What is organic dog food?
Organic food is the most recognizable and available product of the sustainable agriculture movement. While “organic” is a term that brings to mind different things to different people, the United States Department of Agriculture (USDA) defines it as “food grown and processed according to federal guidelines addressing soil quality, animal raising practices, pest and weed control, and use of additives.” Organic production attempts to use naturally occurring substances and mechanical methods, like soil tilling and crop rotation, as much as possible. Conventional agriculture, on the other hand, can freely use thousands of approved pesticides and chemical additives to grow crops and raise livestock.
THE ORIGIN OF ORGANIC
While farmers have been supplementing their fields with substances to boost productivity since the dawn of agriculture, the widespread use of modern chemical pesticides and fertilizers began in the 1940s with the approval of the insecticide DDT. DDT’s efficacy in eliminating insects and boosting crop yields sparked development of new chemical pesticides that soon numbered into the thousands.
However, a combination of lax safety testing and indiscriminate use resulted in serious health and ecological issues, which were famously investigated and exposed in Rachel Carson’s Silent Spring. The blowback from DDT’s approval and use started the organic movement, which took hold in many grassroots campaigns around the US. The movement increased in popularity through the 1970s and 80s, with various states adopting regulations and organic permitting, but the efforts lacked consistency or consumer recognition. In the wake of public outrage over children’s exposure to a now-banned pesticide called Alar, Congress passed the Organic Food Production Act in 1990 that mandated the USDA to establish national guidelines for organic agriculture and production.
WHO DETERMINES ORGANIC STANDARDS?
For producers and consumers concerned about environmental protection, natural resource utilization, and toxin exposure, organic is the most recognizable and regulated standard in the US and abroad. At least 87 countries have some form of organic standards, and more are in the process of drafting them. The regulations are typically steeped in the same desire for sustainability and concern for unknown substances that began the movement. In the U.S, organic pet food must follow the same standards as organic food for humans.
These standards are created by the USDA, largely through the National Organic Standards Board (NOSB). The Federal Advisory Board consists of a diverse group of stakeholders including owners and operators of organic farms, scientists with expertise in resource conservation and toxicology, representatives of public interest and consumer protection groups, and the certifying agents responsible for applying the standards to producers. They bring a significant amount of knowledge from different areas of the supply chain and attempt to balance the needs of producers, consumers, and regulators. This process faces its fair share of criticism regarding fairness and efficacy.
While we may not agree with some decisions, we recognize the challenge and inevitable disagreements that come with creating standards for thousands of very different agricultural businesses across the nation.
WHAT MAKES ORGANIC FOOD DIFFERENT?
One of the primary responsibilities of the NOSB is maintaining the National List of Allowed and Prohibited Substances, which, like it sounds, outlines what ingredients and farming practices are and are not allowed in order for products to receive organic certification. Reviewing the list is the most significant and simple way to understand the difference between organic and conventional agriculture, and is worth looking at if you are drawn to organic to avoid synthetic chemicals. In general, organic agriculture prohibits synthetic substances and allows non-synthetic substances. For example, the list bans fertilizer that is manufactured using natural gas as a source of nitrogen (ammonia), and most organic farms instead use animal manure or plant compost as soil additives.
The list also specifies alternatives where organic methods are not commercially available or nutritionally sufficient. For example, the list includes the mineral iodine - which is not living and thus not organic - which is often added as a nutritional supplement because iodine is not available in a digestible form in most common foods and iodine deficiency causes thyroid issues. During the early days of the organic program, this list contained many synthetic and non-organic ingredients, as entire supply chains for fertilizers, pesticides, nutrient supplements, and manufacturing processes needed to be rebuilt to provide organic-compliant alternatives. The program instituted a “sunset review” process in which every non-organic input on the list is reconsidered every five years to determine if an exemption is still necessary or if feasible organic alternatives now exist.
This flexibility and pragmatism is what allows organic agriculture to be implemented as widely as it is, and also a topic of debate and criticism over the tradeoffs and lack of ideological consistency. For example, prohibiting a synthetic pesticide can produce negative ecological effects, as some methods that are considered more natural can be more toxic and result in more pollution than the synthetic alternative.
In addition to the National List, there are some methods and procedures that the NOSB has prohibited including ionizing radiation, genetic engineering, and the use of sewage sludge or biosolids. This means that any certified organic products must also be completely non-GMO. The role of genetic engineering and genetically modified organisms in sustainable agriculture is another frequently debated topic that will be covered in more detail in future posts.
ARE THERE OTHER FORMS OF SUSTAINABLE FARMING?
