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THE "PET FOOD REGULATION PROTECTS THE PUBLIC AND GUARANTEES HEALTH" MYTHFostering, condoning, promoting and regulating the "100% complete" claim that has killed and maimed untold thousands of pets (see Proofs, pages 74-85), and visits upon their owners emotional anguish and medical costs, is not public protection. It is more like tyranny, or state sanctioned mind control. (Apologies to all the levelheaded regulators who just try to reasonably do their job and do not pretend that present pet food regulation of "100% completeness" is important.)
Strong words? Perhaps. Hyperbole? No. For the reasons set forth in this book, and the documented clinical evidence, health and "100% complete" exclusive feeding are clearly antithetical.
Should we expect regulators, nutritionists and the pet food industry to change any time soon in the face of contrary evidence? Don't count on it. The money is too wonderful, egos and security too important. The burden is on you, Joe Public, to sharpen up, see the obvious, take control and not take it anymore.
This conspiracy by the powerful, although perhaps unintentional, is no big revelation. Life teaches us that we are our own best caretaker. After all, aren't you the most important person in your life? Don't you think experts and regulators have their own interests primarily at heart too? Should you really then trust your, or your pet's health to another?
No, neither trust nor money is the answer to health. With that said, let me get down from my pulpit to have a little fun. Indeed, if the consequences of the "100% complete" claim and its regulation were not so serious, this could all be a real belly slapper. The following are examples of how we at Wysong have been "regulated" through the years in response to efforts to improve nutritional quality. No exaggerations here. These are real live case histories from our files chronicling some of the unreasoning discriminatory efforts of some regulators.
Several agencies regulate pet foods either directly or indirectly. There's the USDA (United States Department of Agriculture), FDA (Food and Drug Administration), AAFCO (Association of American Feed Control Officials Incorporated), and each state has its own feed regulatory agency. All of this to control what is fed to your cat or dog! A little overkill (pardon the pun) wouldn't you say? I mean we're not talking powerful pharmaceuticals, addicting drugs or hazardous chemicals. Just food. You'd wonder what it is all these people do to fill their time. Well, I'll show you.
"ORGANIC"We developed an organic, non-GMO (genetically modified organisms) food and were going to name the product "Organic."
After submitting labels for approval, regulators responded that we could not name it "Organic."
Further, we could not call the ingredients organic (even though they were) without impossible red tape, such as providing third party confirmations, affidavits, and proofs like needed in some kind of criminal case. We were trying to do something good and they treated us like we were planning a mass murder. Now if we wanted to use AAFCO approved, dehydrated refuse and scrap plastic (see pages 7-8) and call it "100% Complete," no problem.
Do you feel safer now that our killer "Organic" food is not on the market?
"FREE RANGE"When we found sources of free-range meats and wanted to describe on labels that this was more humane, regulators said no. Further, to even say "free range" on the label would require the same criminal-type onerous red tape provings as with "organic."
They disagreed that animals out in fields, on real ground, breathing fresh air and getting genuine sun were being treated any more kindly than those in close quartered feedlots standing in manure up to their knees, or in wire cages, pens or crates crammed inside buildings.
By such reasoning, regulators could argue that imprisonment for humans is not even punishment.
"OPTIMAL NUTRITION"Regulators objected to our use of the phrase "Optimal Nutrition." They argued that if we used levels of nutrients above their "approved" levels, that would make our ingredients unapproved food additives. In other words, if we were to discover that regulatory minimums were insufficient to prevent diseases such as arthritis, cancer, dental disease, heart and organ disease, and the like (which we, and scientists worldwide, have), we could not move our formulas to match this new knowledge. No, regulators would want us to stay at their minimums, condemning pets to preventable disease. Public protection?
"GENETICALLY MATCHED"Consistent with the theme throughout this book that creatures require natural food to which their ancestors were adapted, we attempted to describe this on our labels by using the term "genetically matched." Regulators prohibited this unless we could provide proof by way of "scientific peer reviewed literature."
Problem is, there are some things so obvious, scientists would never spend the time or money to prove or publish them. For example, you can't find "scientific peer reviewed literature" proving the sun comes up in the morning, wind contains air, heavy things fall to the Earth, plants need sun or creatures need the natural food that genetically matches them. But we were supposed to hunt through libraries around the world for "peer reviewed" articles proving dogs and cats require natural meat and vegetable products, not things which they are not genetically matched to eat, like ground Formica table tops, shredded carpet, crushed tile flooring, dyes, herbicides, pesticides or used motor oil.
