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"The Thinking Person's Pet Food"™ – Since 1979

The Case Against Raw Frozen Pet Food

R. Wysong, DVM, V. Savant, PhD

For some 25 years Dr. Wysong has alerted the public to the dangers of exclusively feeding heat processed pet foods. Not only is nutrient value diminished by heat, but a spectrum of toxins are created. Additionally, the singular feeding of processed pet foods has led to the spurious "100% complete and balanced" claim that is both logically and scientifically flawed. Entrepreneurs have seized upon this information to create a spate of raw frozen (RF) pet foods to capture a market niche and to fill the demand from consumers wanting a raw alternative to standard heat processed canned, semi-moist and dried pet foods. This market trend, as with most others, may begin with some truth (raw food is the best food) but gets distorted, if not perverted, once economic opportunity enters the picture. This paper will examine the rationale of these pet products, their economics, and dangers. A more intelligent and healthy alternative will be proposed.

Dangers

Weakened Pets And Highly Virulent Organisms – A raw state and the presence of moisture in raw pet foods provide the perfect environment for the growth of pathogenic organisms. Although prey foods in the wild often putrefy and are teeming with microorganisms, carnivores in the wild are immunologically adapted to these organisms and even benefit from the probiotic effects of some. On the other hand, domestic pets eating sterilized heat processed foods are immunologically compromised and are threatened by mutated and highly virulent pathogenic strains created by modern circumstances and antibiotic resistance. Freezing at appropriate temperatures puts pathogens in a state of arrest but does not eliminate them. Although all foods contain some pathogens, unless they are sterilized (requiring high heat or other measures that greatly diminish the nutritional value and create toxins), it is the load of these pathogens that must be of concern to consumers. RF pet foods are a potential reservoir and vector of large numbers of pathogens.

Producers With Only Kitchen Technology – Because of the minimal technology required to produce a RF pet food, essentially anyone regardless of credentials or expertise can bring a product to market. All one needs to do is grind and mix ingredients in a kitchen, package and put in a freezer. There are no controls over the conditions in the kitchen, the quality of the ingredients or the method of freezing. All these factors can dramatically influence the nutritional value and pathogenic and toxic content of the food. But being in a frozen state hides these potential dangers and therefore poses a threat to both pets and the humans who handle the foods. John Doe can make a food under unknown conditions and with unknown ingredients, label, package, freeze and deliver to consumers or stores without one single control monitoring or impeding the process. Regulators may eventually examine the label if they happen to see it in a store (they will never see it if shipped directly to consumers) and may object to some terminology or the like; but, all John needs to do is change the label and all will be well. The product could contain every manner of ingredient, be laced with virulent pathogens, and receive the www.wysong.net/products/cat-dog-health-nutrition-truth-about-pet-foods.aegis of regulators … and into the market it goes.

Raw Frozen Foods Are Not "100% Complete" – Many RF foods make (or imply) the same spurious 100% complete and balanced pet food claim as heat processed foods and thus carry with them the same health dangers. Feeding any food exclusively, let alone a nondescript packaged food containing who-knows-what from who-knows-what manufacturing environment is a bad choice if health and safety are of concern. (See The Truth About Pet Foods by Dr. Wysong).

Problems Are Ignored By Producers – RF food pathogens include not only bacteria, but fungi, viruses and parasites. Toxins include those from molds (mycotoxins), bacteria and those created by oxidation. In our study of RF pet products in the stream of commerce, not one producer addressed these concerns with any technological know-how that we could discern, and most did not even acknowledge the problems potentially lurking in their foods.

Freezing Masks Inedibles – Raw meat and organ tissue continues to use ATP (source of energy) until it is exhausted and the tissue enters a state of rigor. Endogenous enzymatic activity within the tissue continues to digest the muscle tissue (proteolysis) softening it until it becomes tender and develops the typical palatable taste. This process is retarded by cold. The freezing of properly aged meat presents few problems, however, any residual ATP present in the tissue during freezing will contract the muscle upon thawing resulting in a more unpalatable product. Mixed RF pet foods would hide this problem.

Free Radical Problems Masked – Essential fatty acids and other health enhancing lipids are critical in the diet. Once foods are ground, mixed, exposed to air, light and pro-oxidants such as heme iron and other metals found in plant and animal tissue, the contained lipids are oxidized to chain reaction producing free-radicals, causing rancidity and oxidant toxins. Freezing at appropriately low temperatures slows this process but does not stop it. The temperature in conventional freezers used for RF pet foods is not insurance against such oxidation. Because the frozen state masks olfactory detection of rancidity, foods that would be otherwise rejected end up being consumed. The free-radical pathology potential can then work its chronic degenerative disease and immune weakening effects.

Freezer Burn Indicates A More Serious Problem – Air reaching the meat surface is the cause for the freezer burns that result in the typical grayish-brown leathery spots. Frozen water on the surface or just beneath it sublimates (from solid state directly to vapor) into the air, causing moisture to be lost from the meat over time resulting in discoloration and a dry, leathery texture. Proper pet food packaging helps maintain quality and prevent freezer burn, however most packaging is permeable to air. The prevalence of freezer burn in RF pet products speaks to the fact that the product is being oxidized and with that creating free radical toxins to lay the seeds for various degenerative diseases.

Display Packaging Causes Free Radicals – Light, as well as air, can promote free radical production. Retail display pet packaging that is clear or light permeable permits light to catalyze the free radical (disease promoting) process.

Frozen Pet Products Are Not Inert To Degradation – In frozen storage there is deterioration in organoleptic quality – meat texture, fat turning granular and crumbly, and discoloration. Microbial enzymes also remain active, especially lipases that break down fats increasing their susceptibility to oxidation.

Frozen Pet Foods Can Lead To Acidemia – Tissue degradation and oxidation under high heat freezing (above 29° F), which occurs along the supply chain with RF pet products also leads to acidification. Increasing acid consumption can contribute to acidemia that lies at the base of virtually every chronic degenerative disease plaguing modern pets. (See references below.)

Temperature And Time Are Critical – Ice nucleation, as opposed to ice crystallization, is the primary vector in producing a stable, tasty, frozen pet product. Freezing is a technically complex process based on the optimum combination of temperature and time, amongst other factors. In the wrong processor’s hands, slips in proper freezing care can lead to a microbiologically unstable product and/or a sensory inferior one. Rapid freezing leads to nucleation, thereby preventing undesirable large ice crystals from forming throughout the product. With rapid freezing the molecules don’t have time to form positions in the characteristic six-sided snowflake, so nucleation overrides crystallization. On the other hand, slow freezing (the usual RF pet food situation) creates large ice crystals, which on thawing causes cellular damage to the meat. This in turn causes meat to "drip" – lose juiciness – and form a perfect liquid medium for bacterial growth.

The High Risk In Thawing – Thawing is another critical phase in the freezing process as it involves a change from crystal ice to melted water, which upon reabsorption results in microbial reactivation. Pathogenic bacteria inherently contaminate raw meat, fish, and poultry and will begin to multiply again when the temperature reaches just 29.3º F – which is below freezing! Thus a product that may appear subjectively frozen could be a veritable incubator of pathogens. When consumers attempt to thaw RF pe foods, dangers dramatically increase. The surface temperature rises long before the interior is sufficiently thawed to serve. For example, it takes about 15 hours for the middle of a 22-pound turkey to get to 32º F. In the interim the surface temperature rises to 53º F. In this amount of time there would be about 4 multiplications of spoilage bacteria as well as non-detectable multiplications of pathogens.

