Page 178 - Raw Diet References Book 2019

Proposed Revisions Edited per Comments for 2014 Official Publication 11

FEDIAF Guidelines for same life stages. The 2007 CNES decreased the
recommendation for adult maintenance from 80 to 40 mg/kg DM based on
considerations that the RA of the 2006 NRC was 30 mg/kg DM and the FEDIAF
Guidelines concentration was 36 mg/kg DM. The 2007 CNES deleted the maximum
concentration for iron based on one scientific and one practical regulatory
consideration. First, the 2006 NRC indicated that appropriate data for setting a SUL
for iron in dog foods are not available. The previous maximum concentration was
stated to be based on tolerance data in swine. The 2005 Mineral Tolerance of Animals
indicated that the listed tolerance of 3000 mg/kg DM for swine needed to be confirmed
by long-term studies and all other tolerances for iron listed in that publication are 6
times less than 3000 mg/kg DM. Second, the implied safety of a maximum
concentration presumes some amount of apparent digestibility and, as noted above, the
apparent digestibility of iron in any given diet or combination of ingredients can vary
from less than 10% to near 100%. Some sources of iron are considered unavailable
and used for their technical effects (i.e., color) on the product and not for their nutrient
contribution of iron to the animal. Such unavailable sources will still contribute iron to
an analytical result for determining product content, and thus a maximum
concentration set for available sources of iron might prohibit use of unavailable sources
for coloring, whereas a maximum concentration set for unavailable colorants might
permit use of unsafe amounts of available sources on the basis of analytical content.
Thus, the 2007 CNES elected to delete the previous maximum of 3000 mg/kg DM and
not list any other value as a maximum for iron. Manufacturers should note that iron is
toxic at some amount greater than the recommended quantities, but the exact amount is
unknown for dogs.
COPPER
The minimum concentration for copper in the Adult Maintenance Nutrient Profile
was not changed from the previous amount of 7.3 mg/kg DM, the concentration being
consistent with that of the FEDIAF Guidelines and slightly more than the 2006 NRC
RA of 6.0 mg/kg. The 2007 CNES increased the minimum recommended
concentration in the Growth and Reproduction Nutrient Profile to 12.4 mg/kg DM,
consistent with the 2006 NRC RA for peak lactation and slightly more than FEDIAF
Guidelines and the NRC RA for growth. Because of poor bioavailability, the use of
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copper oxide as a nutritional source is excluded. The 2007 CNES deleted the copper
maximum concentration for many of the same science-based reasons cited above for
deleting the maximum for iron content.
MANGANESE
The minimum concentration for manganese in the Adult Maintenance Nutrient
Profile was not changed from the previous amount of 5.0 mg/kg DM, the amount being
slightly more than the 2006 NRC RA of 4.8 and slightly less than the FEDIAF
Guidelines of 5.6 mg/kg DM. The 2007 CNES increased the minimum recommended
concentration in the Growth and Reproduction Nutrient Profile to 7.2 mg/kg DM,
consistent with the 2006 NRC RA for peak lactation and slightly more than FEDIAF
Guidelines concentrations and NRC RA for growth.
ZINC
The 2006 NRC RA for zinc in growth, reproduction, and adult maintenance
formulations was less than the previous concentration in the Dog Food Nutrient
Profiles of 120 mg/kg DM and the 2007 CNES decreased the recommended minimum
concentration to 100 mg/kg DM in the Growth and Reproduction Nutrient Profile and
to 80 mg/kg DM in the Adult Maintenance Nutrient Profile consistent with the 2006
NRC RA and FEDIAF Guidelines concentrations. Both the 2005 Mineral Tolerance of
Animals and the 2006 Nutrient Requirements of Dogs and Cats state there is not
enough data available to set a tolerance or SUL for zinc in dog foods. The 2007 CNES