Cites Dog Food Code Authority
Description:

‘In the February issue of this magazine, there appeared an extended discussion of the plan proposed by the Dog Food Code Authority for the enforcement of “reasonable definitions and reasonable standards of identity and biological value for canned dog food, necessary to prevent deception, fraud and unfair competition in the sale of canned dog food.” It was stated that the plan proposed was so general in its terms as to permit almost anything in the way of improvement or of continuance in whole or part of the extremely objectionable practices of the present; that a remedy of the unsatisfactory conditions prevailing in the industry would, under this plan, depend wholly upon the good intentions and earnestness of the Code Authority.

Unfortunately the long delay of the Dog Food Manufacturers’ Association in agreeing to any code, and the unconscionable delay of the Code Authority in submitting a plan, left more than a little doubt as to the latter’s intentions. Many seemed to share these doubts including one member of the Code Authority, who demanded and obtained a public hearing in Washington, February 12, on the proposed standards and the plan for their enforcement. The general terms in which these documents were couched were objected to, strenuously, by most of those discussing them at the hearing and by none more than by [sic] official representatives of the NRA. The result was the Code Authority was directed to revise them extensively; making more specific practically all provisions as to standards.

This highly interesting meeting aroused the interest of newspapers and created considerable national attention because of the acknowledged abuses within the industry, many of which were first brought to light in Veterinary Medicine.

The proposed standards on canned dog food were submitted by Attorney Charles Wesley Dunn, executive officer of the Dog Food Manufacturer’s Association. Six of the seven members of the Code Authority had unconditionally approved the proposals. One member, P.M. Chappel, had insisted upon a full and complete interpretation and rewriting of the biological standards section in order, he explained: “to positively insure quality standards, honest labeling and truthful advertising.” Mr. Chappel was the only member of the Code Authority present, the others were represented by Mr. Dunn. Assistant Deputy Administrator Richard S. Scott of the NRA presided at the hearing.

Mr. Dunn outlined the development of dog food association since June 1933. Regulation was necessary, he said, because the industry was in a state of injurious progressive demoralization which was undermining the integrity of business and its economic stability. The need to establish standards was imperative in order to assure “fair competition and public protection.” He recommended Prof. George R. Cowgill and Prof. William E. Anderson of the Department of Physiological Chemistry at Yale University, as members of the Scientific Council. Both of these gentlemen were present. Mr. Dunn explained that he and Doctor Cogwill encountered difficulty in setting the form of rules establishing definitions and standards, and could see no way out other than to write “general and comprehensive rules.”

The hearing brought to light that there was some bitter opposition to most of these “general and comprehensive rules,” because they were glittering generalities, artfully arranged that none but Mr. Dunn could understand. The hearing further developed that the present food and drug applies to dog food, but has not been actively enforced for want of sufficient appropriations. The fact was also brought out that two-thirds of the canned dog food manufacturers operate outside the jurisdiction of the federal meat inspection act.

In is statement, Mr. Chappel, a member of the Code Authority, said: “The dog food industry has developed into a racket. Ninety per cent of all the dog food made is unfit [188-189] for either humans or dogs.” Very plain words, but no surprise to those familiar with the discussions of this subject that have appeared in Veterinary Medicine during the past three years. It was interesting, however, to note the shock-effect of this frank statement on the dignified assemblage. He spoke of canned dog food made with two parts corn hominy and one part cured lungs. He also repeated the incident when, at a meeting of the officials of the Dog Food Association, an eastern manufacturer of a cheap dog food (V.M., June 1934) openly admitted that he made “a rotten food and knew it, and others are doing it.” Continuing, the same speaker criticized the Code provision concerning biological standards. He advocated out-lawing dog food below a minimum nutritional and purity standard set by the Scientific Council; urged the adoption of three-generation albino rat tests, to be substantiated by feeding tests on dogs, and suggested complete rewriting of the biological standard section of the proposed plan so that anyone and everyone could understand it and know its exact requirements.