The FDA Model Food Code (1999) recommends that food be thawed in the refrigerator or in flowing water. Thawing RF food in the refrigerator can be inefficient and time consuming, in addition to occupying refrigeration space required for other food items. Most of all, this lengthy procedure can lead to the risk of cross-contamination when the drip from the raw meat comes in contact with ready-to-eat food stored in the refrigerator. In the alternative, consumers usually put the RF pet food out at room temperature, creating the perfect circumstance for pathogen proliferation.

Undetected Freeze-Thaw Cycles – The transit time of RF pet foods from the processor (or John Doe’s kitchen) to the distributor, to the stores and eventually to the consumer is very critical. Although freezer delivery trucks might putatively maintain stable product temperatures, lack of thermocouples fitted in the truck to show temperature readings, and/or inadequate TTIs (time-temperature indicators) can lead to microbiologically infested products without any visible spoilage signs. If the refrigeration in any part of the supply chain fails temporarily and then goes back to frozen (freeze-thaw-freeze), the consumer would never know of this abuse and danger.

Supply Chain Time Dangers – Time is the enemy of nutrition and safety. The longer the time between the farmer’s field and the belly, the greater the potential problems. RF pet foods create the illusion that time is not a factor. Because the frozen state masks toxins and odors, the consumer can be given the impression of value and freshness when, in fact, they may be getting age and toxicity.

Microwave Thawing Dangers – If RF pet foods are thawed in the microwave as a matter of convenience, the value of the food is greatly compromised. Microwaves can virtually boil the liquid phase within cells and electromagnetically alter important food components rendering them not only useless nutritionally, but toxic as well.

Mycotoxins Go Undetected – RF pet foods, particularly those that are a mix of cooked grains (which of course negates the claim for "rawness") and vegetables, can contain mycotoxins. None of the RF pet food producers surveyed addressed this problem.

Frozen Product Mixtures Make No Health Sense – In an attempt to cover every conceivable base and not miss any opportunity for profit, many RF pet food producers mix every manner of ingredient. For example, watermelon, grains, persimmons, liver, lamb, etc. Not only would creatures in the wild never eat such a smorgasbord gruel at one sitting, such combinations in the fresh state can cause serious digestive stress. Many of the exotic RF pet food ingredients do not keep well in the fresh frozen state (for example, freeze watermelon alone and see what happens, let alone combining it with meat). Also, the combination of fruit sugars with proteins can potentially create toxins such as glycation end products, acrylamides (particularly in those "RF" pet foods containing cooked carbohydrates) and reaction products of proteins with plant tannins, phenols and flavonoids. Producers "throwing the book" at RF pet food formulations in desperate attempts to capture market share make evident their motives and their scientific, health and technical naiveté.

Parasites Are Ignored – A wide range of parasites can be found within RF pet foods. Although there is technology in terms of freezing and natural ingredients that can be used to thwart this problem, none of the producers examined employed any of it that we could detect.

Packaging

The best packaging for any pet food, particularly RF pet foods, is light- and oxygen-barrier and modified atmosphere flushed. In the absence of this, oxidation proceeds rendering the lipids toxic. None of the producers surveyed employed these technologies that we could detect. Even if they did, the other problems and dangers listed above would remain.

Environmental

We live in an age of pollution and energy diminishment. RF pet foods require a tremendous amount of refrigeration and equipment all along the supply path. Freezing is energy inefficient and consumes valuable energy resources. Since RF pet foods are 70% water (at least) there are huge resources wasted in freezing and transporting the tons of this food-contained water through the supply chain. Along with all the equipment, trucking, freezing and frozen water handling inefficiency comes the pollution that parallels such industry.

Quality

In order to make their foods anywhere near affordable, RF pet food producers must search the ingredient market for items that can carry the name of real food but may in fact be only a hollow shell of the real thing. Inferior meat and organ ingredients, heat processed grains and vegetable riffraff (for example "broccoli" on a label may really be broccoli stems – like eating a branch from an apple tree rather than the apple) are used because they are of low cost. That is not to say the marketing brochures and labels do not make it appear as though the brand is not a true gourmet meal. If one reviews the various labels it becomes clear that the race is on to see who can put the fanciest and most exotic ingredients on labels ... as if that is the road to pet health. (It is not.) In a brief ingredient survey this is what we found:

Every manner of "pureed" vegetable Organic beef, rabbit, chicken, turkey, goat, lamb, duck, pork Organic honey Organic papaya, persimmons, blueberries, oranges, apples, pears Organic yogurt Organic alfalfa, millet, quinoa and barley sprouts Wheat grass Nettles Bok choy Cultured kefir Cod liver oil Capsicum Watermelon

The reader is challenged to go to the store and total up the cost of such ingredients. Some of the organic ingredients can cost over $15 per pound. But the RF pet diets containing them can retail for as little as $2-4 per pound. Take away margins for distributors and retail stores and the producer is selling them wholesale for close to a dollar per pound. Now on top of the cost of ingredients is the production, advertising, packaging, freezing and in some cases a sales force making six figures. Something most certainly does not add up. The only thing that can be missing is true ingredient quality. But how can the label say these expensive ingredients are in the food? All the RF pet food producer needs to do is put in pinches of the expensive ingredients just to say they are there.

The only economic hope for a RF pet food producer is to create the perception of "value added." They simply could not put the costly ingredients in the food to any degree and make a profit for themselves and all the middlemen up and down the chain. The price they would have to charge would be ridiculous. In effect, in order to be successful, producers must become accomplished at propaganda, not health and nutrition.

Consumers interested in cutting through to the truth do themselves and their pets a service by going to the grocery store with a list of the ingredients ostensibly in a RF pet diet. Although some RF diets in the lower price range appear to not be attempting to mislead, consumers should do the math comparing the exotic ingredients in RF pet foods to the prices for the real thing in the store and decide for themselves whether either value or honesty resides in RF pet products.

Economics

Consumers are under the mistaken assumption that a nondescript package mix of ingredients with an officious label and from a producer posing as a nutritional authority (none of the producers we examined had people at the helm with expertise or credentials) would be the best choice. Little do they realize that they could avoid essentially all of the caveats listed above by simply going to the grocer and buying fresh meats and produce. Pets do not require every nutrient in existence at every meal, as is the impression given by the 100% complete RF pet food producers, and for that matter the rest of the pet food industry. Why would people choose to pay a producer to mix inferior ingredients, package them, label them, freeze them, transport them, advertise them and pay the margin for the producer, the distributor, sales force and the retailer when they can avoid all that cost and put their money into real quality fresh foods? Some people are so convinced that RF pet food manufacturers perform some sort of magic that they will pay to have such foods put in special insulated containers packed with dry ice and overnight delivered! This is particularly ridiculous when one considers that no real convenience – and certainly no health or nutritional value – is added in the process. The consumer still has to go to the store and buy something.

At the grocer a person can buy fresh, raw, untainted meats and produce appropriate for pet carnivores at less than $1 per pound. Slightly out-of-date meats, sale items, trimmings or other still excellent products that cannot be put in the meat case can be even less. True, if you are to purchase the ingredients listed above in perfect human grade organic form (as many RF pet food producers boast) the cost could be far greater. But at least you would know what you are getting. RF pet foods can cost as much as $7 per pound with an average of about $3-4 per pound (not including shipping to the customer’s door) and most of that cost is going into freezing, transportation and profits through a whole chain of participants. Here is a case where a consumer gets to pay more (a whole lot more) and get less (a whole lot less).

