Update for September 22, 2008: Will the highest court in Washington state condone attorney misconduct and criminal destruction of evidence? The text of the final brief in 81674-3 has been added to the legal section of the site. The Court is scheduled to consider the matter on October 1, 2008 without oral argument.

Update for September 8, 2008: The legal section of the site has been updated with recent events and filings in Earl v. Menu Foods. Briefly, Menu Foods was illegally spiking pet food with cyanuric acid during 2006, which was cross contaminated with other toxins, and which also reacted with melamine in gluten, to kill over a quarter million pets. In the most outrageous scam ever to be perpetuated with the approval of our judicial system, Menu Foods destroyed the entire body of evidence that would have proven their criminal conduct. To compile outrage upon outrage, Menu Foods is asking for over $8,000 in sanctions in revenge for my exercising my Constitutional right to due process in attempting to obtain some part of this body of evidence on discovery before it was destroyed.

If any pet owners have unopened samples of pet food manufactured prior to the end of December 2006, and would be willing to make them available for testing, please contact me. The samples I’m interested in would be store brands with expiration dates of “09” for canned food and “08” for pouches. I’m interested in the “loaf” style of pet food that does not list gluten as an ingredient. If anyone has such samples available for testing, I would most sincerely appreciate your making them available. Personal information of those making samples available will be held in the strictest confidence.

Update for March 16, 2008: I've added a new page covering Menu Foods' program to destroy a huge body of critical evidence, and my efforts to obtain some part of that before it is gone. If nothing else, view the photos and documents and ask yourself if you would buy anything intended to be food from a company that maintains its facilities in such a slovenly condition.

Update for November 10, 2007: In documents filed in Federal District Court, the FDA claims it has no public duty to investigate poisoned pet food. A PDF file of the FDA's reply brief has been uploaded to the legal section of the site.

Update for September 20, 2007: Official launch of the Pet Food Products Safety Alliance. Click on the banner to find out how you can get involved at the consumer level to help protect our pets from unsafe food. Update for September 8, 2008: Pfpsa.org is nearly a year old now. The effort has shown that private citizens working together can make a difference. Please take a few minutes to visit the site to see what has been accomplished over the past year. There is always more pet food that needs to be tested than there are funds available to cover the costs. Donations from private citizens are what makes the effort possible.





INTRODUCTION


Many things about the pet food recall appeared odd from the day it was announced. The situation only became more so with each passing day. Menu Foods claimed the recall was in response to two complaints. What company launches a $40 million recall in response to two complaints? Menu Foods claimed they had produced 60 million servings of deadly food over the course of 5 months, but had only become aware there was a problem two weeks earlier. Menu Foods claimed they knew which ingredient was responsible for the problem, but claimed they hadn’t the foggiest notion as to why that ingredient would be at issue to the exclusion of all others. The idea that a food company, with over $350 million in annual revenue, does not have access to world class lab facilities is patently absurd. Perhaps the most alarming aspect of the situation was the FDA, in charge of oversight, declared they would stand down on investigating the situation, leaving the whole thing up to Menu Foods and pet food lobbyists.

Worse yet, having myself lost a six year old cat to the sudden and inexplicable onset of the described symptoms in January, the suspect food in my possession was never added to the lists of deadly products produced by Menu Foods. As additional products were added to a list which grew larger day after day, it was never named. And with each new announcement, we were told that was the last of it and everything else was safe to feed our cherished companion animals.

Considering the Internet originated as a mechanism for what were arguably the top minds in the country to publish credible research, it is truly amazing how few people attempt to access the most awesome body of information ever available. A week after the recall was announced, aminopterin was discovered in pet food samples. It was billed as rat poison. It was quite obvious both Menu Foods and the FDA were in a state of panic that aminopterin was found rather than the anticipated “surprise” announcement of melamine.

With many questions, and few answers, I began a research effort which grew to a collection of many hundreds of bookmarks over the course of the following two months. As of this writing, May 30, 2007, the site has been up for two days. It is rough, incomplete and in dire need of some judicious editing. The ultimate goal is to create a carefully and credibly documented source of answers to those questions. The project is well begun. More will follow.