"FRESH MEAT" & "WHOLE INGREDIENTS"The criminal-type provings (affidavits, third-party documentation) were also required for us to say we used fresh meats (rather than just prerendered dried meat ingredients), and whole ingredients (rather than food fractions such as brewer's rice, white flour, soy mill run, etc.). As you will see later in this section, grocery shelves are lined with approved pet products with claims which were obviously never so proven. Short of practically inviting the AAFCO committee and regulators from every state agency into our plant (we'd probably be responsible for five-star accommodations, firstclass tickets and gourmet meals – which you can bet would have "fresh" and "whole" entrees) – to watch our every move and verify every ingredient, we were being prevented from truthfully stating what was in our products. Now if we were saying something like our food "contains strychnine at healthy levels," I could see regulatory intervention. But how, even if we were wrong, could "Fresh" or "Whole" – even in a regulator's wildest nightmare – create harm!?
"ALIVE"Living creatures require living foods. One way we accomplish this in our dried pet foods is to enrobe the product after processing with active enzymes and living probiotic (yogurt-type) cultures. To describe this we wanted to state that these cultures were "alive." But no, since the public would be at such great risk (?), regulators wanted us to do the "scientific peer reviewed" do-si-do again.
Provide scientific literature proving bacteria are alive? How are you going to do that?
"SYNERGISTIC COMPLEXITY OF LIFE ITSELF"Life is not a simple addition of a few elements. It is complex and interdependent beyond our ability to even comprehend. That's what makes life different from nonlife. By using whole, fresh, natural food ingredients, we recognize this complexity and its value to health. When we tried to describe this on our labels by using the phrase that healthful foods should contain the "synergistic complexity of life itself," regulators hit us with that "peer reviewed" proof thing again.
Now I defy you to find a scientific article that attempts to prove that life is synergistic and complex and not just a simple pile of carbon, nitrogen, hydrogen, oxygen, sulfur and calcium. But we were supposed to.
Do you think maybe they want us to spend our time roaming libraries rather than make products that challenge their tidy little, "add up chemicals and claim 100% completeness," fairy tale?
"PHYTONUTRIENTS"Research has proven that certain plants and plant components can prevent and reverse disease.* To incorporate these elements fresh and unaltered into our foods, our products are enrobed with them after processing. But when we attempted to describe this on labels, regulators asked for "proofs." When proofs were supplied, they either did not respond or said the proofs were insufficient. You see, since regulators don't understand how fresh ingredients can be in a processed food, or that something other than a pharmaceutical can impact disease, they attempt to prohibit innovation and possible salutary effects. If we wanted to dye our foods iridescent purple, put jellybeans or raffle tickets in the package, that would be fine.
* Wysong Companion Animal Health Letter, "Herbs that Heal," 1996(12). Wysong Health Letter, "An Herbal Medicine Chest," 1995; 9(9). ,em>Nutr Rev, 1999; 57(9 Pt 2):S3-6. Mayo Clin Health Lett. 1998; 16(8):7. Rheumatology (Oxford), 2001; 40(12):1388-93. Can J Cardiol, 2001; 17(6):715-21.
"UNIQUE"When we stated our products were "unique," regulators said that was a no-no. They argued that because our label listed ingredients like in other pet foods, there was no uniqueness. But get this. Why do our labels appear this way? Because regulators force us to name our ingredients the same even though they are not (see Chapter 7, pages 25-26). Aside from this, our formulations are totally unique (regulators have no idea what they are since they cannot force manufacturers to reveal this proprietary information), and our nutrient sparing packaging and processing are unique.
Go to the grocery some time and see whether other approved pet food products get to say things like "special," "best," "premium," "superior," or the like, all terms synonymous with unique.
"FORBIDDEN INGREDIENTS"When we tried to incorporate some special nutrient dense ingredients, regulators said they were unapproved.
