A synthetic analog, MSBC, is causing a stir among several state feed control officials.
The Association of American Feed Control Officials (AAFCO) Cat Food Nutrient Profiles demand a supply of Vitamin K be contained in almost any cat food that has more than 25 percent fish and is meant to be balanced and complete for all life stages under the Profiles. Additionally, there is a range of nutritional conditions where the addition of vitamin K from different cat foods, pet foods, and specialty pet foods will be wise. This hasn’t been a problem for decades. However, that scenario has just changed.
Recent issues with MSBC
The artificial analogs menadione and menadione sodium bisulfite complex (MSBC) happen to be tacitly permitted as vitamin K active compounds in pet foods for several decades. As I know it, MSBC is stable, therefore preferred of both. Regardless, they’re equally prior sanctioned from the U.S. Food and Drug Administration (FDA), albeit mostly just to be used in poultry feeds.
However, the FDA notes on its site these substances are frequently utilized in feeds for different species, such as pet foods. Therefore, despite needing proper acceptance, this regard to their use for meals other than for poultry without explicit apology has enabled regulators to exercise enforcement discretion and endure the unfettered use of MSBC in pet foods.
Lately, however, a minimum of one state feed control official has taken actions against any pet merchandise comprising MSBC. This is because the record of MSBC from the AAFCO Official Publication refers to poultry. Since the nation exerts its animal feed regulations, any additional usage is strictly prohibited. Urging of this country to exercise enforcement discretion in this example, or other rapid regulatory fixes, for example, change to the AAFCO list, seem to be in a stalemate.
Solving the Issue
What is asked to proceed, it appears, is for an interested party to submit a Generally Recognized As Safe (GRAS) Notification for MSBC using FDA to provide to this broader use. This process can take substantial time (decades ) and tools. Additionally, fulfilling the GRAS standards would require adequate documentation from the printed literature to set up security for this new usage.
Honestly, that might be troublesome for MSBC. Except for many concerns expressed on customer advocate sites as to its supposed adverse impacts on pets, MSBC continues to be quite widely utilized in all kinds of animal feeds for decades with no real security problems when used in keeping with the right feeding procedures. Lacking a fair incentive to run formal security trials, very little could be anticipated to be found from the science fiction on the topic.
What about other sources of Vitamin K? There are a couple of additional menadione-based ingredients readily available. Still, these are regulated as food additives by the FDA, making the practice of enforcement discretion when it comes to using in pet foods much harder. Hypothetically, natural sources of vitamin K like spinach or spinach could be inserted to satisfy regulatory or nutrient requirements. But, ensuring sufficient addition rates to meet vitamin K demands faithfully could probably prove difficult. Also, in consideration of these issues with processing and formulation of these kinds of ingredients, even with concern over possible adverse effects like decrease in palatability and addition of possibly dangerous substances such as oxalates, the feasibility of the strategy is suspicious at best.
Another possible option stems from a review paper published in 2018 at the Journal of the American Veterinary Medical Association that concludes that phylloquinone (vitamin K1) is GRAS for use in cat and dog foods. Coincidentally, I’m one of those writers, although the newspaper was printed well before this current matter became a problem. Phylloquinone is made commercially by artificial means but is identical to naturally occurring vitamin K from leafy green veggies.
This is hugely different by menadione, which considers its regular identification as vitamin K3″ isn’t actually vitamin K per se but instead an analog which needs an additional transformation from the entire body to be usable. Menadione-based chemicals aren’t allowed in foods for human consumption. Phylloquinone, on the other hand, isn’t only permitted but is needed for use in infant formulas in the USA. FDA believes this usage of phylloquinone to be safe and convenient. To me personally, the same status ought to apply to pet foods.
In any case, a speedy resolution to this issue is required. In the meantime, some fish-based cat foods would have to substantiate nutritional adequacy through a suitable AAFCO feeding trial, or all promises to be balanced and complete would have to be eliminated. However, this treatment doesn’t address most of the other possible nutritional issues (such as potential bleeding disorders) originating from ingestion of pet foods lacking a suitable supply of vitamin K if required.
Briefly: Top Five takeaways
- Vitamin K was contained in pet food formulations without any problems for a while, but lately, the situation has shifted.
- A minimum of one state feed control has taken actions against any pet merchandise comprising MSBC, let as a”vitamin K lively substance” for several decades.
- To move ahead, an interested party would have to submit a GRAS Notification for MSBC using the FDA to provide formally because of the use in pet foods (instead of merely in poultry feed).
- Vitamin K is also a significant component, requiring a speedy resolution to this issue.
- To locate the paper seeing phylloquinone in pet foods: Delaney SJ, Dzanis DA. Security of vitamin K1 and its use in pet foods. JAVMA 252(5):537-542, 2018.