A Better Alternative

Fresh foods fed in variety are without question the perfect form of nutrition. Appropriately designed cat and dog supplements to help reduce the risk of food-borne pathogens and oxidation, and to help balance high meat meals and provide a spectrum of vegetable-based nutrients and nutraceuticals such as Wysong has developed can also be of great benefit. Anything less than this is a compromise. The next best alternative is packaged dried raw foods that have incorporated in them food technology to impede pathogens, parasites and oxidation. The low water activity of these products is a great inhibitor of pathogens and the low level of moisture make storage and shipping efficient and environmentally friendly. (See our Wysong TNT™ raw dog and cat foods .) Good quality table scraps and properly designed dry pet foods and canned pet foods can be mixed into the diet rotation with benefit as well.

Consumers must learn the principles of fresh foods fed in variety and to trust in nature. Every pet owner desires the best for their pet and they are correct in thinking food is an essential element in achieving that goal. But it is incorrect to believe that another person can do more for their pet’s health than they can do themselves. All that is required is a little understanding and use of common sense. To that end we provide a free e-Health Letter, a free one-hour CD by Dr. Wysong entitled, "The Thinking Person’s Master Key To Health," healthy product alternatives designed intelligently with health as the number one objective, and books and recipes for anyone wanting to take control of their own and their family’s and pet’s health destiny so as not be led down health destructive primrose marketing paths.

(Note: Although the authors are associated with the technical development of the Wysong products mentioned above, the reader should not misconstrue the information as a commercial inducement. Wysong will teach people for free how to fresh-food-feed using only products purchased in the meat and vegetable aisles in the grocery. Although Wysong products provide convenient and supplemental alternatives and variety, no Wysong product is required to be purchased in order to achieve this superior method of feeding. The position is taken at Wysong that health professionals [which we are] have an ethical responsibility to help people prevent disease and thus are duty bound to teach people how to not need their services. So that is exactly what we do. Wysong pet products are a mere tool to help people along that path to the ideal goal of health self-sufficiency.)

References: Cano-Muñoz, G. (1991). Manual on meat cold store operation and management. FAO Animal Production And Health Paper 92. Food and Agriculture Organization of The United Nations, Rome. FDA Food Code (1999). U.S. Public Health Service, U.S. Dept. of Health and Human Services. Pub. No. PB99-115925. Washington, D.C. 20250 Food Safety and Inspection Service (2004). FOCUS ON: Freezing. U.S. Dept. of Agriculture. Washington,

D.C. 20250 Klose, A.A., Lineweaver, H., and Palmer, H.H. (1968). Thawing turkeys at ambient air temperature. Food Tech. 22:1310-1314.

Muldrew, K. and McGann, L.E. (1999). Cryobiology - A Short Course. http://www.ucalgary.ca/~kmuldrew/cryo_course/cryo_chap13_1.html

Snyder, O. P. (1999). Thawing At Ambient Temperature On The Counter. Hospitality Institute of Technology and Management, St. Paul, MN.

Wysong, R. L. (2004). Nutrition is a Serious Health Matter: The serious responsibility of manufacturing and selling. Wysong Institute, Midland, MI.

Wysong, R. L. (1990). Lipid Nutrition: Understanding Fats and Oils in Health and Disease. Midland, MI: Inquiry Press.

Wysong R. L. (1993). Rationale for Animal Nutrition. Midland, MI: Inquiry Press.

Wysong, R. L. (2000-2005). Wysong e-Health Letter. Wysong Institute, Midland, MI.

Wysong, R. L. (2002). The Truth About Pet Foods. Midland, MI: Inquiry Press.

Wysong, R. L. (2003, January 14). What to do to reverse and prevent acidemia. The Wysong e-Health Letter. Wysong Institute, Midland, MI.

Wysong, R. L. (2004). The Thinking Person’s Master Key to Health (60 Minute CD Discussion). Wysong Institute, Midland, MI.


Sections of the above article have been rebutted by Steve’s Real Food. That, and Wysong’s response, follows.

Wysong Rebuttal to Steve’s Real Food (SRF) Response

Dr. Wysong has previously published a critique of raw frozen pet foods and outlined their dangers. Here is that original article, followed by a response (SRF), and then, in bold, our rebuttal to that:

The Case AGAINST Raw Frozen Pet Foods—Dr. R. Wysong (the original article)


For some 25 years I have alerted the public to the dangers of exclusively feeding heat processed foods. Companion animal feeding has progressed - actually digressed - from table scraps and real foods the family could spare to today's "100 % complete" processed foods in primarily kibble form, with some canned and semi-moist also available. The foods appear to be scientific and improved, but they're far worse for the animals. Not only is nutrient value diminished by heat, but a spectrum of toxins is created. Additionally, the singular feeding of processed food has led to the spurious "100% complete and balanced" claim that is both logically and scientifically flawed.

SRF Response – For the last 25 years hasn’t Dr Wysong has been selling heat processed dry food??  We agree that the labeling as complete and balanced according to AAFCO regulations is flawed because there is much more involved with nutritional content than simply measuring protein, fat and fiber content. We believe this because protein and caloric content can evolve from ingredients that are not from sources beneficial or readily bio-available to pets. Historically commercial pet foods have been developed from human food bi-products.  This is why, up until recently, most pet food companies were owned by human cereal food processors like Nabisco, Standard Brands, Nestle, Ralston and many others. A smart guy said" why don’t we run that waste back through the extruder and make a kibble for dogs to eat".  Dogs wouldn’t eat it because they didn’t want to eat corn and wheat so they coated it with yellow grease, tallow and rendered digest and dogs ate it growing obese and loosing immune system properties.  No wonder most all dogs life span started to shorten after WW2 when commercial dry and canned pet foods became popular.

We do not deny the apparent Wysong contradiction. We have long taught that if people follow Dr. Wysong’s advice perfectly, they need not feed any commercial pet food—even Wysong’s. However, our world is not ideal. People are not about to turn their pets loose into the wild to seek their most natural food. Nor are most people going to home prepare raw foods mimicking prey. Most are going to seek convenient packaged products. Thus, part of Wysong’s activities is to produce the least compromised foods possible, including raw diets. Wysong does not just produce heat processed foods as SRF implies. In fact, it is Dr. Wysong who introduced the concept of raw food feeding to the pet food industry…and to SRF. Therefore, most of the arguments made in the SRF rebuttal do not apply to Wysong.   

This rebuttal is not to suggest that processed pet foods are the ideal diet, it is to give balance and perspective regarding SRF’s incorrect and exaggerated claims about pet foods other than theirs in order to promote their own commercial interests.

For example, pet foods other than theirs are not, as SRF claims, made of "waste" and "by-products," in the sense the public would normally interpret these terms: useless and harmful junk fit only for a toxic waste dump or land fill.

Most pet foods are comprised of highly nutritious ingredients and, although not "human grade," are far superior to most human foods. Humans would consider much of the natural diet of carnivores—the entire carcass of their prey—waste and by-product, yet this is the most healthful diet of all. White flour, white sugar, white salt, and white oils may seem pure, clean, and wholesome for human consumption, but they are nutrient impoverished. White flour and white rice with the by-product brans removed can create serious diseases that have killed thousands, such as Beri Beri. The "waste" bran had all the important nutrients and vitamins. Other discards from the human food industry can also be highly nutritious. For example, chicken by products—bones, organs, entrails, meat trimmings, digests—are far more nutritious than a  "human grade" white chicken breast (or "human grade" twinkies, wieners, Fruit Loops, etc.), and a lot less costly too.