AMINOPTERIN


Aminopterin was originally developed as a cancer treatment. Unfortunately, the cure ended up being worse than the disease, with some very negative side effects including miscarriage, birth defects, and kidney failure, to name a few. The American Cyanamid Company was issued a patent on aminopterin for use as a rodenticide. American Cyanamid was acquired by BASF in 2000,(1), and there is no indication that either company has ever produced aminopterin commercially for use as a pesticide. There is in fact no indication that aminopterin has ever been used as a rodenticide anywhere in the world.

It would appear the only source in the world today for aminopterin is Syntrix Biosystems.(2) Not surprisingly, Syntrix immediately denounced the finding of aminopterin in pet food.(3) As the only known source of aminopterin, Syntrix could hardly be viewed as an impartial source of information on the toxin. Were an honest investigation to take place, it is certain Syntrix would be at the focal point, being the only known source of an exceedingly rare toxin.

Two quotes in the press release are of particular interest: "The FDA Office of Orphan Products Development has supported Dr. Kamen with grants for the clinical testing of Aminopterin in pediatric leukemia.", and, "These results are completely consistent with the findings of the FDA, who announced today that they found no evidence of Aminopterin in food samples.". The FDA itself does not appear to be an impartial witness when it comes to aminopterin. It is worth taking note that the FDA stated they did not find evidence of aminopterin. It DOES NOT say the FDA actually bothered to test for it.

The fact is the New York State Department of Agriculture & Markets stands behind their finding of aminopterin in samples of the pet food.(4) Under the circumstances, three obvious questions come to mind: 1. Why was the FDA so quick to stand down on following the aminopterin lead? 2. If Syntrix was the original source of the toxin, how did it get into pet food? 3. Are lab animals and/or medical waste sent to rendering plants for use in pet food?


MELAMINE, CYANURIC ACID, AMILORINE AND AMILORIDE


At this point a brief explanation of the reference "LD 50" is in order. The "LD 50" of a substance is the amount of a toxin, in terms of the test subject's body weight, measured in kilograms, that is lethal to 50 percent of the subjects receiving that dosage. It translates roughly as Lethal Dose 50%. For example if the LD 50 of a substance was 1,000 mg./kg., one gram (1,000 mg.) would kill a 1 kilogram rat half the time For a two kilogram rat, it would take 2 grams, etc.. The lower the quantity, the more lethal the toxin. For example, a LD 50 of 500 mg./kg. is twice as toxic as an LD 50 of 1,000 mg./kg..

With the above background information, the LD 50 for Melamine is 3,160 mg./kg. (5). The LD 50 for cyanuric acid is 7,700 mg./kg. (6). For comparison, the LD 50 for common table salt is 3,000 mg./kg. (7). In other words, salt is slightly more toxic than melamine, and over two and a half times as toxic as cyanuric acid.

The University of Guelph in Canada has speculated that a combination of melamine and cyanuric acid could possibly account for the observed kidney failure in cats and dogs. (8) There are four main problems with the theory: 1. The crystals they produced look nothing like the crystals removed from lab animals. 2. The spectrograph in Figure 4 shows the two crystals are not the same. 3. The crystals required large quantities of cyanuric acid to produce, where to date only traces have been found in the contaminated grain products. 4. The resulting crystals are still little more toxic than plain old table salt.

It is also worth noting at this point that the lab animals provided to the University of Guelph were supplied by Menu Foods.

Crunching the numbers, the FDA has reported maximum concentrations of melamine in the grain at 6.6%. The gluten makes up 10% of the pet food, so you have 10% of 6.6% for a total concentration of melamine at .0066%. In a 5.5 ounce can of cat food, there would be 1 gram of melamine at the highest reported concentration. In a 13 ounce can of dog food, there would be 2.4 grams. The LD 50 for a 9 pound cat would be 13 grams. In a 45 pound dog, the LD 50 would be 63 grams or well over 2 full ounces.

