Volume 13: Industry Processes and Controls
8. Other industries
Pet food manufacture
Introduction
Features of the industry
Processes involved in the manufacture of pet food in 1986
Legislative changes and developments in the process post-BSE

Introduction

8.27 Before the emergence of BSE, parts of slaughtered bovine animals were included in food manufactured for consumption by household pets such as cats and dogs. If the bovine material entering this pet food was contaminated with BSE-infective material, the pet food could have been a channel for passing on tranmissible spongiform encephalopathies to domestic pets. This chapter examines which bovine material was used in the manufacture of pet food and how, following the emergence of BSE, practices changed in response to the perceived risks.

Features of the industry

8.28 The UK pet food industry dates from the end of the 19th century, and the production of canned pet food began in the 1930s. ¹ Since that time both the sales of pet food and the range of pet food products available have continued to increase. It is estimated that half of all households in the UK now own a pet. ²

8.29 The total market for prepared cat and dog foods in 1985 was worth approximately £745 million. ³ By 1998, the market for prepared pet food was worth just under £1.5 billion. ⁴ Food for cats and dogs accounts for most of this market, and the Pet Food Manufacturers' Association (PFMA) estimates that all of the 14.6 million pet cats and dogs in the UK eat prepared pet food at least once a week. ⁵

8.30 The emergence of BSE appears to have had a limited effect on the pet food industry. The Inquiry heard no evidence of a decline in demand for pet food. The industry was not reliant on bovine products to a significant extent and manufacturers were able to adapt their operations without excessive difficulty. ⁶

8.31 The manufacture of pet food in the 1980s was regulated by the Feeding Stuffs Regulations 1986. ⁷ These Regulations are examined in vol. 14: Responsibilities for Human and Animal Health.

Processes involved in the manufacture of pet food in 1986

8.32 This section is primarily concerned with the use of bovine material in pet food, rather than the details of pet food manufacturing processes (which were not altered to any significant extent by the emergence of BSE). As will be seen below, manufacturers responded to the perceived risks of BSE by addressing 'supply chain issues' rather than by altering manufacturing processes. Mr Terry Plant of Spillers Petfoods ('Spillers') summarised the reason for this approach: 'To minimise risk by not using raw materials about which we had any doubt.' ⁸

8.33 Pet food prepared for dogs and cats is most relevant, since bovine material was generally not included in prepared foods for other domestic pets, such as rabbits and hamsters. ⁹

Sources of raw material for pet food

8.34 A report prepared for MAFF in May 1997 made the following observations about the raw material used in the manufacture of pet food since the early 1980s:

Poultry is the major source of raw material with pork also being important. Beef and lamb are minor constituents in comparison. Since 1988, the level of imported raw materials has increased, while the amount of beef used has fallen. Bone is used in limited quantities; beef bone usage is minuscule, for reasons of palatability and functionality. ¹⁰

8.35 Pedigree Masterfoods ('Pedigree'), one of the UK's largest manufacturers of pet food, had largely ceased using bovine material by the late 1970s. Up until this time it had used bovine brain, tonsils, thymus, intestines and other derivative materials. However, by 1986 the only bovine materials from the UK that were being included in Pedigree products were spleen and vertebrae. ¹¹

8.36 Although bovine material may not have been the primary ingredient in pet food, it is evident that it was used:

Ruminant offals are, of course an important raw material in the manufacture of all types of pet food, especially tripes and spleen. Thymus is also used, as are oxtails and prime offals such as heart, liver, kidney and lungs, but to a lesser extent because of their relative expense. Crushed heads (which inevitably involve brain and spinal cord material) are used to a limited extent but will also form one of the constituent raw materials of meat and bone meal [MBM], which is used extensively in pet food manufacture - particularly of the dried and compound biscuit type of product. ¹²

8.37 MBM was included in some pet food, although its use was progressively declining during the 1980s:

It was used as a protein source in dry pet food in relatively small quantities compared to other sources of protein meals including poultry meals, soya based and other cereal meals. ¹³

8.38 It has also been suggested that blood meal, a by-product of inedible raw bovine blood, was used in the manufacture of pet food. ¹⁴

8.39 Pet food manufacturers purchased bovine material from slaughterhouses, cutting plants and renderers. ¹⁵ Often the raw material reached the pet food manufacturer in the form of a slurry, making identification of its individual constituents extremely difficult. ¹⁶

The meat materials we use in our manufacturing operation enter our canneries pre-prepared and in the form of blast or plate frozen blocks, each weighing up to 40 kg, on labelled and shrink-wrapped pallets. ¹⁷

8.40 The form in which raw materials were received meant that monitoring and inspection by pet food manufacturers was likely to be limited:

Prior to the concerns regarding BSE, raw materials would not have been subjected to any special inspection to ensure the absence of, eg, spinal cord. ¹⁸

8.41 As discussed in Chapter 5, although most knackers sold bovine meat and offal for pet food, their share of the market was not significant. Mr Alan Lawrence of MAFF's Animal Health Division, writing in 1991, estimated the contribution of knackers to total pet food sold annually to be 'about 2,600 tonnes or just under 0.2%'. ¹⁹ The Inquiry heard that large manufacturers such as Spillers and Pedigree only used materials from carcasses passed as fit for human consumption and therefore did not source any raw material from knackers. ²⁰

Products derived

8.42 Many types of cat and dog food are manufactured. The different varieties are characterised by such features as their ingredients, moisture content, packaging and the processing systems used in their production. ²¹ For instance, dry pet foods have a moisture content of 10-14 per cent, consist mainly of wheat flour and are fortified with calcium and fat soluble vitamins. MBM was used in dry foods to provide animal protein. ²²

