Carnivore Alert: You Are What They Eat

Consumer Reports
January, 2005

You Are What They Eat

Humans are at the top of the food chain. As a result, we're vulnerable
to pathogens, drugs, and contaminants consumed by the animals we eat.
And we eat a lot: an average of 137 pounds of beef, chicken, fish, and
shellfish per American in 2002, the latest year for which figures are

Food animals used to eat what grew naturally - grass and grain for cows
and chickens; small fish or other sea life for big fish. But life on today's
farm - often a 30,000-cow feedlot or a 60,000-chicken coop -
isn't so simple. The need of such facilities for huge quantities of
high-protein rations and the need for slaughterhouses to find a cheap,
safe way to dispose of waste gave rise to a marriage of convenience
between renderers and food producers, and to the inclusion of animal
by-products in animal feed.

The pairing was seen as a boon: Waste was recycled into needed protein
and other nutrients for animals. But the addition of rendering industry
to the animal-feed mix has meant more trouble controlling and monitoring
feed production, more vulnerability to problems, and another layer of

To assess the safety of the nation's animal feed and implications for
consumers, we interviewed feed-industry experts and critics; reviewed
recent research and spoke to scientists who conducted it; and tested
chicken for arsenic, an approved additive in an antiparasitic drug given
to many healthy birds to make them grow faster.

We asked feed-company executives to talk with us, but only
representatives of fish-feed makers and the heads of four feed trade
association were willing.

Our investigation raises concerns that the federal government isn't
doing enough to protect the feed supply and that as a result, the food
we eat may not be as safe as it could be: Regulatory loopholes could
allow mad cow infection, if present, to make its way into cattle feed;
drugs used in chickens could raise human exposure to arsenic or
antibiotic-resistant bacteria; farmed fish could harbor PCBs and


Cattle and chickens are still given plant-based feed: Corn (for carbs)
and soybean meal (for amino acids) make up 70 percent to 90 percent of
most commercial animal feed. But the remaining 10 percent to 30 percent
of feed can differ radically from what cows and poultry would eat in
their natural habitat.

Processed feathers are an acceptable source of protein in cattle feed,
according to the U.S. Food and Drug Administration as is poultry litter
- floor wastes from coops, including feces. Plastic pellets are
permitted as roughage. Chickens can be fed meat and bone meal. And in
addition to their main diet of fish meal and fish oil, farmed fish may
be given rendered meat bone, and feather meal. The goal: to fatten
animals as fast and as cheaply as possible.

Also included in feed: medications, given routinely even to healthy
cattle and chickens to boost growth and keep infections at bay. (It's
illegal for U.S. fish farmers to use drugs for those purposes.)

Whatever the animal, a range of feeds is available. In the U.S. alone,
14,000-plus companies sell as many as 200 basic feeds, plus custom-made
mixes. In all, the companies produce more than 308 billion pounds of
animal feed annually.

The relative percentage of feed ingredients varies with price and
availability. "Last April, soybeans cost twice as much as they did the
year before, and feed suppliers turned more aggressively to rendered
animal protein and by-products," says Chris Hurt, Ph.D., an agricultural
economist at Purdue University. "In October, soybean prices were back to
previous levels, which gives them less incentive to use meat and bone

When a feed producer proposes a new ingredient, it must petition the FDA
to approve it. The FDA gives a thumbs-up or thumbs-down or, in rare
cases, leaves the decision to the states. Once an ingredient is
approved, its name and description appear in an ingredient list
published by the Association of American Feed Control Officials. AAFCO
comprises FDA officials, state feed officials, and feed-industry
representatives (who can't vote on matters such as requiring product

The FDA can't blanket the country with inspectors, so it delegates much
enforcement responsibility to the states, which conduct 70 percent of
feed-company and renderer inspections.


Try to put aside any squeamishness when "waste" and "feed" are used in
the same sentence. The waste is processed until it bears no resemblance
to its former self. Thomas Cook, president of the National Renderers
Association, told us that after the rendering process thoroughly heats,
presses, and grinds animals tissue, it "looks like a pile of brown

The benefits. "Animal-protein products, meat and bone meal, and blood
meal are very nutritional feed ingredients," says David Fairfield,
director of feed services for the National Grain and Feed Association.
Philip Petry, president of AAFCO, speaks of the merits of chicken waste.
"There's a yuck factor because it doesn't sound at all appetizing," he
says, "but the nitrogen level in poultry litter is real high, so they
get a real good protein jump out of that."