Mr. Rich, another dog food manufacturer, read a statement as follows: “Some unknowing people may question statements about unclean and diseased meats being used in dog foods . . . when canned dog foods whose principal ingredient is supposed to be meat sell regularly at retain for 5 cents a can? . . . when the can and label cost approximately 2 cents?” It was “an unclean subject” to talk about, said Mr. Rich, but approximately 90 per cent of this food is sold from grocery stores whose principal business is selling human food.

“Practically every dog food on the market has either been claimed to be either ‘a balanced ration’ or ‘clean, pure food.’ But what proof or guarantee has the public?” To clinch his point in criticizing the very general terms and chances of slipshod enforcement, Mr. Rich quoted from the February issue of this magazine, and offered a practical plan whereby the nutritional findings of approved laboratories could be submitted to and passed upon by the Scientific Council.

Many unsupported claims from the advertising of various popular brands of canned dog food were read by Mr. Rich. Some amusement was apparent when the speaker read from a label and an advertisement published in the Long Island Press,  January 24^th, 1935 – “Puro, Sanitarily prepared with pure water and cooked ready for use. Contains bran, wheat, meat scraps and assorted cereals.” This dog food was offered six cans for 25 cents.

The Consumers’ Advisory Board’s review of the proposal offered by the Code Authority of the Dog Food Manufacturers’ Association, read by Mr. Wilson, was eagerly awaited by everyone attending the hearing. Mr. Wilson saw no value in the “broad language” and “intents to prescribe” used in the proposal. It might “have some slight effect upon false, misleading and extravagant advertising” – “but in no way does it scientifically establish a minimum standard of biological value.”

There could be no misunderstanding that kind of language! The plan was not acceptable to the Government. The wording the Code plan supposed to cover standards of biological value, of Section 4, Article III of the Dog Food Industry Code reads: “Section 4. Canned dog food shall have the biological and nutritive value (a) represented by its dog food name or designation; or (b) alleged for it upon its label or in its advertisements or otherwise in its sale.”

The Consumers’ Advisory Board’s crisp answer to these jokers was:

“The Consumers’ Advisory Board sees in this section virtual evasion being accomplished under the guise of compliance with the Code provision requiring the establishments of biological value.”

The Board also emphasized the need of a new nomenclature which would definitely specify the various food substances going into canned dog food, to prevent word juggling or misuse of terms. Some of these substances have particular pedigrees as all on the inside well know. The nomenclature in use today “is not only unfair but vicious” in its effect on “honest manufacturers packing quality products.” The Board recommended [189-190] establishing a scientific procedure for the grading of biological and nutritive ratings, and non-standard labels on products that are below standard. They also objected to the personnel of the Scientific Council being subject to the approval of the Dog Food Manufacturers’ Association.

Mr. Brosemer, pleading the case of veterinarians and dog owners and breeders who want truth and honesty in dog foods, stated that 809,000,000 pounds of fresh junk of animal origin is available for canned dog foods during the average year. Emphasis was placed on the fact that it was animal junk and not meat, and that it returned around 7/16 of a cent per pound when it was used (where much of it rightfully belongs) in tankage and fertilizer, but, it brought two or three cents a pound when sold for use in canned dog foods.

Mr. Haddock of the Consumers Advisory Board asked Mr. Dunn if there was a definition of the term “dog food” in either the Food and Drugs Act or the Federal Meat Inspection Act. Mr. Dunn answered “no.” Then it came to light that the philosophy of Mr. Dunn’s interpretation was the designation “dog food” – in and by itself – “meant a complete dog food, therefore anything less than a complete dog food must have a descriptive label accordingly, to show its limited value.”

Now we were getting somewhere, and the brilliant Mr. Haddock set out to have things made clear. Questioning brought considerable explanation. For example, “There will be certain minimum biological requirements. Anything less than a complete food must have a descriptive label statement approved by the Scientific Council. The Council will lay down certain requirements, certain rules and regulations, if and when the proposals are approved by the NRA. Dr. Cogwill will draw up a set of principles of practical interpretation which, upon approval by the Council, will then be published by the Code Authority. Canned dog food manufacturers will then know exactly, on the basis of that statement of principles and interpretation, whether or not their products comply with these broad rules.” An example of how all this would apply to chemical analysis of dog foods was cited.

