It was more than inedible, the meat supplier Evanger’s Pet Food purchased from was a dead animal carcass processor. A company that removes dead animals from farms – including euthanized horses – and processes the meat from those dead animals for sale to pet food.

Some background. In Evanger’s lawsuit against meat supplier Bailey Farms, LLC – it states:

Bailey represented to Evanger’s that its plant was APHIS certified; when Bailey delivered its beef to Evanger’s, each pallets on which Bailey shipped the beef had a tag that contained Bailey’s APHIS certificate number “WI.-BLO-0004.” This same designation “APHIS #WI.-BLO-0004” was included on bills of lading and invoices Bailey sent to Evanger’s.

What is APHIS certified?

APHIS stands for Animal Plant Health Inspection Service. APHIS is a division of the USDA (United States Department of Agriculture) but APHIS most certainly does NOT inspect – pass or fail – meat (for human consumption). Explained by the FDA in a previous update regarding Evanger’s: “USDA-APHIS provides a voluntary service to facilities that wish to export to certain countries, inspecting their facilities according to standards established by the importing country.” An APHIS certification would NOT provide the holder with the ability to process “human grade” meat.



Was the Evanger’s meat supplier (Bailey Farms) certified by APHIS for export?

The FDA says no; “The APHIS-assigned number that the supplier was using signifies export certification.”

But…was it actually a APHIS number?



I made a phone call to the USDA, APHIS regional office (governing Wisconsin), the office confirmed that Bailey Farms does not hold a current APHIS license. When I provided the APHIS number (stated in the Evanger’s lawsuit) to the USDA representative (APHIS #WI.-BLO-0004), I was told this number “was not a APHIS number”. The USDA representative stated the number must be a state number (such as in some type of Wisconsin state license). (I have shared everything I have learned with FDA – waiting on a response from FDA on this issue. When clarification is provided by FDA – it will be shared with consumers. I do not know if Bailey Farms ever had an APHIS number or not.)

The next phone call was to Wisconsin Department of Agriculture. Again, Wisconsin Department of Agriculture was not familiar with this type of number. However they did explain that Bailey Farms holds a valid “Animal Food Processor License” within the state (license number 209915-M2). Wisconsin Department of Agriculture stated the Animal Food Processor License held by Bailey Farms would also include the license to transport and process dead animal carcasses into pet food products.

Does a Wisconsin ‘Animal Food Processor License’ mean the Bailey Farms meat was USDA inspected and approved ‘human grade’ as Evanger’s told consumers?

No. Absolutely no. An Animal Food Processor License does NOT permit the holder with ability to process “human grade” meat. Wisconsin law states: “‘Animal food processing’ means slaughtering animals or processing carcasses or carcass materials for use as animal feed”. And (bold added): “(5) “Carcass” means all or part of a dead animal, as defined in s. 95.72 (1) (c), Stats. “Carcass” does not include any of the following: (a) Material that may be lawfully sold or distributed as food for human consumption.

What kind of ‘meat’ does Bailey Farms (supplier to Evanger’s Pet Food) actually process?

If you Google the street address for Bailey Farms (549 Karem Drive, Marshall, WI), this image is displayed…

Bailey Farms website…

Quoting their website “a producer of quality pet food products”. But…

The Google Map also tells us there is another business located at the very same location. The other business is “Marshall Stock Removal”…

A Google search for ‘Marshall Stock Removal’ finds “Bailey Farms Stock Removal“

Bailey Farms and Bailey Farms Stock Removal have the same exact logo, same physical address – they are the same company. Bailey Farms is not a ‘farm’ at all. Bailey Farms turns out to be a dead animal processor. A company that picks up dead animals (cattle and horses) from area farms and processes meat from these animal carcasses into pet food meat – no matter why the animal died and no matter if the animal was euthanized.

From the Bailey Farms Stock Removal Facebook page we find these images…

Freeze-Dried Dog Treats sourced from dead animal carcasses (non-slaughtered). The Bailey Farms/Bailey Stock Removal dog treats do not disclose they are sourced from dead animal carcasses, but they do include the warning “Not for human consumption – Dog Food” (unlike the Evanger’s pet food which marketed the products as “Human Grade” meat).

Are there more ‘Bailey Farms’ out there? Are more stock removal companies selling dead animal carcass meats – including euthanized horse meat – to pet food companies?