Richard Sellers, vice president for feed control and nutrition at the
American Feed Industry Association (AFIA), points out that some of the
50 million tons of animal and plant by-products generated by the food
industry might have ended up in landfill. "We turn them into valuable
sources of protein to feed a hungry world," he adds.

The risks. What the feed officials say is true, but what consumers need
to know is whether those processed feed ingredients pose risks to them.

Industry officials cite the approval process. "All the feed ingredients
are approved by the government," says David Bossman, recent president
and chief executive of AFIA. "FDA is part of that process. It's the most
scientifically sound food-safety organization in the world."

Yet even Bossman acknowledges that accidents can happen: Feed can become
contaminated, for instance, simply by being stored in the wrong bin.
"People make honest mistakes," he says.

Indeed. According to a recent report from the federal Centers for
Disease Control and Prevention (CDC), "There is considerable potential
for contaminated animal feed or animal-feed ingredients to move between
and within countries. This could result in the widespread and rapid
dissemination of a pathogen to geographically dispersed animal herds -
and, in turn, to a range of human food products."

Jean Halloran, director of the Consumer Policy Institute of Consumers
Union (publisher of Consumer Reports), thinks the FDA's rules are not
stringent enough. "There needs to be rigorous analysis of the health
impact of what's fed to food animals," she says.

Other consumer advocates agree. Caroline Smith DeWaal, director of food
safety for the Center for Science in the Public Interest, notes "I think
the yuck factor is huge. But we have actual concerns when things like
clay are mixed in and other by-products that can increase the exposure
of humans who eat those animals to toxic chemicals." Clay can be
contaminated with dioxins; in fiscal year 2003, dioxin contamination led
the FDA to recall 479 feed products from 17 companies.

Robert Lawrence, M.D., chairman of a National Academy of Sciences
committee that recently examined dioxin exposure, says that dioxins and
PCBs, which accumulate in animal fat, are being recycled into the food
supply. "I was shocked to learn that every year in the U.S., 11 billion
pounds of animal fat is recycled into animal feed," he says.

Even if rendered material starts out clean, it can become contaminated
with bacteria. Whether that happens during processing, storage,
handling, or shipping isn't clear. But tests by the Animal Protein
Producers Industry, a nonprofit renderers group, found salmonella in
about one-fourth of rendered feedstuffs, on average, from 1996 through
2000. The good news: That's down from about half in 1990.

The FDA is aware of only a handful of incidents worldwide in which
salmonella infections in human were linked to animal feed. The most
recent was in the U.S. in 2003. But connecting human illness to
contaminated feed is difficult, says Fred Angulo, chief of the CDC's
foodborne and diarrheal diseases branch.

It would help to have a "farm to fork" surveillance system such as those
in Europe, he says, where contamination is looked for in feed, animals,
the marketplace, and humans. In the U.S., Angulo says, that might mean
requiring a Hazard Analysis and Critical Control Points (HACCP) system
for feed processing, like those already in place for animal processing.
It would make feed manufacturers spell out where contamination might
occur during processing, then build in procedures to prevent it.

Stephen Sundlof, Ph.D., director of the FDA's Center for Veterinary
Medicine, which regulates drugs, devices, and food additives for food
animals, says the agency is "engaged in discussions with the feed
industry" to put a HACCP-like system in place. An FDA spokeswoman called
the system a priority, but it may not be fully implemented until 2007.
AFIA has launched a voluntary system that incorporates HACCP-like

If all animals were raised organically - on feed lacking pesticides,
animal by-products, and antibiotics - would our food supply be safe?
Yes, in some ways. There would be less risk of mad cow disease, little
or no arsenic in chicken, and fewer bacteria able to resist antibiotics.
But there's no guarantee that organic feed is free of garden-variety
bacteria, including salmonella.