POLLEN – even though it is impossible to eat plant foods without eating pollen. Additionally, pollen can be found in grocery stores and has been consumed by people and animals for eons. It is, in effect, a plant kingdom egg and as such contains almost every nutrient known.1
SPIRULINA – available in stores and even consumed as a staple by some cultures. It too contains essentially every nutrient known. Regulators evidently feel vitamins and minerals should come from "approved" chemical factories rather than from real natural foods.2
1. Wysong Health Letter, "Natural Foods Can Heal," 1992; 6(5). J Altern Complement Med, 2000; 6(5):383-9. Br J Sports Med, 1982; 16(3):142-5. Br J Urol, 1989; 64:496-499. Hua Xi Yi Ke Da Xue Xue Bao, 1994; 25(4):434-7.
2. J AOAC Int, 2001; 84(6):1708-14. Crit Rev Food Sci Nutr, 1991; 30(6):555-73. J Nutr Sci Vitaminol, 1998; 44(6):841-51
TRACE MINERAL SEA SALT – processed salt (approved) with its important trace minerals removed, and additives combined, is a totally different creature than real trace mineral rich sea salt which regulators would not permit us to describe on labels.1
GEOLOGICALLY COMPOSTED SEA VEGETATION, SEA CUCUMBER, CHONDROITIN, COLLAGEN, PSYLLIUM SEED — all prohibited even though they have proven health benefits, are consumed with regulatory approval by humans and are natural foods.2
VITAMIN C – an innocuous vitamin proven to have great benefit in many species is prohibited because regulators who are not au courant think it unnecessary.3
"FORBIDDEN NAMES""PREMIE" – We designed this intermittent special diet to emphasize certain nutrients for the very young. Regulators said this was like a medical claim. In other words, they would not want the public to be "misled" into thinking that if they used Wysong "Premie" it would be like putting your kitten or puppy into an intensive care pediatric unit, or that any infant disease would be automatically cured. Thank goodness they saved you from having us pull that one over on you!
1. Wysong RL, “Rationale for Whole Salt™,” 2002. Price-Pottenger Nutrition
Foundation Health Journal, 1999; 21(2):574. J Amer Coll Nutr, 1987; 6(3):261-
"STRESS/PERFORMANCE" – This special intermittent diet was high in protein and energy for animals with increased needs. Regulations said we couldn't use the name "Stress/Performance" because it implied a medical claim. You know, like if your cat or dog were exposed to stress, it would not experience it if you fed this food. Or if you had a Greyhound and fed the food it would automatically win all races. Right. That's just what we meant and what the public would think.
"GERIATRx" – This intermittent diet was designed to emphasize special nutrients for the elderly. See the Rx symbol in "GeriatRx"? Regulators said no way. That would tell the public that this food was a drug. Is that what you would think, that if you had an older animal with cancer, obesity, arthritis, heart disease, tooth loss, blindness or the like, all you would need to do is feed a food called "GeriatRx"? Seems regulators don't give the public much credit for intelligence. Or do they? See with what names they expect you to use discernment (see pages 67-72).
"SYNTAX AND OTHER FELONIES" PUTTING YOUR PET IN PERILIf you thought your old English teacher was tough, you should try writing a pet food label to be graded by regulators. Only here you either pass or fail. If you don't pass, your products can be banned and confiscated. For a small producer it could mean bankruptcy.
Here are examples of some things, which if not "corrected," could have sealed our fate long ago.
It's like arresting jaywalkers while permitting murder and rape in the alley.
MORE PICAYUNE REGULATORY NONSENSEHere's more.
* Wysong RL, "Rationale for Contifin™, Glucosamine Complex™ & Arthegic™," 2002. Physiol Rev, 1988; 68:858-910. Ann Rev Biochem, 1986; 55:539. Varma R, Glycosaminoglycans and Proteoglycans in Physiological and Pathological Processes of Body Systems, 1982. J Am Med Assoc, 2000; 283(11):1469-75. Br J Community Nurs, 2002; 7(3):148-52. Curr Opin Rheumatol, 2000; 12(5):450-5. Med Hypotheses, 1997; 48(5):437-41. Clouatre D, Glucosamine Sulfate and Chondroitin Sulfate, 1999.
OTHER PET FOOD LABELSThis is a random sampling from pet food labels and advertisements approved through the years by state regulatory agencies. We do not necessarily disagree with the following producers' right to say what they say – as long as Wysong can say the things we wish to say. If Wysong comes under painstaking scrutiny, so should everyone else.