There are many other frameworks and approaches to sustainable agriculture - such as biodynamic and regenerative - which take many of the objectives of the organic program even further and place additional attention on maintaining the health of the soil and farm ecosystem. However, they currently lack the ubiquity and regulatory-imposed standardization that organic carries - partially because of the inherently unique geographic factors and practices that characterize those forms of agriculture.
Without consistent and enforceable certification, the responsibility falls on the buyer to investigate and ensure that the farms are implementing sustainable practices.
While those direct, personal relationships are valuable and often preferable, they add significant complexity to supply chains and are particularly challenging for products like Petaluma’s dog foods that have a long ingredient list and require suppliers in different climates to meet year-round production schedules. Much of organic food’s commercial success - as well as its criticism - comes from its ability to work within our commoditized food system in which buyers and farmers operate at an arm's-length and an organic certification is the only indicator that a farm took additional efforts to protect the environment.
HOW TO READ AN ORGANIC LABEL
There is a common misconception that there is a single organic certification when in reality food and pet food can be certified to different degrees. The USDA does not actually carry out the inspection and verification process and instead licenses a number of private ‘certifying agents’ to offer official certification services. Those agents - like Oregon Tilth, CCOF, and QAI - perform the actual farm and manufacturing plant inspections to ensure compliance with the USDA’s guidelines.
If a product is labeled with "100 Percent Organic,” it must contain 100% organic ingredients, not including salt and water added during manufacturing. Additionally, the information panel must identify the organic ingredients. If a product is labeled with just the term “Organic,” it must contain at least 95% organic ingredients, also excluding salt and water. The remaining 5% can be non-organic if there are no commercially available organic forms, as specified on the National List. This is typically used for ingredients like gelatin, gums, and other additives or non-agricultural ingredients like minerals, bacteria, and enzymes. Both of these certification levels allow the producers to use the USDA organic seal on the label. Since dog food must be nutritionally complete as the dog’s only food source, the addition of minerals and vitamins from non-agricultural sources (i.e. non-living) like calcium carbonate (limestone) or zinc sulphate is strongly recommended. That means that producing a nutritionally-complete dog food that is 100% organic is almost impossible.
Made with Organic
If a product does not have the USDA organic seal but mentions organic ingredients on the main label, it must be made from at least 70% organic ingredients, not use any GMOs, and be inspected and certified by one of the licensed agents. This is a more realistic certification level for pet food, as most veterinary nutritionists recommend that the food is supplemented with digestible sources of amino acids like taurine that are not yet on the organic “allowed list” and thus disqualify the products from “organic” certification.
Many products have ingredients that have been certified organic, but the organic ingredients make up less than 70% of the total. In this case, the organic ingredients can be identified in the ingredient list, but the product can’t use the organic seal or the word organic on the front of the package. This labeling standard also applies to foods that use >70% organic ingredients but contain a non-agricultural ingredient that isn’t explicitly allowed on the National List. This is a problem in formulating certified organic dog foods, as the amino acid taurine is now being considered an essential dietary supplement by many veterinary nutritionists due to its perceived role in alleviating major heart issues (DCM). The synthetic form of taurine is highly digestible and has a long safety record (it is in every Red Bull energy drink), but its inclusion on the National List is still being discussed and so far has only been allowed for cat food.
We’ve chosen to include supplemental taurine in our products due to the well-supported link between taurine deficiency and heart issues, as well as the emerging evidence about the inability for some dogs to absorb taurine and taurine precursors from some natural foods. The addition of synthetic taurine makes our products ineligible for organic certification under the current rules, no matter what portion of organic-certified ingredients we use.
OUR APPROACH TO ORGANIC
We started Petaluma because of our passion for sustainable nutrition, and organic agriculture fits into our vision of a more environmentally-conscious food system. However, we recognize that supporting organic is not a cure-all to animal welfare and environmental issues. We believe buying ingredients that are certified organic is a useful proxy to support sustainable farming due to the well-documented rules, enforcement systems, and widespread availability. While we prefer to have a direct relationship with a farm, choosing organic ingredients gives an additional degree of quality assurance for ingredients that are not feasible to source directly.
Organic does not need to be an all or nothing choice to benefit the environment.Every organic ingredient we are able to source lessens our ecological burden. Dog food requires a long ingredient list to provide nutritional variety and balance, and these nutritional considerations make formulating a 100% organic product nearly impossible and adds significantly complexity to organic certification. While we are unable to carry an organic certification on our main label, we are proud to support the movement by buying thousands of pounds of organic ingredients from certified farms.
Take a look at our other posts to see how we are innovating pet food in the realm of health and the environment.