Pet foods other than SRF are not made of corn and wheat coated with "grease" and other unspeakables. Not only is this not true, as anyone can discern by reading the label of modern quality pet foods, but SRF’s undocumented claim of decreased life span of pets since WW2 is untrue as well. Carnivores in the wild, given a sufficient supply of prey, have the most robust and long-lived health. That was not the state of pets prior to WW2. If anything, canning, baking, and extruding pet foods afforded most pets with a better opportunity for adequate (not to be confused with ideal) nutrition and longer life. Many people have used Wysong heat processed foods through generations of animals (contrary to our advice, but done because of ease and economy) and have had remarkable success with health (see testimonials).

Grains and food processing are, in fact, responsible for the burgeoning human population around the world. Although the best human diet is that which we could find in the wild, as the wild has run out, and agriculture (corn, wheat, etc.) took over, there has been an increased average life span. Although food abundance and heat processing is in large part responsible for this, such foods are, admittedly, not ideal. But neither are they the devil as SRF implies.

The reality of our world is that the grain food supply has taken population beyond the earth’s natural carrying capacity. To sustain the present population of people and pets requires aggressive agriculture and prudent use of all food materials (including highly nutritious human food "waste" and "by-products") until a real solution for sustainability is found and enacted. Not only that, it is unethical and inhumane to raise animals for food and harvest only those parts that are cosmetically pleasing to us and discard the rest. It’s like fishermen killing sharks, cutting off their fins for soup, and then throwing the body back in the ocean.
Expensive, high energy consuming SRF-type frozen pet foods made only of cosmetically sounding ingredients do not address these realities and ethical concerns.  

Entrepreneurs have seized upon this information to create a spate of raw frozen (RF) foods to capture a market niche and to fill the demand from consumers wanting a raw alternative to standard heat processed canned, semi-moist and dried pet foods. This market trend, as with most others, may begin with some truth (raw food is the best food) but gets distorted, if not perverted, once economic opportunity enters the picture. This paper will examine the rationale of these products, their economics and dangers. A more intelligent and healthy alternative will be proposed.

Dangers          

1. Weakened Pets And Highly Virulent Organisms - A raw state and the presence of moisture in food provide the perfect environment for the growth of pathogenic organisms. Although prey foods in the wild often putrefy and are teeming with microorganisms, carnivores in the wild are immunologically adapted to these organisms and even benefit from the probiotic effects of some. On the other hand, domestic pets eating sterilized heat processed foods are immunologically compromised and are threatened by mutated and highly virulent pathogenic strains created by modern circumstances and antibiotic resistance. Freezing at appropriate temperatures puts pathogens in a state of arrest but does not eliminate them. Although all foods contain some pathogens, unless they are sterilized (requiring high heat or other measures that greatly diminish the nutritional value and create toxins), it is the load of these pathogens that must be of concern to consumers. RF foods are a potential reservoir and vector of large numbers of pathogens.

SRF Response – To say that pets have evolved immune systems because of eating commercial sterile food for that last 40 years or so is preposterous. It takes a lot longer than that to evolve an organic system to the above mentioned degree. If you look at the time pets evolved eating raw food and human waste compared to the time they have been eating commercial food it is like comparing an inch to a hundred miles. Also if you think about it, a sterilized bag of dog food sitting around the garage or laundry room is a perfect breeding ground for bacteria of a single kind which can be a much greater health risk. Pets thrive and benefit from multiple kinds of bacteria present in their diet. Dogs and cats still have the same lengthy resident time in the gut acid bath that they evolved with and that allows them to process and benefit bacteria that humans can not tolerate. Pet health deterioration is not an evolution issue, it is a health issue that has happened because of pets eating commercial dry food diets in a short a time. They have become obese, allergic, and lethargic and have shorter life spans. Also I would like to point out that SRF is made from human quality USDA inspected ingredients processed under strict quality control procedures, not from putrefying raw material. It is the dry food and canned food manufacturers that use 4D beef.  The D’s stand for dead, downed, diseased or dieing cattle. These are commonly known as downers not fit for human consumption.

SRF discussion of how animals can or cannot "evolve" presumes knowledge they do not possess, and gives a window into a flawed materialistic/reductionistic premise. There is abundant evidence that animals can adapt and vary to a degree. There is no evidence whatsoever that life has "evolved" from inorganic matter or that organisms can transmutate. SRF makes the claim that pets cannot adapt (they use the word evolve) over a short period of time. The new science of epigenetics proves otherwise. New genetic expression (which is not "evolution") can occur in one generation. (For a complete discussion of this with proofs see Dr. Wysong’s books at AsIfThinkingMatters.com.)

The idea that creatures are nothing more than evolved stardust is science fiction, not science, and creates the mindset that living things are nothing more than a conglomeration of atoms. This in turn leads to the assumption that analyses of chemicals in creatures and foods can create good nutrition and health. The fruit of that sort of thinking has created the flawed medical system that is responsible for more deaths than any other cause (see The Greatest Threat To Your Health), nutritionally-induced diseases, and a food system with producers who attempt to convince you that you need them to tell you how much of which chemicals you and your pet need, i.e., "complete" diets.

Dried pet foods are not the perfect breeding ground for bacteria of a "single kind" as SRF claims but provides no documentation for. Bacterial growth depends upon moisture, specifically available moisture (Aw). Properly processed dry pet foods have moisture and water activity levels below that which can support microbial growth. Raw foods used in frozen products, on the other hand, support the proliferation of such organisms at any time that they are not deep frozen…and consumers cannot know when that may have occurred along the supply chain.

SRF continues with tendentious and hot button words by claiming that pet foods are made from "putrefying" and "4D beef." Not only is this largely untrue, but the fact of the matter is that carnivores thrive on putrefying carcasses and purposely select as prey the dead, dying, diseased, and disabled. They don’t try to chase down just the most robust animals and then carefully dissect out their white meat. Additionally, fermentation (a type of putrefaction) can greatly enhance nutritional value. In some cultures people bury food to let it rot before eating it to great benefit.

This is not to suggest that any food which is harmful to man or beast be eaten, but determining what is harmful or not is not determined by way of simple, nasty sounding words.

It should be noted in this SRF criticism of pet foods "not fit for human consumption," that SRF foods made in their "human quality USDA inspected" facility are not fit for human consumption either. If in doubt, ask them if it would be alright for you and your family to eat their foods.

2. Producers With Only Kitchen Technology - Because of the minimal technology required to produce a RF pet food, essentially anyone regardless of credentials or expertise can bring a product to market. All one needs to do is grind and mix ingredients in a kitchen, package and put in a freezer. There are no controls over the conditions in the kitchen, the quality of the ingredients or the method of freezing. All these factors can dramatically influence the nutritional value and pathogenic and toxic content of the food. But being in a frozen state hides these potential dangers and therefore poses a threat to both pets and the humans who handle the foods. John Doe can make a food under unknown conditions and with unknown ingredients, label, package, freeze and deliver to consumers or stores without one single control monitoring or impeding the process. Regulators may eventually examine the label if they happen to see it in a store (they will never see it if shipped directly to consumers) and object to some terminology or the like; but, all John needs to do is change the label and all will be well. The product could contain every manner of ingredient, be laced with virulent pathogens, and receive the aegis of regulators? And into the market it goes.

SRF Response – Our food is made in a plant that cost in excess of $400,000 to complete. We use Formax forming equipment to make patties and our own specially designed extrusion system to make the kibbles. This is the same kind of stainless steel equipment that is used for human food production.  We use a production crew that has extensive experience in human food production and they use the same quality control procedures as those used in human food production. Our plant is certified by the state and sterilized after each production run. We agree that some RF producers may not have the experience and facilities that we do and that is why we feel we have the best raw food available. We sample our products and test them for salmonella, campylobacter and pesticides. We even wipe the plant equipment down with a sponge and run the same tests on the sponge to make sure the plant is always sanitary. We register our products each year with the states we ship product to and comply with their testing as well. I have 30 years in the commercial pet food business and I am making raw food because I realized what a poor job commercial pet food manufacturers were doing making canned and dry products. Our formulas were developed by Steve Brown with an extensive background in food nutrition with help from UC Davis School of Veterinary Medicine . We also have a PhD in animal nutrition at our disposal and use him for frequent consultation.