This critique is not meant to criticize the producers cited (they are merely taking liberty with words for marketing purposes), but rather to demonstrate a regulatory double standard. So permit me here to be the regulatory devil's advocate. I'll censor these foods as ours have been, taking every word literally and permitting no poetic or marketing license.
BONZ™♦ sta – I can't say "Bonz" without it sounding like "bones." That's no accident. Yet when you open the box, you see no real bones. They claim: "Is good for a dog's teeth." What is "good for"? Proven? Peer reviewed? Where are the regulators?
MILK-BONES FLAVOR SNACKS™♦ – They are neither bones nor milk, but regulators don't seem to care here. "Your dog's 6 favorite flavors" – how do they know? Don't dogs have individual tastes? "A flavor no dog can resist" – is this every dog in the universe? Palatability is extremely individual. To say "no dog can resist" is without "peer reviewed" proof. "A hearty snap of cheese flavor that will tickle your dog's taste buds" – how exactly do a dog's taste buds become tickled? "Your dog will bark with delight" – is this a guarantee? Will the neighbors sue? Where are the regulators?
MILK-BONES™♦ – "Cleans teeth" – what does "clean" mean? Peer reviewed proof? "Freshens Breath Naturally" and "Nothing freshens your dog's breath better than Milk-Bone Dog Biscuits." Isn't a real bone natural, not a "Milk-Bone"? Veterinary dentists would argue that a complete tartar scraping and dentistry, followed by rinsing of the mouth, would certainly freshen most dogs' breath better than Milk-Bones. This second statement, in fact, may lead consumers to believe that dentistry is not necessary for dogs. A medical claim? Where are the regulators?
MILK-BONE DOG TREATS™♦ – They are shaped like bone segments with a reddish center, and claim "with Real Bone Marrow." At a glance, we discover that it is the ingredient "meat and bone meal" to which they must be referring as "real bone marrow." In fact, meat and bone meal contains only insignificant fractions (if any) of marrow. Naturally it has some marrow in it, but the red dyed stuff in the middle is not just marrow. Where are the regulators?
SNAUSAGES™♦ – "The Ideal Snack" – unless the definition of "ideal" has changed, this cannot be true, since they contain artificial/chemical and by-product ingredients. Can it be proven that they are "ideal"? They can say "ideal" (unproven) but we can't say "unique" (proven)? Where are the regulators?
JERKY TREATS™♦ – Proclaims "Contains real meat" as if the consumer is to believe that is unusual, as opposed to the "fake" meat in all other treats? Where are the regulators?
TAST-TEE CHUNKS™♦ – "They will have any Rover rolling over." Really? Probably pretty safe since nobody names their pet "Rover" anyway. Peer reviewed proof? Where are the regulators?
JERKY BITS™♦ – "You and your dog will flip for ALPO Jerky BitsTM." Not only your dog flips, but you do too. Is the flip a one-and-ahalf, or a backward with a full twist? What if a human were to break his or her neck while doing one of these flips? Who pays for damages? Pity the insurance carrier. Where are the regulators?
CHEW-EEZ™ – "Chew-eezTM gets your dog's teeth cleaner than Milk-Bone." Well, now hold everything. If this is true, somebody lied to us when they said nothing was better than Milk-Bones for my dog's teeth! I'm confused. How can both be approved and licensed? Where are the regulators?
TOP CHOICE™♦ – Here the front panel claims "Better Than Hamburger," and "Chopped Beef Burger for Dogs." Better tasting, better nutrition, better smelling? Exactly how better? The second claim "Chopped Beef Burger for Dogs" should read "Chopped Soybean Meal and High Fructose Corn Syrup Burger for Dogs" since these are the first two ingredients. Where are the regulators?
PUPPY CHOICE™♦ – "Easy for puppies to digest." Peer reviewed? Proof? Because it is soft and mushy (easy to chew), does that make it easily digestible? Where are the regulators?
GAINESBURGERS™♦ – "The canned dog food without the can." If there is not a can, it is not a canned food. Where are the regulators?
CYCLE 1™♦ – "Because of its special formulation..." – special? How? What is special? Special for the consumer and pet, or special for the producer? They can say "special," but Wysong can't say "unique." Where are the regulators?
GRAVY TRAIN™♦ – Another one claiming "Is ideal...." What is ideal? They get to say "ideal," but we can't say "unique"? C'mon. Peer reviewed proof? Where are the regulators?