Richard Sellers of AFIA sees another roadblock, at least for now: "There
are not enough organic-grain suppliers to go all organic." Currently,
about a dozen brands each of organic chicken and beef are sold, and far
fewer organic fish (many are imports; USDA organic standards don't yet
apply to seafood).

On the other hand, price might not be a big barrier. If the organic-feed
industry grew, Chris Hurt, the Purdue economist, estimates that organic
beef or chicken might cost only 10 percent to 20 percent more per pound,
on average, than meat from conventionally raised animals.

American consumers are willing to pay more for greater safety
guarantees, according to a national online survey of 1,085 adults
conducted last January by Consumers Union. Of the 95 percent of
respondents who said they eat beef, 77 percent said they would pay more
at the supermarket for beef certified as free of mad cow disease.

Beef Delays in mad cow protection

In 1997, the U.S. Food and Drug Administration required that most
protein derived from ruminants (cud-chewing animals) be kept out of feed
given to other ruminants. The goal was to keep the feed supply free of
infectious prions, proteins thought to spread bovine spongiform
encephalopathy (BSE, or mad cow disease), which has been linked to a
fatal brain disease in humans. Although the rendering process can kill
viruses and bacteria, it doesn't eliminate all prions.

That feed ban was designed to prevent cattle from eating tainted feed,
becoming sick, being slaughtered before showing symptoms, and being
eaten by a person who then becomes infected.

But loopholes still allowed certain risky feedstuffs to be fed to cattle
and other ruminants. Ruminant remains - even from "downer" cows, which
are unable to walk and at higher risk of BSE - could still be fed to
chickens, pigs, and fish. And their remains, in turn, could be fed back
to ruminants, creating a cycle that some worry could transmit mad cow
disease. There's also concern that nonruminant feed containing
infectious prions could accidentally become mixed with cattled feed.

Even enforcement of the existing ban has been lax. A January 2002 report
by the Government Accountability Office found that more than four years
after the feed ban took effect, the FDA still had "not acted promptly to
compel firms to keep prohibited proteins out of cattle feed and to label
animal feed that cannot be fed to cattle." GAO investigators identified
some noncompliant feed operations that had not been reinspected for two
or more years and cases in which the FDA had not cracked down on
companies found noncompliant on multiple inspections. "FDA does not know
the full extent of industry compliance," the report said, because its
data on inspections are "severely flawed."

We do know that industry compliance with the feed ban has been
imperfect. From August 1997 through 2003, 47 companies recalled 280 feed
products that were in violation of the federal rules. During that time,
the FDA issued 63 letters warning of noncompliance. And in July 2003,
the FDA announced a consent decree with one feed manufacturer in which
the company officers admitted liability for adulterated and misbranded
animal feed and agreed to take corrective measures. With that
announcement, the FDA stated that compliance with the feed ban exceeded
99 percent. But last year, our research showed, the agency was still
sending warning letters. By March, it had recalled an additional 130
products from five more firms for violating the ban.

In January 2004 - shortly after the first mad cow, of Canadian origin,
was discovered in the U.S. - Health and Human Services Secretary Tommy
Thompson and then-FDA Commissioner Mark B. McClellan promised two new
rules to bolster the firewalls against mad cow disease. The steps were
to take effect immediately upon publication in the Federal Register, the
daily government publication of federal regulations. The rules did the

@ Banned downer cows and animal parts known to harbor the highest
concentrations of infectious prions from human food, dietary
supplements, and cosmetics.

@ Banned the use in ruminant feed of mammalian blood and blood products,
poultry litter, and meat leftovers from restaurants. Those ingredients
were used in ruminant feeds in the United Kingdom before that nation's
mad cow outbreak and contributed to the epidemic. The FDA also mandated
steps to keep ruminant feed and nonruminant feed from mixing.

Last July, the FDA put the first rule into effect. But it unexpectedly
put the other rule on hold. Instead, it called for public comment,
including comment on a new proposal to remove particularly risky cow
parts - "specified risk materials" (SRMs), such as older cows' brains
and spinal cords - from all animal feed. Such a ban would be stricter
but, like any proposal in the public-comment stage, might not result in
final regulations.