Quoting from previous melamine toxicity studies: (9) "CHRONIC FEEDING TESTS HAVE BEEN CARRIED OUT ON RATS OVER A 2-YR PERIOD AT A DIETARY LEVEL OF 1000 PPM AND ON DOGS FOR 1 YR AT A LEVEL OF 30,000 PPM. THROUGHOUT THE STUDY, THE GENERAL HEALTH ... WAS NOT SIGNIFICANTLY DIFFERENT FROM THAT OF THE CONTROLS ... AFTER 60 TO 90 DAYS, HOWEVER, THE DOGS SHOWED MELAMINE CRYSTALLURIA, WHICH PERSISTED THROUGHOUT THE REMAINDER OF THE 1 YR OF OBSERVATION. AT THESE LEVELS AT AUTOPSY, GROSS AND MICROSCOPIC EXAMINATION OF THE TISSUES REVEALED NO ABNORMALITY ATTRIBUTABLE TO THE FEEDING OF MELAMINE."

30,000 parts per million comes to 30 grams per kilograms. At that level, a 13 ounce can of dog food would contain 11 grams of melamine. In other words, in the above study, dogs were fed nearly 5 times as much melamine as what was found in the contaminated pet food, for a full year, with no ill effects. Even if we cross over into the realm of pure speculation, proposing an unproven theory that cats may be less tolerant to melamine than dogs, there should have not been ANY dog deaths from eating food contaminated with melamine.

At this point, as we know dog deaths have been widely reported, we also know melamine could not possibly have been responsible for those deaths because well documented studies have shown dogs can tolerate melamine at levels 5 times the maximum amount found in the pet food.

This also proves both Menu Foods and the FDA are lying through their teeth and are engaged in a massive cover up. Toxins far more lethal are involved in the pet deaths.

In a recent lab analysis of a mixture of Pet Pride "Mixed Grill" SEP07 09, and Pet Pride "Turkey Giblets Dinner" APR24 09, both produced by Menu Foods, and neither on any recall lists, cyanuric acid and acetaminophen were found in the food. Acetaminophen is fantastically deadly to cats, and very dangerous to dogs. There are no grain ingredients listed in either of these products, and NO MELAMINE WAS FOUND IN THE SAMPLES.

Once again, we are able to prove conclusively that both Menu Foods and the FDA are engaged in fraud. We know that ALL of the suspect grain products from China contained melamine. For the food to contain cyanuric acid, but NO melamine, proves it DID NOT come from China. As we know cyanuric acid, being high in nitrogen content, falsely inflates the apparent protein content in the food, and that it was not introduced into the food by the Chinese, it can only have been added by the folks at Menu Foods.

While this proves Menu Foods is engaged in fraud, the question of how acetaminophen got into the food still needs to be explained. While the possibility of sabotage is not impossible, there would be no reason for Menu Foods to engage in a 6 month long cover up. A quick criminal investigation, an indictment, a recall of the batches contaminated by the criminal, and the usual PR fluff about how sorry, etc.. It would have been a done deal last December.

A more likely scenario is that Menu Foods, after suffering massive losses the previous year, with no cash cushion due to a policy to pay out all profits to shareholders, having briefly returned to profitability as a result of the cyanuric acid scam, found the cyanuric acid to be contaminated. As the least enlightened citizen knows these days, adulterating food with industrial chemicals for fun and profit is against the law. Intentionally doing so means heap big trouble and massive liabilities, both civil and criminal. Among other considerations, Menu Foods' product liability insurance would not provide coverage for intentional adulteration of the pet food by the company.

Chemicals such as acetaminophen don't come from the factory in neat little pills. It is shipped in bulk and has to be packaged for further distribution. While you would not want acetaminophen to be present in food intended for cats and dogs, it would not be a major concern if it was present in cyanuric acid intended to be mixed with 10,000 gallons of swimming pool water. In our corner cutting, modern industrial world, while some care to clean packaging equipment before processing acetaminophen would be in order, getting fussy about cleaning the equipment for a subsequent cyanuric acid run just means lost productivity and a higher cost of doing business.