KEN-L RATION CANNED FOOD™♦ – This packaging tells us it is "America's first dog food," and is "a trademark of quality and commitment." First? Does being first (if this is really so) automatically imply merit? Was the "first" food good or bad? Are they still using this "first" formula from so many years ago? Where are the regulators?
TENDER CHOPS™ – "Each succulent little chop tastes and looks like the center cut of the savory real meat chops dogs love." Will Fido love it because it looks like a meat chop? If I tasted it, would I agree that this grain-based product tastes like a "real meat chop"? Where are the regulators?
O.N.E.™♦ – "Highly nourishing." What does "highly" mean? Compared to what? "Leading pet nutrition center in the world" – well, I'm sure they think so. "Visible results in just 10 days." This daring statement sounds like a health promise. Peer reviewed proof? Where are the regulators?
CYCLE 3™♦ – "Fitness Food," which implies that fitness will surely result and sounds very much like a health claim. They can say "fitness" and we can't say "performance"? They also state "Nothing but good food," and yet the number one ingredient is wheat middlings. Other ingredients include rice hulls and BHA (butylated hydroxy anisol). Where are the regulators?
COME 'N GET IT™♦ – This food is "Bursting With Taste." How does taste burst? I'm not going to taste it to see, and I can't get my dog to answer me when I ask him. They also claim to be the "Only dry dog food which offers 4 different flavors," but Flavor Snacks™ had my "dog's 6 favorite flavors" in the box! Regulators can't count apparently. Where are they?
LUCKY DOG™♦ – Well, the "leading pet nutrition center in the world" announced, "You could find $100 inside this bag." What does that have to do with nutrition? Where are the regulators?
CHEWY MORSELS™♦ – "Extra nutrition." What is "extra"? They can say "extra" but we can't say "optimal"? Nutrition that is extra is excreted or deposited like fat. If extra is important, do all their other products have extra? They continue, "No other puppy or adult food does more for your puppy," but their original Puppy Chow™ is still being sold. How can they offer it if it is inferior? Chewy Morsels is also proclaimed to "produce small, firm stools." Is this proven by peer review? Where are the regulators?
TENDER MEALS™♦ – "The only soft-moist cat food good enough for Morris." Isn't Morris on the payroll? Wouldn't his opinion be biased? Are all other soft-moist foods in the universe not "good enough"? Where are the regulators?
ALLEY CAT™♦ – "Good for cat's teeth and gums" and "Easy to digest." Did regulators demand peer reviewed scientific proof? I doubt it. Where are the regulators?
CHEF'S BLEND™♦ – This cat food has "twice the meat taste." Twice the meat taste of what? Corn? Clay? Where are the regulators?
THRIVE™♦ – "Thrive is the only cat food with chicken, fish, meat, milk, cheese, and egg protein." (Emphasis theirs.) Did regulators check all other cat foods? They missed at least one we know of (ours), which contains all those proteins plus more. Where are the regulators?
JOY PUPPY FOOD™♦ – "There's no other puppy food as digestible as JOY Puppy Food." Perhaps Gaines, with their digestible Puppy Choice, would argue. Anyone could argue for that matter. So, can Joy prove their claim? Have they provided peer reviewed proof? Where are the regulators?
FIT & TRIM™♦ – "For a healthy aging process." Is it to be inferred that the aging process of my dog will be guaranteed healthy? He won't get ill? Not at all? Less? Will he really live a longer and healthier life? Are these foods FDA approved? They can make this health claim but we can't use the name GeriatRx ? Where are the regulators?
r/d™♦ – "With 40% fewer calories than grocery store brands" – which brands? "Three times more fiber" – than what? Water? They don't say. They claim an "optimum supply of vitamins, minerals, and protein" – what does this mean? How can they say optimum but we can't? Finally, their trademarked byline in this particular ad: "Nutrition as an aid in the management of disease™" sounds very much like a health claim. Is this a drug? Which diseases? Where are the peer reviewed proofs? Where are the regulators?
