We need better labels and stronger requirements for our non-pet and non-food animals, like horses.

No one can guarantee the safety and wholesomeness of every bag of feed produced by every feed mill across the country. Although equine feeds are less regulated than pet foods and other livestock feeds—remember, horses are legally considered livestock, but they aren’t a food animal nor are they legally a pet animal—there are some safeguards in place to ensure that we can confidently purchase safe feed.

Who's in Charge?
Both human foods and animal foods are regulated by the same agencies. At the federal level, the Food and Drug Administration’s Center for Veterinary Medicine (FDA/CVM) is ultimately responsible for overseeing the safety of animal feeds.

Working with the American Association of Feed Control Officials (AAFCO), the FDA has established a list of ingredients considered safe and appropriate for inclusion in horse feeds. In some instances, this also includes maximal levels permitted. Minimal requirements for labeling are also established.

FDA Responds To Pergolide Loss

On May 11, just after our June issue went to press, the Food and Drug Administration (FDA) issued an official statement that included permission for the compounding of the drug pergolide for horses, within the framework of a valid client-patient-veterinarian relationship. The statement indicated the FDA would exercise “regulatory discretion” with regard to compounding pergolide for horses from bulk drug sources. This basically means they’re willing to bend the rules since, at this time, there is no other source. Importers were instructed how to properly label the drug so that there would be no hold-up at customs, and the flow of the bulk drug through drug wholesalers is expected to resume promptly.

Under the Food Quality Protection Act of 1996, the Environmental Protection Agency (EPA) sets acceptable levels for contaminating pesticides or other chemicals in ingredients to be used for animal feeds. They also work in conjunction with the FDA and USDA to establish surveillance systems. Testing is performed under the FDA’s Center for Food Safety and Applied Nutrition, CFSAN.

Unfortunately, there is no federal licensing requirement for a business to become an equine feed mill. There are also no federal operating standards or inspections.

However, in the wake of September 11, the FDA tightened its control over foods and food ingredients, including for animals. By law, the FDA has to be notified when foods or ingredients are being imported and their distribution is carefully documented. The FDA also has the power to quickly stop the movement/sale of any suspect product, foreign or domestic.

Animal feeds at the state level are regulated by the individual Departments of Agriculture. The regulations will be spelled out in their Commercial Feed Law.

Most states follow the federal standards for ingredients and labeling, although additional labeling requirements may vary by state. States also conduct random feed samplings to make sure that the feed conforms to its label claims, such as its listed percentage of protein or amount of calcium included.

States often publish an annual list of feeds sampled that didn’t meet label claims. Protein, the most expensive ingredient in feeds, is also the level that most frequently don’t meet label claims.

Most states also adopt the federal regulations on contaminating chemicals and pesticides. There’s generally no testing, unless a problem arises with animal health that is suspected to be feed related.

Fortunately, all states require that feed mills “register,” and they collect tonnage fees on feed produced. However, there are no specific training requirements, no standards for general cleanliness or equipment maintenance, no standards for use of pesticides or rodenticides in feed mills (other than what may come on their packaging), no standards for manufacturing, packaging, shipping or storage of feeds or feed ingredients.

State agricultural agents are authorized to enter any feed mill, storage facility, etc. for the purpose of collecting samples and inspecting, but they usually only do so if a problem is suspected.  There are no routine inspections. Since there are no manufacturing standards for equine feeds, no violations are possible other than those based on a feed not measuring up to its label claims, being incorrectly labeled, or containing a contaminating chemical or toxin (assuming anyone looks for them).

How Much Testing?
Feed for animals that are not intended for the human food chain is given a low priority, which means few if any equine feeds might be sampled at any given time.

The wheels of regulatory change move slowly, but there are ongoing efforts to define the threat posed by fungal toxins and pesticide residues, and the FDA is looking at ways to fill in the gaps in state-regulatory programs for how feeds are manufactured. AAFCO has been working on this for a long time, with their “Model Feed Safety Program,” which has proposed a set of manufacturing guidelines for states to adopt, addressing GMPs (good manufacturing processes).

However, AAFCO can’t make laws. The FDA is interested, but primarily because the regulation of the feed-manufacturing processes could be a tool for them to use in fighting bigger problems, such as controlling the risk of feed ingredients potentially contaminated with bovine spongiform encephyalopathy, also known as BSE or mad-cow disease from entering the livestock-food chain.

Bottom Line
Could something like the pet-food tragedy happen with horse feeds? Absolutely. Horses die from fumonisin (a fungal toxin found in corn, commonly called “moldy corn disease”) contamination of feeds every year. The fact of the matter is that if a feed mill wanted to make an economy feed based on what they sweep up off the floor, they could.

Is Wheat Gluten in Horse Feed?

Fortunately, much of our horse feed comes from American and Canadian farmers. At press time, wheat gluten is the pet-food ingredient believed to be contaminated with a chemical causing the small animal illnesses and deaths. It’s the high protein by-product left over after starch is extracted from wheat flour. You’re not likely to find wheat gluten listed on your horse’s feed tag, although you could. Corn gluten meal is more commonly used simply because it is more readily available here, but manufacturers who base their feed ingredients on whatever is the least expensive might use it if the price was right. Wheat gluten meal could also be listed in generic terms under “plant protein by-products” or “processed grain by-products.” And Melamine? Melamine is the chemical suspected of poisoning dogs and cats. It’s used in the manufacturing of plastics and flame retardants but also as a fertilizer in some parts of the world. In addition to wheat gluten, melamine has also been detected in imported rice protein. If it’s getting there from fertilizer, it’s conceivable that other plant/vegetable products being imported may have it too. If it’s being deliberately added to give rise to falsely high protein levels, which is beginning to look likely, any imported high protein by-product may contain it. Interestingly enough, your horse’s feed may contain melamine even if all the ingredients in your feed originated in the USA. The pesticide cyromazine, legal in the USA and also the active ingredient in an equine feed-through fly control product, is metabolized to melamine by animals and plants. The Environmental Protection Agency (EPA) has established tolerance levels for cyromazine in feeds, foods and animal tissues, but it stated that melamine is “no longer considered a residue of concern,” a decision based on a low level of toxicity in rats. In fact, no amount of testing could have prevented the pet-food problem, since melamine isn’t tested for, and cyromazine is not on the list of pesticides detectable by FDA pesticide-residue testing methods.

We’re at the mercy of farmers and manufacturers when it comes to keeping our foods free of contaminating pesticides and chemicals. Actual testing is only done on a tiny fraction of feeds and foods. Even then, “safe residues” only applies to the species used to establish them, usually rats and mice, and may not hold true for other animals.

Comprehensive testing isn’t possible. Instead, regulatory bodies have to focus on identifying what pesticides and chemicals are likely to pose the greatest threat and, most of all, on having systems in place that allow them to rapidly trace and seize any potentially dangerous foods or feeds.

We can’t be sure that our horse feeds have an acceptable standard of general quality. The USDA does have whole-grain grading systems in place, with specifics regarding contaminants and damaged or undersized kernels, but feeds don’t list the grading of the grains they use on the bag. Somewhere along the line, everyone has found corn cobs, rocks or other things that weren’t supposed to be there in their feed. There’s little more than consumer pressure to motivate feed mills and manufacturers to produce a quality product. Learn what to look for in your grain, and if something doesn’t measure up, don’t buy it.