While a claim of grain products unknowingly contaminated with melamine makes for a convenient business lie. That doesn't work for cyanuric acid contaminated with acetaminophen, which is not allowed in food under any circumstances.

Perhaps the most patently absurd lie being told by Menu Foods is the claim they were unaware they were distributing pet food containing deadly toxins for over 4 months before they noticed it. The claim is they accidentally discovered the problem as a result of "regular" food testing trials at the end of February. The initial claim was such tests are conducted at least quarterly. Menu Foods has also admitted the manufacture of contaminated food dates back to at least November. That being the case, Menu Foods was well aware the food contained poisons deadly to pets no later than December as a result of the previous quarter's taste tests.

You might ask why Menu Foods would delay the recall for months, knowing pets were dying slow and terrible deaths with every hour the recall was delayed. $350 million in annual revenue is why. With a third of a billion dollar market share at stake, criminals do not admit to criminal acts. The cover up required that they allow enough time to pass to let every last can of poisoned food be consumed by pets, or discarded by the pet's owner after the death of the pet, in order to destroy the evidence.


HOW MANY PETS WERE MURDERED?


From information in the public domain, it is possible to calculate the number of pet deaths with a reasonable degree of certainty. Banfield, a nationwide veterinary chain, reported a 30% increase in kidney failure during the recall period.(10) This is from a statistical universe of one million pets over the 3 month period. One study shows kidney failure to be the cause of death in 18.7% of cats, with 9 years as the average life span of a cat and 12% in dogs with the average lifespan being 11.5 years (11) While sources vary, it is estimated there are 80 million cats and 70 million dogs in the US. At that rate, it would be expected that 415,000 cats and 182,000 dogs would die of kidney failure in any given 3 month period. A 30% increase caused by poisoned food would come to a total of 180,000 dogs and cats.

The "16 confirmed cases" quote, so popular with the media, has largely been openly debunked at this late date, although some sources still insist on repeating it. The current trend is to quote hundreds to several thousand. Those numbers are still orders of magnitude too low. As of this writing, the FDA has reported 18,000 cases of pet food related poisonings, with half of the reports entered into their systems resulting in death. The FDA alone has 9,000 reported pet food related deaths, and this accounts only for those willing to take time to file a complaint. The 180,000 figure is consistent with the FDA statistics if 5% of pet deaths have been reported. Considering how difficult it has been to get through to the FDA, and less than easy to find information on what number to call, 5% is probably high, and an estimate of 180,000 deaths is probably low.


ACETAMINOPHEN


According to the Merck Manual(12)an acetaminophen overdose in humans follows a 4 step pattern. The first 24 hours the symptoms are anorexia, nausea, and vomiting. 24 to 72 hours abdominal pain is added. At 72 to 96 hours liver and kidney failure may occur. Sometime after 5 days, you either get better or drop dead when your organs fail.

This article(13) also describes kidney failure in people from acetaminophen overdoses, although in language not in common usage by the layman. Renal means kidneys. Hepatic means liver. Necrosis means it kills the cells. Those three terms will help us layman through the high points in the piece. Unfortunately, the pattern on acetaminophen information seems to be the more credible the source, the more bogged down with technical jargon it becomes.

This site(14) describes some of what goes into handling and packaging materials shipped in bulk, and lists both acetaminophen and cyanuric acid as being substances they handle. I wish to stress at this point that this company, to the best of my knowledge, has absolutely no connection to the pet food recall whatsoever. I include the reference solely to illustrate that a wide variety of substances are handled at any given packaging plant.