SRF states that their facility required $400,000. Although that is probably better than making and selling raw frozen pet foods from an unregulated kitchen, it does not compare to the investment required for other types of processing. For example, a modest extrusion facility today (producing all the garbage SRF claims they do) can easily cost $10 million. It uses "human grade" stainless steel equipment too. The various test procedures and registrations SRF describes are performed by most quality pet food manufacturers.  So, the facts do not support their argument that the pet food industry has "poor standards" that somehow SRF has solved.

With regard to expertise, the best way for consumers to measure that is to explore the degree to which a company perpetuates myths, rather than facts and science. Also, it is most important that the decision maker in a company has deep food science, nutrition, biochemistry, health, and pathophysiology understanding, not that they farm it out to so-called experts. Experts can be found to support every conceivable product and marketing scheme—as evidenced by the fact that every human and pet food company can list their experts. That includes Jolly Rancher factories, baby formula manufacturers (responsible for deaths and disease around the world), and pet food companies who say their diets are "complete," yet have caused incidents of death and disease for decades.

Contrary to SRF’s claim, raw frozen foods do not just contain "good bacteria," nor are sterile canned or dried foods more likely to support microbial growth. If in doubt, set SRF’s raw frozen food on a kitchen counter for a month along with a bag and can of dried pet food. Then observe at the end of the thirty days to determine which supports the most microbial growth. The results of that experiment are known by anyone with common sense even before performing it.
 
3. Raw Frozen Foods Are Not "100% Complete" - Many RF foods make (or imply) the same spurious 100% complete claim as heat processed foods and thus carry with them the same health dangers. Feeding any food exclusively, let alone a nondescript packaged food containing who-knows-what from who-knows what manufacturing environment, is a bad choice if health and safety are of concern. (See The Truth About Pet Foods by Dr. Wysong).
SRF Response – It is easy to meet AAFCO (American Feed Control Officials) requirements and to state that a pet food is complete balance nutrition. AAFCO simply requires a measurement of crude protein, fat and fiber without consideration of the type of protein, fat and fiber. This has allowed commercial dry foods to meet AAFCO requirements using proteins from carbohydrates such as corn, wheat and soy to comply. The problem exists that pets do not do well on carbohydrates and other types of filler included in traditional commercial food formulated to meet AAFCO compliance. We agree that many RF diets may not be complete because they are just meat or lack necessary vitamins to provide optimum health. That is not the case with SRF because we have based our formulas on science using premium raw material and quality controls to produce our products. Many RF producers may be amateurs producing products under questionable conditions; SRF however has done this nationally since 1998 making thousands of pets healthier and lives longer. We are not amateurs!

Pet food companies do not make a practice of creating products with "fillers." They may try to make a product that is more affordable using nutritious ingredients other than "human grade" meats, but that does not mean they are using fillers. SRF makes arguments about the "completeness" of their foods and their expertise. But this goes back to their flawed materialistic/reductionistic/evolutionary assumption that their knowledge is complete and that nutrition is about percentages. What is known is a drop in the ocean of what remains to be known. Respect and humility in the face of nature, not hubris about "completeness," is the safest road to health.

4. Problems Are Ignored By Producers - RF food pathogens include not only bacteria, but fungi, viruses and parasites. Toxins include those from molds (mycotoxins), bacteria and those created by oxidation. In our study of RF products in the stream of commerce, not one producer addressed these concerns with any technological know-how that we could discern, and most did not even acknowledge the problems potentially lurking in their foods.

SRF Response – Talk about toxins, how about aflatoxin found in Diamon and Doanes dry pet food. How about the vomotoxin recall with Natures Recipe pet food? One of the reasons I got into the raw business was because of a realization of toxins present in dry foods. Dry pet food producers have a sad history of killing or making our pets deathly ill due to inadequate testing procedures and low grade ingredients. Feed grain can contain certain levels of these toxins and that may not kill immediately. Consider the fact though that we feed the same diet over and over again with this toxin, no wonder pets get cancer with compromised immune systems. Cancer is the number one killer of pets.  Feed grain specifications allow smutty, moldy, contaminated cereal to be allowed in commercial dry and canned pet food.

Every pet food company has a story about beginning their company because nobody else was doing it right. Pet food companies, as a practice, do not use "low grade ingredients," and thus that is not a reason for a new company to begin. The best way to separate profiteers from true health innovators is by the tactics used to sell their products. Profiteers can be identified by unscientific and unsubstantiated myths they either create or perpetuate to sell their products. Such myths include the claims that pet foods (other than theirs) contain "fillers," "by-products,"  "low grade ingredients," "non-human grade," "corn and wheat covered with yellow grease, tallow, and rendered digest,"  "4D beef," "putrefying raw material," "downers not fit for human consumption," "smutty, moldy, contaminated cereal," "masked bad smells," "glop produced at ten tons per hour," "infested raw material," are "toxin laden," and  "permit rats in conveyors and silos that are never cleaned."

SRF claims the reason for their existence is because of toxins in dry foods. That does not explain the millions of animals that have survived quite well, even into their late teens, consuming dried foods. The fact is, all foods (including SRF’s) contain toxins to one degree or another. SRF’s claim that their foods are tested pesticide free cannot be true since today virtually no fat sample from humans or animals does not contain such toxins. All dry foods, as SRF implies, are not laden with toxins. Nor do pet food specifications permit "smutty, moldy, contaminated cereal" into products. Why on earth would a company that wants to stay in business purposely poison their customers, "killing and making pets deathly ill," as SRF tries to argue?

5. Freezing Masks Inedibles - Raw meat and organ tissue continues to use ATP (source of energy) until it is exhausted and the tissue enters a state of rigor. Endogenous enzymatic activity within the tissue continues to digest the muscle tissue (proteolysis), softening it until it becomes tender and develops the typical palatable taste. This process is retarded by cold. The freezing of properly aged meat presents few problems, however, any residual ATP present in the tissue during freezing will contract the muscle upon thawing resulting in a more unpalatable product. Mixed RF foods would hide this problem.

SRF Response – We mask nothing in our products while dry and canned food producers do mask bad smells, coming from inferior by products, with onion and garlic and other items to keep the pet owners from being repulsed. If you want to test palatability, set our frozen raw diets instant quick frozen made from high grade meats, vegetables and fruit from Del Monte down against a bowl of dry kibble. The dog will mow you over getting to the SRF.

Virtually no pet food companies, other than Wysong, have used onion and garlic. It is not done to mask "bad smells," it is done for the health benefits created.

6. Free Radical Problems Masked - Essential fatty acids and other health enhancing lipids are critical in the diet. Once foods are ground, mixed, exposed to air, light and pro-oxidants such as heme iron and other metals found in plant and animal tissue, the contained lipids are oxidized to chain reaction producing free-radicals, causing rancidity and oxidant toxins. Freezing at appropriately low temperatures slows this process but does not stop it. The temperature in conventional freezers used for RF foods is not insurance against such oxidation. Because the frozen state masks olfactory detection of rancidity, foods that would be otherwise rejected end up being consumed. The free-radical pathology potential can then work its chronic degenerative disease and immune weakening effects.