8.43 Moist, semi-moist and frozen pet foods are also manufactured. Moist foods have a moisture content of 60 to 85 per cent, and are generally (though not always) preserved by heat treatment. The ingredients, including meats, cereals and jellies or gravies, are packed into sealed cans to preserve them. ²³

Canned foods are effectively cooked and sterilised within the can at temperatures above boiling point. Very few people cook foods above boiling point unless using a pressure cooker. Within the industry in the UK at that time it was fairly common for manufacturers to cook and sterilise their canned meat products between 125° centigrade and 130° centigrade. ²⁴

Legislative changes and developments in the process post-BSE

Voluntary measures adopted by pet food manufacturers

8.44 The pet food industry first became aware of BSE in 1987. In the months that followed, the UK's larger manufacturers of pet foods, such as Pedigree and Spillers, took a number of steps in response to the perceived risk posed by the disease.

8.45 In July 1988, Spillers stopped using bovine spleen in its products and replaced it with liver. At the same time, it changed its specification for ground bone to exclude the use of bovine heads and backbones with the intention of eliminating brains and spinal cord. ²⁵

8.46 In October 1988, Spillers stopped using MBM which originated in the UK and replaced it with poultry meal, imported pork meat meal and prairie meal (derived from maize). ²⁶

8.47 In February 1989, the report of the Southwood Working Party stated that domestic pets could be susceptible to BSE, if the agent were to reach them 'in an adequate dose by an appropriate route'. However, the report also suggested that pets such as cats and dogs might not be able to acquire the infection orally and that the high temperatures used in the canning process might have destroyed any infectious agent present. ²⁷

8.48 By March 1989, it was reported that most companies manufacturing pet food were 'avoiding UK cattle nerve tissue, spleen and brains' in favour of sheep or poultry meat. ²⁸

8.49 In May 1989, following receipt of advice from the spongiform encephalopathy expert Dr Richard Kimberlin (whom the company had retained in July 1988 to advise it on BSE), Pedigree decided to remove certain bovine materials from its pet foods. In particular, it ceased purchasing from UK sources both spleen and those parts of the vertebrae which might include spinal cord. ²⁹

The materials did not represent a major part of Pedigree's raw material supply and could be relatively easily and inexpensively replaced. Pedigree decided in May 1989 no longer to include them in its recipes, and told the PFMA and MAFF of its decision. ³⁰

8.50 Pet food manufacturers also took steps to monitor the quality of the material they were receiving from suppliers. For instance, the Inquiry heard that in 1988 Spillers used whole rather than minced offals so that its inspectors 'could detect any adulteration or contamination of material as it entered the factory'. ³¹ Other manufacturers adopted similar measures:

. . . as a routine procedure we would have vendor assurance technicians visiting the collector who collected from the abattoirs and from time to time the abattoirs themselves. ³²

PFMA voluntary ban

8.51 On 16 June 1989, following the announcement of the proposed ban on SBO for human consumption, the PFMA announced a voluntary Code of Practice under which its members would not use certain bovine materials of UK origin. The materials to be excluded were those which were to become SBO upon the subsequent introduction of the Bovine Offal (Prohibition) Regulations 1989, banning their use in human food. In particular, PFMA members were advised not to include the following bovine materials of UK origin:

(i) spleen;

(ii) thymus;

(iii) tonsils; and

(iv) any emulsions, forms of ground material or other product containing any material from heads (including the brain) and spinal columns, including the spinal cord. ³³

8.52 In November 1989, small and large intestines were added to this list so that it accorded with the human SBO ban introduced by the Bovine Offal (Prohibition) Regulations 1989.

8.53 Adoption of the PFMA ban and the changes in policy made previously by manufacturers were voluntary measures. Pet food manufacturers were not subject to the ruminant feed ban, and the PFMA noted that the pet food industry often adopted policies in relation to raw materials which were ahead of legislation. ³⁴

8.54 The level of compliance with the PFMA voluntary ban appears to have been high. Members of the PFMA were responsible for the manufacture of at least 95 per cent of all pet food, and the PFMA said that compliance was not difficult for its members as the specified tissues were 'only in minimal use for quality and quantity reasons'. ³⁵ While the PFMA was satisfied that its members were observing the ban, it was less certain about observance by non-member manufacturers. ³⁶ These were likely to be small businesses who were unlikely to have distributed their products nationally. ³⁷ They were considered to be a mixed group, including 'small enterprises attached to granaries, abattoirs, knacker's yards and butcher shops'. ³⁸

8.55 By July 1990, the voluntary ban had affected the demand for MBM to the extent that it was described as 'unsaleable' as a pet food ingredient. ³⁹

The Bovine Spongiform Encephalopathy (No. 2) Amendment Order 1990

8.56 The BSE Amendment Order of 1990 came into effect in September of that year. It extended the ban on the use of SBO to animal feed. Any pet food manufacturers not already complying with the PFMA voluntary ban were now required by law to exclude all SBO from their products.

Alternative sources of raw materials

8.57 The policies of major pet food manufacturers meant that they had been sourcing raw material from outside the UK before the introduction of the PFMA voluntary ban and the 1990 Order. Owing to insufficient UK production, the industry already imported 'primary offals such as liver, kidney and tripe'. ⁴⁰ Instead of UK bovine material, it used poultry and porcine material or imported bovine material from outside the UK. ⁴¹ Manufacturers had obtained materials from the US, Canada and Australasia, ⁴² and some had been importing meat meal from Denmark, from as early as June 1988. ⁴³