While there are many references available which describe the symptoms and effects of a massive single dose acetaminophen poisoning incident, there does not appear to be any references on the effects of small doses received with every meal over the course of days. There also appears to be little consensus on what constitutes a lethal dose of acetaminophen in cats. One site gives half a 325 mg. tablet, or 160 mg., as being lethal, (15)while another gives a range of 50-100 mg. per kg. of body weight, which would be a dose of 200 to 400 mg. (16) The ASPCA quotes a figure of 10 mg. per kg. of body weight, which would be about 40 mg. for an average size cat, as being potentially lethal, and concludes, "Perhaps the safest way to look at acetaminophen toxicity in cats is that no dose is safe.".(17)

In addition to questions on dosage, symptoms appear to vary. For example, edema (swelling) of the face is viewed as a classic symptom of acetaminophen poisoning in cats, but in one study where 4 cats were given massive doses of the drug, one cat did not display this symptom.(18)

It is perhaps impossible to form a conclusion on exactly what symptoms would appear in connection with smaller, but repeated doses of acetaminophen in cats and dogs. More uncertainty is added if cyanuric acid affects the toxic effect of the drug. Much of the available information related to the pet food recall is consistent with acetaminophen poisoning. Dogs are less affected than cats. Lethargy, vomiting, loss of appetite and anemia are consistent with both kidney failure and acetaminophen poisoning. Elevated BUN and creatinine levels are also seen in both cases. Dark urine associated with acetaminophen poisoning would likely be missed in the liter box if it occurs at all with lower doses. Acetaminophen is known to cause kidney damage in studies of animals and humans, both from heavy usage over a period of time and from overdoses. While it may be argued the symptoms of a massive acetaminophen overdose in cats is not completely consistent with the publicized recall symptoms, the publicized recall symptoms are anecdotal at best, and the situation is not one of a single dose poisoning incident.

The two things we do know with certainty is that acetaminophen is poisonous to cats in any amount, and, that independent tests are detecting acetaminophen in pet food samples.


MISCELLANEOUS INFORMATION


Patent claims high nitrogen content substances, such as melamine, increases the toxicity of various substances.(19)

In the US, urea, the chemical melamine is made of, is fed to livestock in place of protein.(20) Urea is also approved for use in sugar free chewing gum in the US. (21) Care for a stick? Umm... perhaps not.

Some information on protein content in food and details on how protein content is calculated by measuring the nitrogen content. Approximately 6 times nitrogen equals protein.(22) For example, if a 5.5 ounce (about 150 grams) can of cat food had a guaranteed protein content of 10%, or 15 grams of protein, an analysis of the food would be done by using 6 times 2.5 grams of nitrogen to reach the 15 grams of protein. To fake the protein content with a substance such as cyanuric acid, which is about half nitrogen, would take 5 grams of cyanuric acid.

A very comprehensive and in depth write up on pet food regulation, or lack thereof, in the US.(23)

Problems in Canada with sulfa drugs and slaughter house waste rendering.(24) Some background on sulfa drugs and potential side effects such as forming crystals in the kidneys.(25)

An in depth technical study on causes of kidney failure, including information on substances which target the kidneys. (26)


FDA CORRUPTION


In 2005 FDA insiders voted themselves half a million dollars in bonuses. (27) It's also interesting to note the FDA‘s 2008 budget represents a 40% increase from 3 years ago. (28)

So, what does a cool two billion dollars buy the American tax payer? Last year 3 of those tax payers died from eating E. coli infected spinach and lettuce, and hundreds more were sickened or hospitalized. The FDA concluded the investigation without any finding of fact on the cause of the outbreak. (29) How E. coli bearing manure could end up in a crop field is evidently a mystery to the FDA.

Have you ever driven past a field and wondered why the water being sprayed on the field is brown? If you don't know the answer, a quick Internet search will provide you with one. (30) The answer to the two billion dollar question is the water is mixed with livestock manure. Does it take a rocket scientist to figure out what happened? Is it conceivable the FDA is unaware of the practice? When in doubt, follow the money. Public awareness of the fact foods typically eaten raw are grown in animal dung would be bad for business. Changing methods due to a public outcry would be expensive to the mega agricultural co ops. But, what if YOU were one of the three people who died? Paying off your heirs is orders of magnitude less expensive than changing farming methods.

The current spin is Americans are in danger from Chinese imports. Skim through last year's FDA press releases to get a better picture of the situation here in the good old USA. (31) Americans are dying every day due to the malfeasance of corporate America, all under the watchful eye of its FDA lackeys. At least in China, FDA corruption is punishable by death.

