On May 20, 2004, the U.S. Food and Drug Administration's Center for Veterinary Medicine (CVM) issued its final Guidance for Industry (GFI) entitled "Manufacture and Labeling of Raw Meat Foods for Companion and Captive Noncompanion Carnivores and Omnivores" (GFI #122).  This guidance was developed in response to the increasing trend in the use of raw meat animal feeds.  If the raw meat is not properly handled, bacteria present on the meat can make people and animals ill, and can contaminate home environments.  CVM issued the guidance in order to better protect animals and their owners.

Guidance for manufacturing and labeling raw meat foods for companion animals.

In this guidance document, FDA recommends that ingredient sources used in raw meat diets should be USDA/Food Safety and Inspection Service (FSIS)-inspected and passed for human consumption; that bones and hard materials be ground; and that all other ingredients (if any) be suitable for use in animal feeds - that is - the ingredients should be of an appropriate grade that qualified experts would agree they are safe for use in raw food for animals.

FDA recommends that manufacturing facilities take all measures necessary to prevent adulteration, including one or more of the following:

• Irradiating the final packaged product as specified in 21 CFR, Part 579
• Participating in the USDA voluntary inspection program for Certified Products for Dogs, Cats, and Other Carnivora (9 CFR, Part 355)
• Following other Good Manufacturing Practices, such as those for human foods in 21 CFR, Part 100 - and/or
• Implementing a Hazard Analysis and Critical Control Point (HACCP) plan

FDA also recommends that, unless freeze-dried, product remain frozen at all times prior to use, and that it be transported and stored in a manner to avoid microbial contamination and growth.

As for labeling, the guidance states that labels must conform to all pertinent FDA regulations and statutes, and recommends that the labels conform to all applicable Association of American Feed Control Officials (AAFCO) Model Regulations. The guide also contains several other recommendations for information that should appear on the label to encourage proper consumer handling and storage and warn of potential safety issues related to handling raw meat products.

Michigan's Requirements

To manufacture or distribute raw meat diets for animals in Michigan, a person or firm must first obtain a Commercial Feed License and comply with all of Michigan's Labeling Requirements.   Anyone manufacturing or distributing raw meat diets in Michigan will be expected to strictly follow FDA Guidance for Industry #122.

Consumer Guidelines for Safe Use

Although this guidance contains recommendations directed mainly toward the manufacturers and distributors of raw meat diets, it also recommends that the label contain a section titled Guidelines for Safe Use that informs the reader to:

• Keep the product frozen until ready to use.
• Thaw the product in the refrigerator or microwave.
• Keep the product seperate from other foods.  Wash working surfaces, utensils (including cutting boards, preparation and feeding bowls), hands, and any other items that touch or contact the product with hot soapy water.
• Refrigerate leftover product immediately or discard."Manufacture and Labeling of Raw Meat Foods for Companion and Captive Noncompanion Carnivores and Ominvores".

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