FELINE GROWTH™♦ & FELINE MAINTENANCE™♦ – In an advertisement of bold health claims we find: "...for the prevention of Feline Urologic Syndrome...optimum growth...proven to help kittens mature into strong, healthy cats...ideal food...optimum balance...extremely effective...This is the preventive health care difference between Science Diet™ cat foods and competing brands...only the highest quality ingredients are used to assure palatability and provide the optimum nutritional balance..." "Optimum...health care...ideal...effective...highest quality" – those are words regulators would lynch us for. Where are they?
CHUNKS™♦ – "All meat for protein." Meat is muscle, yet these products contain poultry by-products with viscera, heads, and feet (according to AAFCO), and corn, which also contains protein and is not a meat. "Never soy products" is claimed, implying that there is something wrong with soy products – but what is wrong and what is the proof? Where are the regulators?
BENCH & FIELD™♦ – Regarding pictures of their food not swelling when in water as compared to extruded foods swelling; is the implication that all dogs, which eat extruded foods (probably about 50 million in the U.S. alone), will get bloat if they don't eat Bench and Field? Do any dogs that eat extruded foods get bloat because the food swells in water? Peer reviewed proof? Where are the regulators? Again, none of the above is meant to find fault with other manufacturers. They should be given such marketing license. The public is intelligent enough to separate fanfare from reality. This does, however, demonstrate a double standard when, instead of being cute or offering raffle tickets in our packages, we attempt to make serious health innovations.
What has brought pet food regulation to this sad state? It began when the public, with their quest for ease, and fixes for their consumer addiction, wanted a "100% complete" meal in a bowl. Actually, it may have begun when manufacturers discovered how to create food products with shelf-life and saw dollar signs. I'm not sure which was first, but the end result, people feeding these foods of convenience only, begged for regulation. There's too much danger and so regulators emerged to assure "100% complete" foods were just that. Problem is, they never stopped to examine the underlying premise. They simply assumed nutrition was at a scientific end point (absurd, of course) and went from there.
Similarly, if you assume yellow, white, brown, or black skin signifies inferiority, discrimination is fine and proper. If you assume disease is just one of those things that happens to you, then you don't practice prevention. If profit is the only objective of industry, then spending money on antipollution measures is a waste. The validity of starting premises must always be examined first, and closely, before public policy is enacted. That's how freedom is kept and tyranny held at bay. Problem is, the "100% complete" premise has not been critically examined by regulators (or for that matter, by most nutritionists, veterinarians, or the public).
So what should regulators do? First, forbid the spurious, unproven and unprovable claim of "100% completeness." Then, permit all manufacturers to say what they want about their products, as long as it is truthful and cannot cause harm. Leave discernment to buyers.
♦ Bonz™, ALPO Jerky Bits ™, Chew-Eez™, Come 'N Get It™, Chef's Blend™, O.N.E.™, Lucky Dog™, Chewy Morsels™, Alley Cat™, Thrive™ and Fit & Trim™ are trademarks of Nestlé Purina PetCare; Milk-Bones Flavor Snacks™, Milk-Bones™ and Milk-Bone Dog Treats™ are trademarks of Kraft Foods Inc.; Snausages™, Jerky Treats™ and Tender Meals™ are trademarks of H.J. Heinz Company; Tast-Tee Chunks™, Top Choice™, Puppy Choice™, Gainsburgers™, Cycle 1™, Gravy Train™ and Cycle 3™ are trademarks of Gaines Pet Foods; JOY Puppy Food™ is a trademark of JOY Dog Food; Ken- L Ration Canned Food™ and Tender Chops™ are trademarks of Ken-L Ration; r/d™, Feline Growth™ and Feline Maintenance™ are trademarks of Hill's Pet Nutrition, Inc.; Chunks™ is a trademark of The Iams Company; Bench & Field™ is a trademark of Bench & Field Pet Foods, LLC.
In the alternative, prohibit all claims just like the World Health Organization (WHO) did with baby formulas. The analogy is practically perfect. Breast milk is what babies genetically expect. It is raw, natural and truly complete (provided mom is not eating too crazy). But no, nutritionists know better. A baby's tummy would never know the difference between a chemist's lab or food processor's concoction and the real thing. So along with the "Coca Cola-nization" of the third world, commerce further "solved" their starvation with synthetic formula.* The results were so disasterous the WHO interceded.
Singularly fed processed pet foods are just as synthetic and just as disasterous.
So I will follow the WHO/UNICEF code on the marketing of breast milk substitutes with an analagous pet food code that would truly make a difference in pet health.