SRF Response – Our complete and balance diets have an Omega 3-6 balance that comes from the fresh raw ingredients and the exclusive premix we use. We use anchovy and sardine oils to do this without oils from larger fish such as salmon that may contain heavy amounts of mercury. We do not use slow freezing conventional freezer as some lower quality RF producers do We have nothing to mask because our ingredients are fresh and high quality..

SRF is not capable of making a "complete and balance (sic) diets," because SRF does not possess complete knowledge. Also, the problem that can exist with fish is not "heavy amounts of mercury," but rather about any level of the heavy metal, mercury.

7. Freezer Burn Indicates A More Serious Problem - Air reaching the meat surface is the cause for the freezer burns that result in the typical grayish-brown leathery spots. Frozen water on the surface or just beneath it sublimates (from solid state directly to vapor) into the air, causing moisture to be lost from the meat over time resulting in discoloration and a dry, leathery texture. Proper packaging helps maintain quality and prevent freezer burn, however most packaging is permeable to air. The prevalence of freezer burn in RF products speaks to the fact that the product is being oxidized and with that creating free radical toxins to lay the seeds for various degenerative diseases.

SRF Response – We use a nitrogen tunnel to freeze our products immediately after forming. Having a frozen product in a freezer with constant temperature variation because the door frequently is opened can cause frost on the outside of the product. You can witness this with human food in a freezer. The frost that may sometimes accumulate is not an indication of freezer burn so much as time frozen. Because of this we rotate our inventory and ship products within 30 days of manufacture. We also date code our bags with a best before date to insure our customers of freshness. Unlike many RF producers we don’t use inferior generic white bags with sticker label to designate what the product is.  We have been converting our packaging to heat sealed nylon bags with a small window to let the customer see what is inside the bag. These bags are state of the art printed exclusive for each individual product with a zip lock to control freshness after processing. They are thick walled nylon to prevent puncture and prevent ambient air from seeping into the bag.  

8. Display Packaging Causes Free Radicals - Light, as well as air, can promote free radical production. Retail display packaging that is clear or light permeable permits light to catalyze the free radical (disease promoting) process.

SRF Response – See above comment and also we would like to point out that RF products are kept in a dark freezer not on a loading dock or next the a heated window in the sun.

That may be true, but SRF has no control once the product leaves their dock—which is the point being made in the article.

9. Frozen Products Are Not Inert To Degradation - In frozen storage there is deterioration in organoleptic quality - meat texture, fat turning granular and crumbly, and discoloration. Microbial enzymes also remain active, especially lipases that break down fats increasing their susceptibility to oxidation.

SRF Response – This is especially true for dry kibble. One of the primary causes the dry kibble has a short shelf life is the grease and rendering digest flaking off the outside of the kibble.  Without that coating dogs and cats don’t want the stuff because carbohydrates are alien to their natural diet and taste buds. Everything degrades over time, a fact of life.  Poke a miniscule hole in a can of dog food and wait a few days it will blow up. Set a dry kibble bag out for a time, especially in hot months, and watch out for what flies out of the bag. Ever wonder why commercial pet food warehouses have to be fumigated with pesticides continually. There are no pesticides in SRF, we even test it to make sure our fruit and veggies to ensure they are pesticide free.

Dry kibble does not have a short shelf life. Nor does grease and rendering digest flake off. A fairer test of shelf life is to put an unopened can, bag of dry food, and SRF on the counter and watch what happens over time.

10. Frozen Foods Can Lead To Acidemia - Tissue degradation and oxidation under high heat freezing (above 29° F), which occurs along the supply chain with most RF products, also leads to acidification. Increasing acid consumption can contribute to acidemia that lies at the base of virtually every chronic degenerative disease plaguing modern pets. (See reference below.)

SRF Response – We process at 27 degrees or below. Unlike some RF manufactures we control the production environment for temperature and exposure to pathogens that could cause rancidity and resulting academia.

But this does not address what occurs after the product leaves their warehouse. Pathogens do not cause "rancidity and resulting academia (sic)." Oxidation causes acidemia. SRF does not seem to understand what it is, so how are they going to prevent it?

11. Temperature And Time Are Critical - Ice nucleation, as opposed to ice crystallization, is the primary vector in producing a stable, tasty, frozen product. Freezing is a technically complex process based on the optimum combination of temperature and time, amongst other factors. In the wrong processor's hands, slips in proper freezing care can lead to a microbiologically unstable product and/or a sensory inferior one. Rapid freezing leads to nucleation, thereby preventing undesirable large ice crystals from forming throughout the product. With rapid freezing the molecules don't have time to form positions in the characteristic six-sided snowflake, so nucleation overrides crystallization. On the other hand, slow freezing (the usual RF situation) creates large ice crystals, which on thawing causes cellular damage to the meat. This in turn causes meat to "drip" - lose juiciness - and form a perfect liquid medium for bacterial growth.

SRF Response – We agree that many of our competitors use slow freezing.  SRF uses liquid nitrogen to instantly freeze our product for precisely the reasons mentioned.

12. The High Risk In Thawing - Thawing is another critical phase in the freezing process as it involves a change from crystal ice to melted water, which upon reabsorption results in microbial reactivation. Pathogenic bacteria inherently contaminate raw meat, fish, and poultry and will begin to multiply again when the temperature reaches just 29.3º F - which is below freezing! Thus a product that may appear subjectively frozen could be a veritable incubator of pathogens. When consumers attempt to thaw RF foods, dangers dramatically increase. The surface temperature rises long before the interior is sufficiently thawed to serve. For example, it takes about 15 hours for the middle of a 22-pound turkey to get to 32º F. In the interim the surface temperature rises to 53º F. In this amount of time there would be about 4 multiplications of spoilage bacteria as well as non-detectable multiplications of pathogens. The FDA Model Food Code (1999) recommends that food be thawed in the refrigerator or in flowing water. Thawing RF food in the refrigerator can be inefficient and time consuming, in addition to occupying refrigeration space required for other food items. Most of all, this lengthy procedure can lead to the risk of cross-contamination when the drip from the raw meat comes in contact with ready-to-eat food stored in the refrigerator. In the alternative, consumers usually put the RF food out at room temperature, creating the perfect circumstance for pathogen proliferation.

SRF Response – We aren’t selling 22lb turkeys. We produce small kibbles or 8 oz. patties that have enough surface area to thaw effectively without contamination.  We recommend that thawing take place in a refrigerator. I thaw my dog’s food by running warm water over it and feeding it within a few minutes. Talking about the use of refrigerator space or cross contamination seems to be the Author stretching for anything to complain about. The sterilized open can or dry kibble bag will grow bacteria much more rapidly than frozen products that contain good bacteria inhibiting growth of other dangerous pathogens.

Of course at room temperature anything is going to grow bacteria more rapidly than something that is frozen. But apples should be compared to apples. Room temperature SRF raw foods will grow bacteria much more prolifically than open canned food or dry kibble. It is also not true that frozen canned or dry pet foods will grow bacteria more rapidly than SRF foods. SRF provides no evidence of their astonishing claim that their foods contain "good bacteria inhibiting growth of other dangerous pathogens."

13. Undetected Freeze-Thaw Cycles - The transit time of RF food from the processor (or John Doe's kitchen) to the distributor, to the stores and eventually to the consumer is very critical. Although freezer delivery trucks might putatively maintain stable product temperatures, lack of thermocouples fitted in the truck to show temperature readings, and/or inadequate TTIs (time-temperature indicators) can lead to microbiologically infested products without any visible spoilage signs. If the refrigeration in any part of the supply chain fails temporarily and then goes back to frozen (freeze-thaw-freeze), the consumer would never know of this abuse and danger.