This is the environment in which the deadly pet food recall arose. On June 13, 2007, the Pittsburgh Tribune quoted FDA spokesman, Mike Herndon, as saying, "The FDA found no trace of the medication in five samples of one type of cat and two dog foods it tested in the past week. At this point, FDA sees no compelling need to analyze any more samples for acetaminophen." (32) No mention by the FDA of acetaminophen is to be found in the FDA‘s pet food recall section. (33)

ExperTox found acetaminophen in 5 of between 100 and 150 pet food samples it tested. (34) Three of those reports are posted on the lab section of this site. I am in contact with a forth person whose samples tested positive for acetaminophen. The fifth positive sample has been reported to have been submitted by an unnamed pet food company. Subsequent to the above FDA official position on acetaminophen in pet food, I and three of the others with acetaminophen positive samples were contacted by ExperTox for permission to release the samples to the FDA, at the FDA's request. It is assumed the unnamed pet food company was contacted at the same time. In other words, the 5 mystery samples the FDA claims to have tested have no connection whatsoever to the 5 acetaminophen positive samples tested by ExperTox.

In sum, the FDA decision to stand down on the acetaminophen findings is motivated by some factor other than finding acetaminophen.

When in doubt, follow the money.

And, by the way, did you know cyanuric acid is an FDA approved feed additive? (35)

In the more things change, the more they stay the same category, the pet food recall is not the first time the FDA and coroprate interests have attacked ExperTox. ExperTox found toxic levels of platinum, in women suffering symptoms of platinum toxicity, who had received silicon breast implants known to contain platinum. What's to figure out here?

The FDA's response: "Lykissa's (head of ExperTox) yet-to-be-submitted findings are too limited to prove that the platinum came from the implants."(36) What do you suppose the FDA position was on that one? That as soon as hundreds of thousands of women get an implant, they hit the town snorting platinum, then sue the implant makers just to make them look bad and to raise cash to support their platinum habits?

Darling International recalled 1.4 million pounds of meat and bone meal adulterated with melamine at the end of April 2007. As most of us will remember, this was at the height of the melamine from China hype. So, why did the FDA wait over 3 months to add the recall to its site? Also, if melamine in pet food is a Class I recall, why is melamine in the meat and bone meal used for pet food a Class III recall? Inquiring minds would like to know. (37)

Added August 13, 2007:

Over 100 varities of Nutro Products pet food subject to a Refusal Action by the FDA. (38) According to information on the FDA site, the reason is the food was either adulterated with unapproved substances, contained known poisons, or both. There appears to be at least two substances involved. It is unclear if Nutro was trying to import their toxic waste, or to export it. According to Nutro, none of their products have ever tested positive for melamine. (39) The obvious question is, what substances are involved? The FDA continues to keep a tight lid on anything that doesn't support the melamine from China theory. Any bets that contrary to the lies the FDA feeds to the media, the FDA has in fact duplicated the ExperTox results as shown in the lab section of the site?

One unsafe ingredient, one poisonous ingredient, and no melamine.

NOTE: Nutro has changed their tune on link (39) above. Their previous claim that none of their products have ever tested positive for melamine has mysteriously vanished. Would you buy a used car from these people?


ACETAMINOPHEN HYPOTHESIS


Keep in mind what follows in this section is in the nature of speculation. In the sciences, a theory is a best effort to find an explanation consistent with a set of observed facts. In police work, the first question asked is "Who benefits from this?". Obviously, the most common motive for criminal activities is profit. Let's start with what we know:

1. Protein is a valuable commodity. The more there is of it in a product, the more it is worth.

2. The most commonly used method for measuring protein content, is rather than measuring protein directly, nitrogen is measured, then a formula of 6.25 times nitrogen is used to arrive at the protein content.

3. A number of nitrogen rich substances may be used to boost apparent protein content, both legally in ruminant (cattle, etc.) feed, and illegally in other products. Cyanuric acid and urea are both legal nitrogen sources approved for use in ruminent feed. Melamine isn't approved for that use in the US, but is commonly used for that purpose in other countries. None of them are approved for use in pet or human food. The substances are virtually harmless, but where ruminants are able to use raw nitrogen as food, people and pets are not.