Absolutely there are. In every state – multiple in areas of the US that have large livestock populations – there are companies that remove dead animal carcasses and process the meat into pet food/animal feed. These companies are just like Bailey Farms – selling raw meat processed from the dead/non-slaughtered or euthanized animal carcass. And as well, rendering companies (some) pick up and process dead animal carcasses into pet food ingredients (though these would be rendered ingredients – not raw meat).

Is this legal? Is it legal to sell dog treats/dog food made from dead/non-slaughtered animal material?

Per federal law, it is ILLEGAL for animal food to contain any part of an animal that is non-slaughtered. The Federal Food Drug and Cosmetic Act defines an adulterated (illegal) food as (in part) “if it is, in whole or in part, the product of a diseased animal or of an animal which has died otherwise than by slaughter”. Repeat: it is a direct violation of federal law for a pet food (any food) to contain even the smallest amount of meat sourced from a dead/non-slaughtered animal.

But…FDA openly allows anyone in the animal food business the opportunity to violate that law without prosecution. The exception is…unless the pet food company or meat supplier gets caught harming an animal.

With canned pet food – opposite to federal law – the FDA openly allows canned pet food to source meat from “diseased animals and animals that have died otherwise than by slaughter” – FDA states “it will be considered fit for animal consumption”. But FDA includes this disclaimer:

The Center will consider regulatory action based on low acid canned food violations alone where the report indicates a probable hazard to pets. CVM will also consider regulatory action against canned pet food on the basis of use of decomposed animal tissues or use of tissues containing violative drug residues.

So with the example of Evanger’s pet food – since the pet food caused the illness of multiple animals and the death of one, FDA investigated and multiple recalls occurred (again…only AFTER pets got sick and died).

With the use of meat such as that sold by Bailey Farms – sourced from dead animal carcasses – the FDA states:

CVM is aware of the sale of dead, dying, disabled, or diseased (4-D) animals to salvagers for use as animal food. Meat from these carcasses is boned and the meat is packaged or frozen without heat processing. The raw, frozen meat is shipped for use by several industries, including pet food manufacturers, zoos, greyhound kennels, and mink ranches. This meat may present a potential health hazard to the animals that consume it and to the people who handle it. Districts should conduct preliminary investigations only as follow-up to complaints or reports of injuries and should contact CVM before expending substantial resources.

Review –

FDA “is aware” that meat from dead/non-slaughtered and diseased animal carcasses is sold to pet food manufacturers.

FDA “is aware” that this material is a direct violation of federal law (laws the agency is charged with enforcing).

FDA “is aware” this material “may present a potential health hazard to the animals that consume it”.

But…FDA will continue to allow meat from dead/non-slaughtered and diseased animal carcasses to be processed as pet ‘food’ and will only investigate it a pet dies or is sickened, but won’t expend “substantial resources” on the investigation.

Evanger’s purchased meat from a dead animal carcass processor – and sold this illegal meat as “human grade” to consumers (even in a pet food claiming “organic”). There was no punishment for a violation of law – only a recall.

By the way…The penalty (per law) for introducing an adulterated food into interstate commerce: “(1) Any person who violates a provision of section 331 of this title shall be imprisoned for not more than one year or fined not more than $1,000, or both.”

When will this end? When will FDA enforce law with pet food? When will a pet food company using illegal sources of ingredients be held accountable by law?

Maybe if some pet food companies, ingredient providers and FDA representatives spent a year in jail…maybe pet food would change.

A lawsuit – Pet Food Consumers v. FDA is coming. This has to stop and consumers will sue the FDA – forcing the agency to enforce law. Soon.

Wishing you and your pet(s) the best,

Susan Thixton

Pet Food Safety Advocate

Author Buyer Beware, Co-Author Dinner PAWsible

TruthaboutPetFood.com

Association for Truth in Pet Food

What’s in Your Pet’s Food?

Is your dog or cat eating risk ingredients? Chinese imports? Petsumer Report tells the ‘rest of the story’ on over 4,000 cat foods, dog foods, and pet treats. 30 Day Satisfaction Guarantee. Click Here to preview Petsumer Report. www.PetsumerReport.com

The 2017 List

Susan’s List of trusted pet foods. Click Here

Have you read Buyer Beware? Click Here

Cooking pet food made easy, Dinner PAWsible



Find Healthy Pet Foods in Your Area Click Here