SRF Response – This may be a problem with sausage rolls (chubs), tubs, large medallions and packaged sleeves of 1 lb. or more. SRF is supplied to the customer in small kibbles or 8 oz. patties so that the consumer can detect if the product has had a temperature drop during the delivery process. After the instant quick freeze we package immediately and it goes through a wall into a storage freezer until it is shipped in a truck kept at zero degrees or below. If the temperature is compromised the product turns into one clump in the bag because of the small size and amount of product surface area.

14. Supply Chain Time Dangers - Time is the enemy of nutrition and safety. The longer the time between the farmer's field and the belly, the greater the potential problems. RF foods create the illusion that time is not a factor. Because the frozen state masks toxins and odors, the consumer can be given the impression of value and freshness when, in fact, they may be getting age and toxicity.

SRF Response – I think this statement would be more applicable to kibble food where grains are produced and put in a storage silo for months growing mold, then into a rail road car crossing the nation with an open top, then dropped through the rail car belly into a screw conveyor with rats running around and up a bucket elevator that is never cleaned into a silo that is never cleaned then finally into a cooker.  Have you ever driven by a commercial dry pet food plant or cannery, and taken a whiff?

This horrific portrayal of what goes on in all pet food companies other than SRF’s makes sensational reading, but is simply not true. No company could stay in business long with such practices.

15. Microwave Thawing Dangers - If RF foods are thawed in the microwave as a matter of convenience, the value of the food is greatly compromised. Microwaves can virtually boil the liquid phase within cells and electromagnetically alter important food components rendering them not only useless nutritionally, but toxic as well.

SRF Response - A microwave is kid glove handling compared to the extrusion cookers that produce kibble.  These are steam jacketed machines that cook as much from friction generated by pressure as from heat dumping out 8 to 10 tons per hour of glop before they dry it so that it will absorb a tallow or grease coating,  Pet food canneries inject steam into the products to raise the glop to a certain temperature then a piston jams the glop into a can, a lid is slapped on and it is put in a pressure cooker to get a core temperature so the can won’t blow up from the infested raw material in the can. We recommend not heating our product in a microwave above 160 degrees and would prefer it not be heated at all. Too much heat can destroy the essential natural vitamins, enzymes and bacteria pets need for optimal nutrition and digestion.

Again, words like "dumping" and "glop" make for interesting reading to an uncritical mind looking for demons, but do not reflect what actually happens outside the walls of the SRF plant.

16. Mycotoxins Go Undetected - RF foods, particularly those that are a mix of cooked grains (which of course negates the claim for "rawness") and vegetables, can contain mycotoxins. None of the producers surveyed addressed this problem.

SRF Response – We do not include cooked grains in any of our products. The fruits and vegetables are immerged in a cleansing bath to eliminate mycrotoxins.

"Immerged (sic) fruits and vegetables in a cleansing bath" does not eliminate "mycrotoxins (sic)." SRF does not seem to understand what mycotoxins are. They are not normally found on fruits and vegetables, nor are they eliminated by baths.

17. Frozen Product Mixtures Make No Health Sense - In an attempt to cover every conceivable base and not miss any opportunity for profit, many RF producers mix every manner of ingredient. For example, watermelon, grains, persimmons, liver, lamb, etc. Not only would creatures in the wild never eat such a mixed gruel at one sitting, such combinations in the fresh state can cause serious digestive stress. Many of the exotic RF ingredients do not keep well in the fresh frozen state (for example, freeze watermelon alone and see what happens, let alone combining it with meat). Also, the combination of fruit sugars with proteins can potentially create toxins such as glycation end products, acrylamides (particularly in those "RF" foods containing cooked carbohydrates) and reaction products of proteins with plant tannins, phenols and flavonoids. Producers "throwing the book" at RF formulations in desperate attempts to capture market share make evident their motives and their scientific, health and technical naiveté.

SRF Response – What makes no sense is to health is feeding low grade cereal grains, human food by-products , or rendered meat meals to pets who are carnivores. We grind suitable amounts of fresh frozen fruits and vegetables into our products to provide natural vitamins and minerals instead of adding synthetic vitamin packs like the commercial dry and canned producers. They can’t do that because their cooking process is so harsh that it kills natural vitamins. We grind the fruits and vegetables so they are introduced to the pet in the same way they would receive them from the gut or craw of their prey. The grinding also makes the vitamins more absorbable by the pet. Our fruits and vegetables vary by type depending on our protein source because our formulas are balanced and complete.

Food processing does not "kill" (sic) all natural vitamins and minerals. Also, not all vitamins and minerals added to pet foods are synthetic. Even those that are exert a beneficial effect. SRF’s claim to make "balanced and complete" foods by grinding up fruits and vegetables is just that, a claim. Making a "complete" food cannot be true because SRF does not have complete knowledge.

18. Parasites Are Ignored - A wide range of parasites can be found within RF foods. Although there is technology in terms of freezing and natural ingredients that can be used to thwart this problem, none of the producers examined employed any of it that we could detect.

SRF Response – The Author must not have looked at SRF and the quality control features we employ.

SRF has not stated what they have specifically done to eliminate parasites from their foods, they just imply that looking at their foods should give the answer. It doesn’t.

Packaging

The best packaging for any food, particularly RF foods, is light- and oxygen-barrier and modified atmosphere flushed. In the absence of this, oxidation proceeds rendering the lipids toxic. None of the producers surveyed employed these technologies that we could detect. Even if they did, the other problems and dangers listed above would remain.

SRF Response – We are setting the standard for raw pet food packaging as mentioned previously. In 8 years of production we have never had a problem.

SRF states that in eight years they have not had a (reported) problem. Although that is good, it is no assurance that problems will not occur or have not. Also, eight years is only about half the life span of pets. Additionally, food production is inherently risky. Even the most sophisticated of food processors have problems. Consumers decrease their risk by varying the diet as described in the Optimal Health Program™, not by feeding pet foods such as SRF that claim to be "complete and balanced."

Environmental

We live in an age of pollution and energy diminishment. RF foods require a tremendous amount of refrigeration and equipment all along the supply path. Freezing is energy inefficient and consumes valuable energy resources. Since RF foods are 70% water (at least) there are huge resources wasted in freezing and transporting the tons of this food-contained water through the supply chain. Along with all the equipment, trucking, freezing and frozen water handling inefficiency comes the pollution that parallels such industry.

SRF Response – The straws being grasped for by the author are so small I can hardly see them. All I can say is have you ever driven by a pet food plant and if you could stand the smell looked at the steam and smoke belching out of the stacks. I personally am aware of ground pollution, air pollution, and water pollution in grate magnitude caused by dry and canned pet food facilities. Hey let’s not forget about air pollution, anyone want to live next door to a commercial pet food canning or extrusion plant?

SRF claims to be "personally" aware of ground, air, and water pollution in "grate (sic) magnitude" from canned and dried pet food facilities. Yes, all industry pollutes. Consumers can change that by using local products and consuming less, not by purchasing raw frozen pet foods produced by polluting and energy intensive agriculture, and polluting and energy intensive trucking and freezing of raw frozen pet foods.