The delay has been widely criticized by consumer groups, including the
Consumer Policy Institute of Consumers Union, publisher of Consumer
Reports. "The FDA should have taken immediate action on the promises it
made," says Jean Halloran, director of the institute. "In what appears
to be a guise of considering a bigger step, they did nothing." Caroline
Smith DeWaal of the Center for Science in the Public Interest says,
"They have been studying this action since 2002, so the idea that we
need more study prior to taking such commonsense action seems absurd."
Carol Tucker-Foreman of the Consumer Federation of America called the
delay "inexplicable and irresponsible."

Stephen Sundlof of the FDA's Center for Veterinary Medicine suggests the
FDA is postponing a small step while considering a bigger one. He says
the agency was swayed by an international expert panel report in
February that suggested steps well beyond those the agency had announced
weeks earlier. "The one thing that would have the biggest impact would
be getting the SRMs out of the animal-feed system altogether," Sundlof

James Hodges, president of the American Meat Institute Foundation, which
represents the meat and poultry industry, counters that "there need to
be a risk-benefit analysis and cost-benefit analysis," adding that
there's no evidence of BSE among domestic cattle. "Spending millions or
hundreds of millions of dollars for no practical risk-reduction benefit
is not good public policy," he says. He agrees with testing high-risk
animals, which must occur after slaughter: There's no way to check
whether asymptomatic, live animals harbor mad cow disease.

"We've heard every opinion," Sundlof says. "I would say that in the
animal-feed industry there is not unanimity." However, the agency has
tentatively concluded that it agrees with the expert panel and will
propose banning all risky materials from all animal feed. When will that
ban take effect? Maybe this year, maybe not, according to Sundlof.
"These things unfortunately do take a lot of time," he says.

Chicken Arsenic and antibiotics

Chickens eat mostly a corn-and-soy mix, plus rendered animal
by-products. Since chickens do not appear to contract mad cow disease,
the main issue with their feed is drugs that are intentionally added to
kill microbes and fatten birds faster.

Conventional poultry farmers often give chickens Roxarsone (3-Nitro),
one of many drugs approved by the Food and Drug Administration for those
purposes. Roxarsone contains arsenic, though in a form less toxic to
humans than the form linked to cancer.

The USDA monitors arsenic levels in food animals. Agency researchers
ruffled feathers last January when they reported in Environmental Health
Perspectives that young chickens contain three to four times more
arsenic than other poultry and meat.

The data were based on analysis of chicken livers. Consumer Reports
decided to test both liver and muscle, the part most people eat. We took
116 samples from widely sold brands of conventional and organic chickens
bought in stores around the U.S. and from a mail-order company.

We found no detectable arsenic in the 15 liver samples from Foster
Farms, a conventional chicken brand, and none in the organic chicken
samples. The rest averaged 466 parts per billion (ppb) of total arsenic.
That's still far less than the FDA's 2,000 ppb chicken-liver tolerance
limit - the amount allowed in a food product.

There was no way to tell whether the arsenic came from drugs or was
taken up from the environment, where it's found naturally. But the lack
of arsenic in organic chickens is suggestive: USDA standards do not
allow arsenic in organic-chicken feed.

The FDA's tolerance limit for arsenic in chicken muscle meat is 500 ppb
- lower than in liver, the FDA says, because people eat more muscle than
liver. We found no detectable arsenic in our samples of muscle.

The U.S. Environmental Protection Agency, which regulates arsenic levels
in drinking water, has more stringent limits than the FDA. A few of our
chicken-liver samples had an amount that according to EPA standards
could cause neurological problems in a child who ate 2 ounces of cooked
liver per week or in an adult who ate 5.5 ounces per week.

Critics ask why arsenic is allowed in feed at all. "We're trying to do
everything we can to get levels lower in drinking water at very great
cost," Ellen Silbergeld, Ph.D., professor of environmental health
sciences at the Johns Hopkins University's Bloomberg School of Public
Health, told us. "And yet we're deliberately adding it to chicken."

Asked to comment on the use of arsenic-containing drugs, Richard Lobb, a
spokesman for the National Chicken Council, said, "There simply does not
appear to be a human health problem of any kind resulting from the use
of arsenicals in poultry production."