But Mr. Haddock and his co-workers on the Consumers’ Advisory Board think in terms of biological values. He read from a letter Mr. Dunn had written Mr. Chappel, referring to the minimum standard: A food “which has the value necessary to sustain the life of the dog and to keep it adequately nourished and in good health and condition, and permit it to reproduce and nourish puppies.” Would there be, Mr. Haddock asked, any objection to putting that right into the plan?

Mr. Dunn: “None whatever, only I would prefer to have it drawn in the broader form.”

[Mr. Dunn was] Asked if the principle of reproduction would cover three or more generations of standard laboratory animals, as a test of nutritional values would be included in the biological value section defining the requirements of a complete dog food. The answer was “yes and no.” An affirmative answer was vital. Well-known students of nutrition – Cannon, Dawley, Darling, Hart, McCollum, Mitchell, Oser, Patton and others – had agreed as to the soundness of the three-generation test. Quotations, letters or wires from all these experts had been filed with the NRA by the Breeders’ and Veterinarians’ League. Haddock knew it. He insisted upon getting it – and did get it.

Doctor Cogwill made the following statement: “A canned dog food that will successfully pass a three-generation test, with standardized test animals of known nutritional history, might be adequately called a complete dog food for practical purposes,” and added that he did not think any student of nutrition in this country would seriously argue that point.

If and when this principle is put into effect and dog foods are required to meet it, or be labeled otherwise, many practical questions on adequacy and comparative biological values constantly confronting both dog owners and canine practitioners will be answered officially. If Doctor Cogwill and Mr. Dunn can and will bring this about, honest dog food manufacturers, the veterinary [190] profession [191] and all dogdom will standard [sic] everlastingly indebted to them.

The standards and plan for enforcement proposed by the Code Authority will be re-written, incorporating numerous amendments proposed and agreed to at the hearing. In the meantime, months will probably have elapsed and “racketeering” will have continued just that much longer. The revised plan will ultimately be resubmitted to the NRA for approval unless in the interim the NIRA has lapsed through the failure of Congress to extend it beyond its present expiration date in June.’ (188-191)

Cites National Association of Dog Food Manufacturers
Description:

‘In the February issue of this magazine, there appeared an extended discussion of the plan proposed by the Dog Food Code Authority for the enforcement of “reasonable definitions and reasonable standards of identity and biological value for canned dog food, necessary to prevent deception, fraud and unfair competition in the sale of canned dog food.” It was stated that the plan proposed was so general in its terms as to permit almost anything in the way of improvement or of continuance in whole or part of the extremely objectionable practices of the present; that a remedy of the unsatisfactory conditions prevailing in the industry would, under this plan, depend wholly upon the good intentions and earnestness of the Code Authority.

Unfortunately the long delay of the Dog Food Manufacturers’ Association in agreeing to any code, and the unconscionable delay of the Code Authority in submitting a plan, left more than a little doubt as to the latter’s intentions. Many seemed to share these doubts including one member of the Code Authority, who demanded and obtained a public hearing in Washington, February 12, on the proposed standards and the plan for their enforcement. The general terms in which these documents were couched were objected to, strenuously, by most of those discussing them at the hearing and by none more than by [sic] official representatives of the NRA. The result was the Code Authority was directed to revise them extensively; making more specific practically all provisions as to standards.

This highly interesting meeting aroused the interest of newspapers and created considerable national attention because of the acknowledged abuses within the industry, many of which were first brought to light in Veterinary Medicine.

The proposed standards on canned dog food were submitted by Attorney Charles Wesley Dunn, executive officer of the Dog Food Manufacturer’s Association. Six of the seven members of the Code Authority had unconditionally approved the proposals. One member, P.M. Chappel, had insisted upon a full and complete interpretation and rewriting of the biological standards section in order, he explained: “to positively insure quality standards, honest labeling and truthful advertising.” Mr. Chappel was the only member of the Code Authority present, the others were represented by Mr. Dunn. Assistant Deputy Administrator Richard S. Scott of the NRA presided at the hearing.