Quality

In order to make their foods anywhere near affordable, RF producers must search the ingredient market for items that can carry the name of real food but may in fact be only a hollow shell of the real thing. Inferior meat and organ ingredients, heat processed grains and vegetable riffraff (for example "broccoli" on a label may really be broccoli stems - like eating a branch from an apple tree rather than the apple) are used because they are of low cost. That is not to say the marketing brochures and labels do not make it appear as though the brand is not a true gourmet meal. If one reviews the various labels it becomes clear that the race is on to see who can put the fanciest and most exotic ingredients on labels ... as if that is the road to pet health. (It is not.) In a brief ingredient survey this is what we found:

Every manner of "pureed" vegetable
Organic beef, rabbit, chicken, turkey, goat, lamb, duck, pork
Organic honey
Organic papaya, persimmons, blueberries, oranges, apples, pears
Organic yogurt
Organic alfalfa, millet, quinoa and barley sprouts
Wheat grass
Nettles
Bok choy
Cultured kefir
Cod liver oil
Capsicum
Watermelon

The reader is challenged to go to the store and total up the cost of such ingredients. Some of the organic ingredients can cost over $15 per pound. But the RF diets containing them can retail for as little as $2-4 per pound. Take away margins for distributors and retail stores and the producer is selling them wholesale for close to a dollar per pound. Now on top of the cost of ingredients is the production, advertising, packaging, freezing and in some cases a sales force making six figures. Something most certainly does not add up. The only thing that can be missing is true ingredient quality. But how can the label say these expensive ingredients are in the food? All the producer needs to do is put in pinches of the expensive ingredients just to say they are there.

The only economic hope for a RF producer is to create the perception of "value added." They simply could not put the costly ingredients in the food to any degree and make a profit for themselves and all the middlemen up and down the chain. The price they would have to charge would be ridiculous. In effect, in order to be successful, producers must become accomplished at propaganda, not health and nutrition.

Consumers interested in cutting through to the truth do themselves and their pets a service by going to the grocery store with a list of the ingredients ostensibly in a RF diet. Although some RF diets in the lower price range appear to not be attempting to mislead, consumers should do the math comparing the exotic ingredients in RF pet foods to the prices for the real thing in the store and decide for themselves whether either value or honesty resides in RF products.

SRF Response – We use common easily found fruits and vegetables from a reliable source. We use things like carrots, broccoli, romaine and apples.  We use high grade poultry raised in barns, not caged or on a conveyor belt. We use high grade beef not fed growth hormone enhanced grain and not animals from dirty feed lots. We do not use organic or free range products because the prices are prohibitive and they are not found in abundance. We do believe the Author is correct about some raw food produces that seem to be making claims beyond the limits of reality. Not everybody does it truthfully and professionally in this fastest growing segment of pet food, SRF does however. 

It is not clear what "high grade" means. If it means no "fillers," "by-products,"  "low grade ingredients," "corn and wheat covered with yellow grease, tallow, and rendered digest,"  "4D beef," "putrefying raw material," "downers not fit for human consumption," "smutty, moldy, contaminated cereal," "masked bad smells," "glop produced at ten tons per hour," "infested raw material," "toxin laden," and  "rats in conveyors and silos that are never cleaned," then most other pet foods are high grade as well. With regard to "some raw food produces (sic) that seem to be making claims beyond the limits of reality," SRF is guilty as well when they claim to have complete knowledge of nutrition, biochemistry, and biology—the requisite to making a complete and balanced food.
   
Economics

Consumers are under the mistaken assumption that a nondescript package mix of ingredients with an officious label and from a producer posing as a nutritional authority (none of the producers we examined had people at the helm with expertise or credentials) would be the best choice. Little do they realize that they could avoid essentially all of the caveats listed above by simply going to the grocer and buying fresh meats and produce. Pets do not require every nutrient in existence at every meal, as is the impression given by the 100% complete RF producers, and for that matter the rest of the pet food industry. Why would people choose to pay a producer to mix inferior ingredients, package them, label them, freeze them, transport them, advertise them and pay the margin for the producer, the distributor, sales force and the retailer when they can avoid all that cost and put their money into real quality fresh foods? Some people are so convinced that RF manufacturers perform some sort of magic that they will pay to have such foods put in special insulated containers packed with dry ice and overnight delivered! This is particularly ridiculous when one considers that no real convenience - and certainly no health or nutritional value - is added in the process. The consumer still has to go to the store and buy something.

At the grocer a person can buy fresh, raw, untainted meats and produce appropriate for pet carnivores at less than $1 per pound. Slightly out-of-date meats, sale items, trimmings or other still excellent products that cannot be put in the meat case can be even less. True, if you are to purchase the ingredients listed above in perfect human grade organic form (as many RF producers boast) the cost could be far greater. But at least you would know what you are getting. RF foods can cost as much as $7 per pound with an average of about $3-4 per pound (not including shipping to the customer's door) and most of that cost is going into freezing, transportation and profits through a whole chain of participants. Here is a case where a consumer gets to pay more (a whole lot more) and get less (a whole lot less). Isn't marketing a wonderful thing?

A Better Alternative

Fresh foods fed in variety are without question the perfect form of nutrition. Appropriately designed supplements to help reduce the risk of food-borne pathogens and oxidation, and to help balance high meat meals and provide a spectrum of vegetable-based nutrients and nutraceuticals can also be of great benefit. Anything less than this is a compromise. The next best alternative is packaged dried raw foods that have incorporated in them food technology to impede pathogens, parasites and oxidation. The low water activity of these products is a great inhibitor of pathogens and the low level of moisture make storage and shipping efficient and environmentally friendly. Good quality table scraps and properly designed dried extruded and canned foods can be mixed into the diet rotation with benefit as well.

Consumers must learn the principles of fresh foods fed in variety and to trust in nature. Every pet owner desires the best for a beloved pet, and is correct in thinking food is an essential element in achieving that goal. But it is incorrect to believe that another person can do more for their pet's health than they can do themselves. All that is required is a little understanding and use of common sense.

[ NOTE: To that end, the Wysong Institute makes available a free e-Health Letter, a free one-hour CD entitled, "The Thinking Person's Master Key To Health," healthy product alternatives designed intelligently with health as the number one objective, and books and recipes for anyone wanting to take control of their own and their family's and pet's health. See www.wysonginstitute.org ]

SRF Response – Wysong is not making money on free letters, they are making money on commercial pet food we believe is inferior to our raw food diets. I feel I know because I have done it their way as a Board Member, President, CFO and Controller for more than 8 pet food companies for the past 30 years before seeing the light and helping to introduce SRF for Pets. Pet owners producing their own diets are fine. The problem is, to completely meet the needs of your pet, one should make a formula that is complete and balanced using raw food nutrients and research on the vitamin and mineral content of those items. We are adding value doing this for pet owners who do not have the desire to run a five horse grinder in a sterile kitchen making a diet that is very convenient to measure out and feed.

The objective of Wysong is not to just "make money," as SRF implies. We also do not believe that SRF can identify even one company, let alone eight, that fits the description they outline above. With regard to Wysong products being inferior to theirs, that simply cannot be true. The Wysong "product" is a method of feeding, not "a product," that incorporates dried, canned, and raw TNT™ packaged products, plus supplements backed by thousands of scientific studies, plus owner supplied fresh foods from the grocer and table. To any thinking person, that is better than relying on a SRF singular so-called complete and balanced food.

Which brings us back to the mantra by SRF about their "complete and balanced" foods. This, as repeatedly pointed out, presumes SRF actually knows what complete nutrition is. In fact, the science of nutrition is nowhere near completed with full knowledge gained, anymore than any other science is completed. What we know is puny compared to what remains to be known. No person should trust any food as a constant source of nutrition, much less from any supplier making the claim that they have complete knowledge of anything.  Nor should that trust be extended if the company demonstrates (as SRF does) that they do not even have a good understanding of the current relevant sciences.  Additionally, since SRF attempts to get you to buy their products by spreading false, exaggerated, and libelous claims about other products and companies, there is no reason to believe the accuracy of what they say about their own products.