and reasonable hygiene. Wash your hands regularly. Don’t let your kids eat dog poop. Follow safe raw meat handling practices. Don’t let your dog eat raw meat on the living room couch….

At a recent conference I attended, a veterinarian from the University of Minnesota presented a sad case of a litter of puppies that died of bacterial meningitis. The bacteria cultured from their brain tissue matched the bacteria cultured from their mother’s raw diet. Although well-meaning, this pet owner’s choice of pet food directly led to the death of the puppies. This was certainly not an example of optimum nutrition.

This is indeed unfortunate, but hardly a reason to take into question the practice of raw feeding. How many non rawfed dams and pups suffer bacterial meningitis? Surely it’s not a malady confined to raw fed dogs! Though I’m not going to argue that this happened, again I think that the focus isn’t in the right place. One must consider why this happened to this particular mom and pups. Was it related to unsafe handling? Was this dog more severely compromised health wise than other dogs in her demographic? Maybe a better issue to raise is why the thousands and thousands of raw fed breeding dogs and their progeny don’t all die of bacterial meningitis?

However, it probably does accurately reflect what happens in wild wolves from time to time.

I doubt it, not on a significant scale anyway. “Mother Nature” or whatever you want to call it doesn’t allow for animals to be sickened by their natural diet.

Like most veterinarians, I never recommend raw pet food.

Like most veterinarians he appears to know very little about raw food, and if he’s like “most vets” he probably has very little training or experience in the field of nutrition. There are definitely vets out there who do recommend raw diets, and those who feel comfortable discussing them and recommending raw to their clients.

I advise my clients on ways to provide optimum nutrition.

“Optimum nutrition” as defined by who? Last time I checked there was hardly a consensus on what foods are capable of delivering “optimum nutrition”. It would be nice if there were — every dog owner in the world could just feed this one food and stop worrying about it!

For those who choose to disregard the advice of the overwhelming majority of veterinarians, the FDA has issued guidelines for feeding raw pet foods. The guidelines can be found at

Those guidelines in my personal opinion are pretty lax, even just plain misinformed. Then again it doesn’t take the FDA issuing a list of guidelines to tell me that my own prepared foods should be kept frozen in transport or that the companies who make prepared foods that I might buy should self-regulate their practices to avoid contamination. FYI, raw dog food should NEVER be thawed in the microwave as recommended by the FDA. I’ve seen the danger of this one first hand.

Dr. Watts is a companion animal general practitioner and owner of Clevengers Corner Veterinary Care. He can be reached through or by calling 428-1000.

Anika Evans does not hold a veterinary degree, but has owned between one and three dogs at a time over the last decade and spent much of the last three years intensively researching topics related to the world of veterinary care, nutrition, physiology, commercial pet food manufacturing, among other things. She has experience with natural food diets and non-pharmaceutical oriented health care for both humans and companion animals. She has been feeding her own dogs a completely raw diet with no reliance on commercially prepared foods for many years. She can be found participating in discussions about health, nutrition, and raw feeding on the forums. You can contact her through her website at

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