Mr. Dunn outlined the development of dog food association since June 1933. Regulation was necessary, he said, because the industry was in a state of injurious progressive demoralization which was undermining the integrity of business and its economic stability. The need to establish standards was imperative in order to assure “fair competition and public protection.” He recommended Prof. George R. Cowgill and Prof. William E. Anderson of the Department of Physiological Chemistry at Yale University, as members of the Scientific Council. Both of these gentlemen were present. Mr. Dunn explained that he and Doctor Cowgill encountered difficulty in setting the form of rules establishing definitions and standards, and could see no way out other than to write “general and comprehensive rules.”

The hearing brought to light that there was some bitter opposition to most of these “general and comprehensive rules,” because they were glittering generalities, artfully arranged that none but Mr. Dunn could understand. The hearing further developed that the present food and drug applies to dog food, but has not been actively enforced for want of sufficient appropriations. The fact was also brought out that two-thirds of the canned dog food manufacturers operate outside the jurisdiction of the federal meat inspection act.

In is statement, Mr. Chappel, a member of the Code Authority, said: “The dog food industry has developed into a racket. Ninety per cent of all the dog food made is unfit [188-189] for either humans or dogs.” Very plain words, but no surprise to those familiar with the discussions of this subject that have appeared in Veterinary Medicine during the past three years. It was interesting, however, to note the shock-effect of this frank statement on the dignified assemblage. He spoke of canned dog food made with two parts corn hominy and one part cured lungs. He also repeated the incident when, at a meeting of the officials of the Dog Food Association, an eastern manufacturer of a cheap dog food (V.M., June 1934) openly admitted that he made “a rotten food and knew it, and others are doing it.” Continuing, the same speaker criticized the Code provision concerning biological standards. He advocated out-lawing dog food below a minimum nutritional and purity standard set by the Scientific Council; urged the adoption of three-generation albino rat tests, to be substantiated by feeding tests on dogs, and suggested complete rewriting of the biological standard section of the proposed plan so that anyone and everyone could understand it and know its exact requirements.

Mr. Rich, another dog food manufacturer, read a statement as follows: “Some unknowing people may question statements about unclean and diseased meats being used in dog foods . . . when canned dog foods whose principal ingredient is supposed to be meat sell regularly at retain for 5 cents a can? . . . when the can and label cost approximately 2 cents?” It was “an unclean subject” to talk about, said Mr. Rich, but approximately 90 per cent of this food is sold from grocery stores whose principal business is selling human food.

“Practically every dog food on the market has either been claimed to be either ‘a balanced ration’ or ‘clean, pure food.’ But what proof or guarantee has the public?” To clinch his point in criticizing the very general terms and chances of slipshod enforcement, Mr. Rich quoted from the February issue of this magazine, and offered a practical plan whereby the nutritional findings of approved laboratories could be submitted to and passed upon by the Scientific Council.

Many unsupported claims from the advertising of various popular brands of canned dog food were read by Mr. Rich. Some amusement was apparent when the speaker read from a label and an advertisement published in the Long Island Press,  January 24^th, 1935 – “Puro, Sanitarily prepared with pure water and cooked ready for use. Contains bran, wheat, meat scraps and assorted cereals.” This dog food was offered six cans for 25 cents.

The Consumers’ Advisory Board’s review of the proposal offered by the Code Authority of the Dog Food Manufacturers’ Association, read by Mr. Wilson, was eagerly awaited by everyone attending the hearing. Mr. Wilson saw no value in the “broad language” and “intents to prescribe” used in the proposal. It might “have some slight effect upon false, misleading and extravagant advertising” – “but in no way does it scientifically establish a minimum standard of biological value.”

There could be no misunderstanding that kind of language! The plan was not acceptable to the Government. The wording the Code plan supposed to cover standards of biological value, of Section 4, Article III of the Dog Food Industry Code reads: “Section 4. Canned dog food shall have the biological and nutritive value (a) represented by its dog food name or designation; or (b) alleged for it upon its label or in its advertisements or otherwise in its sale.”

The Consumers’ Advisory Board’s crisp answer to these jokers was:

“The Consumers’ Advisory Board sees in this section virtual evasion being accomplished under the guise of compliance with the Code provision requiring the establishments of biological value.”