Like Roxarsone, human antibiotics are fed to chickens to speed growth.
But bacteria in the birds' intestines can develop resistance to them.
People who eat chicken harboring those bacteria can fall ill if they
don't handle and cook meat properly, and they may not be cured by the
drugs typically used to get rid of their illness.

In October 2000, the FDA concluded that two antibiotics used in poultry
had spawned drug resistance. The maker of one drug pulled it off the
market quickly. Bayer, maker of the other drug, challenged the FDA's
proposal to withdraw approval of its drug, Baytril, for use in poultry.
Last March an FDA administrative law judge ruled in the agency's favor.
Bayer appealed, and as of November, the FDA had not acted.

On Capitol Hill, proposed legislation would phase out the
"nontherapeutic" use in feed of antibiotics important for humans. More
than 300 organizations, including the American Medical Association, have
endorsed the bill, but its future is uncertain.

Seafood Farmed vs. wild

The FDA is responsible for ensuring the safety of imported seafood. And
there's a lot of ensuring to do: About 80 percent of seafood sold in the
U.S. is imported. Yet the FDA tests only about 2 percent of those
imports, mainly for drug residues. Last January, the GAO reported that
despite an earlier recommendation, the FDA had not established
agreements with other countries to document that their seafood-safety
systems are as stringent as the U.S. system.

Salmon are one of the major imports. They're high in heart-healthy
omega-3 fatty acids, but their fat also tends to accumulate toxins
consumed in the wild or on fish farms. In the wild, a salmon's meal of
choice is smaller fish. On farms, salmon are typically fed concentrated
fish meal and fish oil.

Results of a study led by Ronald Hites, Ph.D., an environmental chemist
at Indiana University, and published in the Oct. 1, 2004, issue of
Environmental Science & Technology showed that farmed salmon tended to
have higher levels of PBDEs, flame retardants used in polyurethane foam,
than wild salmon. PBDEs have become ubiquitous in the environment and
appear to have found their way into farmed-fish feed. They have posed
neurological problems in animals; their toxicity in humans isn't known.

The Hites team also reported in the journal Science in January 2004 that
compared with wild salmon, farmed salmon had more PCBs and dioxins,
likely carcinogens. On its own, each contaminant was well below the
FDA's tolerance level. But some samples had combined concentrations high
enough to trigger local consumption advisories. The data indicated that
farmed salmon from Europe were more contaminated than those from North
and South America.

Two major international fish-feed producers, EWOS Ltd. of Norway and
Nutreco Aquaculture of the Netherlands, test their feed for
contaminants, and spokesmen say they've taken steps to reduce levels of
PCBs and dioxins. Nutreco Aquaculture, for example, has increased the
substitution of vegetable oil for fish oil, says Viggo Halseth, managing
director of the company's research center.

The FDA is concerned, however, that some foreign fish and seafood
producers are adding unapproved drugs to feed, leaving traces in food
that could pose human health risks. Since 2003, foreign shipments of
farmed salmon reportedly tainted with malachite green, a fungicide not
approved for aquaculture use in the U.S., have been stopped in the
United Kingdom and the Netherlands, according to press reports. This
fiscal year, the FDA plans to test catfish - 80 samples of domestic, 80
of imported - for malachite-green residues. Tests from fiscal years
2001-03 have found no residues. Plans to test salmon are on hold, an FDA
spokeswoman says, while the agency assesses detection methods.

Chloramphenicol, a potent antibiotic and suspected carcinogen, is
another cause for concern. Although federal regulations prohibit its use
in animal feed, chloramphenicol has been found in shrimp imported to the
U.S. The Louisiana Department of Agriculture & Forestry began testing
imported shrimp in 2002. Ten percent of its samples to date have been
tainted with the drug.

This and other incidents here and abroad led the FDA to announce
increased testing of imported seafood for chloramphenicol. Currently,
the agency collects just eight samples of imported shrimp each week,
according to an FDA spokeswoman.

"We are concerned about chloramphenicol and malachite green and other
veterinary drugs that are not allowed in the United States because there
are serious health concerns," says Stephen Sundlof at the FDA. The
agency is trying to work with other countries to help them resolve

problems with medications unapproved in the U.S., he adds.

Reprinted from Organic Consumers Association

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