4. For a number of reasons, meat and bone meal products produced by renderers are of a lower quality and less valuable if the protein content is less than 50%. A few percentage points makes a big difference. For example, meat and bone meat that tests out at 48% is a much lower grade than meat and bone meal that tests out at 51% protein.

5. The acetaminophen we see pressed into neat tablets is shipped in bulk in powdered form. It typically is shipped by the boxcar load to packaging plants where it is bagged into 50 pound gunny sacks for further distribution.

6. Cyanuric acid is handled in the same manner as acetaminophen in number 5.

7. In the lab tests conducted by ExperTox on pet food, samples tested positive for acetaminophen, cyanuric acid, or both. No melamine was found in those samples and grain products were not listed as ingredients.

8. It is unlikely there would be any profit motive for renderers or pet food companies to knowingly add acetaminophen to pet food, or rendered products.

9. Acetaminophen was found in pet food samples at levels as high as 2 parts per thousand, or .002%.

10. That lethal levels of acetaminophen were found in pet food indicates it was added in pure, or nearly pure form at some stage of manufacture.

11. Meat and bone meal products are cheap enough that a profit motive at the point of pet food manufacture, to spike nitrogen content, to fake protein, is fairly low.

12. Melamine is the marker for contaminated Chinese gluten products, so contaminated pet food without melamine was contaminated from a source other than Chinese gluten.

13. Darling International was caught selling melamine spiked meat and bone meal, which suggests a practice of faking protein at the point of rendering, which is consistent with the profit motive listed in number 4.

The best working theory I've been able to come up with that explains and encompases all of the above is:

A large quantity of acetaminophen was mislabeled as cyanuric acid. This could be explained as easily as a less than conscientious employee grabbing the wrong labels or bags at a packaging plant, or even a bulk shipment being miss marked or miss routed. One or more rendering companies were illegally spiking low grade meat and bone meal with cyanuric acid to pass it off as the good stuff for extra profit. They didn't know the cyanuric acid was in fact acetaminophen, likely to kill hundreds of thousands of pets, but it never would have happened if they weren't engaged in criminal activities in the first place.

Is the above a good guess? Let's test the theory from another angle. Pet food is typically 10% protein. With meat and bone meal running around half protein, it would take 20% meat and bone meal content to make up the required 10%.

Adding 1% cyanuric acid, which is about half nitrogen, to meat and bone meal, would boost the apparent protein content by about 3%. That would be perfect to bump a poor grade of 48% meat and bone meal past the magic 50% mark.

If the 1% cyanuric acid was actually acetaminophen, and the pet food companies use 20% meat and bone meal in their products, you would have 20% of 1%, or .002%, or 2 parts per thousand. That's an across the board match for number 9 above.


DARLING INTERNATIONAL RECALL OF MEAT AND BONEMEAL PRODUCT


Some interesting quotes from documents obtained under the Freedom of Information Act related to the Darling International recall of 1.4 million pounds of dry rendered tankage:

*** "The product contains melamine. Test results in the FDA samples found amounts ranging between 19 ppm - 135 ppm Melamine."

*** "Rendering material obtained from a pet food manufacturer was used in recalled product. The rendered material had been mixed with wheat gluten that has been found to contain melamine."

*** "No product was recovered. It had already been used in the manufacture of other products."

*** "For use in animal feed."

*** "KAN-DO [FDA labs] does not plan any further follow-up with the manufacturer or recalling firm at this time unless new information is received that would make follow-up necessary."

It's worth remembering that just because a product is recalled, it is not necessarily recovered. What exactly does go into rendered products? One would think it would be all animal protein, but if garbage from pet food companies is recycled, it apparently contains just about anything one might find at the local landfill - vegetable protein as well as animal protein. The quantities of melamine in the product are fairly small, but this is the same FDA that told us no amount of melamine is acceptable, as it is not approved for use in US animal feed products.

Scanned images containing the above quotes are on Page 1, Page 2, Page 3, and Page 4.