The Board also emphasized the need of a new nomenclature which would definitely specify the various food substances going into canned dog food, to prevent word juggling or misuse of terms. Some of these substances have particular pedigrees as all on the inside well know. The nomenclature in use today “is not only unfair but vicious” in its effect on “honest manufacturers packing quality products.” The Board recommended [189-190] establishing a scientific procedure for the grading of biological and nutritive ratings, and non-standard labels on products that are below standard. They also objected to the personnel of the Scientific Council being subject to the approval of the Dog Food Manufacturers’ Association.

Mr. Brosemer, pleading the case of veterinarians and dog owners and breeders who want truth and honesty in dog foods, stated that 809,000,000 pounds of fresh junk of animal origin is available for canned dog foods during the average year. Emphasis was placed on the fact that it was animal junk and not meat, and that it returned around 7/16 of a cent per pound when it was used (where much of it rightfully belongs) in tankage and fertilizer, but, it brought two or three cents a pound when sold for use in canned dog foods.

Mr. Haddock of the Consumers Advisory Board asked Mr. Dunn if there was a definition of the term “dog food” in either the Food and Drugs Act or the Federal Meat Inspection Act. Mr. Dunn answered “no.” Then it came to light that the philosophy of Mr. Dunn’s interpretation was the designation “dog food” – in and by itself – “meant a complete dog food, therefore anything less than a complete dog food must have a descriptive label accordingly, to show its limited value.”

Now we were getting somewhere, and the brilliant Mr. Haddock set out to have things made clear. Questioning brought considerable explanation. For example, “There will be certain minimum biological requirements. Anything less than a complete food must have a descriptive label statement approved by the Scientific Council. The Council will lay down certain requirements, certain rules and regulations, if and when the proposals are approved by the NRA. Dr. Cowgill will draw up a set of principles of practical interpretation which, upon approval by the Council, will then be published by the Code Authority. Canned dog food manufacturers will then know exactly, on the basis of that statement of principles and interpretation, whether or not their products comply with these broad rules.” An example of how all this would apply to chemical analysis of dog foods was cited.

But Mr. Haddock and his co-workers on the Consumers’ Advisory Board think in terms of biological values. He read from a letter Mr. Dunn had written Mr. Chappel, referring to the minimum standard: A food “which has the value necessary to sustain the life of the dog and to keep it adequately nourished and in good health and condition, and permit it to reproduce and nourish puppies.” Would there be, Mr. Haddock asked, any objection to putting that right into the plan?

Mr. Dunn: “None whatever, only I would prefer to have it drawn in the broader form.”

[Mr. Dunn was] Asked if the principle of reproduction would cover three or more generations of standard laboratory animals, as a test of nutritional values would be included in the biological value section defining the requirements of a complete dog food. The answer was “yes and no.” An affirmative answer was vital. Well-known students of nutrition – Cannon, Dawley, Darling, Hart, McCollum, Mitchell, Oser, Patton and others – had agreed as to the soundness of the three-generation test. Quotations, letters or wires from all these experts had been filed with the NRA by the Breeders’ and Veterinarians’ League. Haddock knew it. He insisted upon getting it – and did get it.

Doctor Cowgill made the following statement: “A canned dog food that will successfully pass a three-generation test, with standardized test animals of known nutritional history, might be adequately called a complete dog food for practical purposes,” and added that he did not think any student of nutrition in this country would seriously argue that point.

If and when this principle is put into effect and dog foods are required to meet it, or be labeled otherwise, many practical questions on adequacy and comparative biological values constantly confronting both dog owners and canine practitioners will be answered officially. If Doctor Cowgill and Mr. Dunn can and will bring this about, honest dog food manufacturers, the veterinary [190] profession [191] and all dogdom will standard [sic] everlastingly indebted to them.

The standards and plan for enforcement proposed by the Code Authority will be re-written, incorporating numerous amendments proposed and agreed to at the hearing. In the meantime, months will probably have elapsed and “racketeering” will have continued just that much longer. The revised plan will ultimately be resubmitted to the NRA for approval unless in the interim the NIRA has lapsed through the failure of Congress to extend it beyond its present expiration date in June.’ (188-191)