The following is a collection of what we call the "Raw Facts".  These are the end results of research by professionals in the industry and the personal experiences of the feeding team at Raw Wagon. Knowledge is power, our goal is to spread the truth, both the good and the bad, so we are confident that you will find this informative.

U.S. Food and Drug Adminstration

The following is a link to what the FDA has advised in regards to our industry.

Avoiding the Dangers of raw Pet food

Where to Begin....

How long has the dog been around? How long has kibble?

  • Dogs were first domesticated between 14,000 and 17,000 years ago.
  • The dog (Canis lupus familiaris) is far more variable in size, shape and behavior than any other living mammal, but most experts now believe that all dogs, no matter how different, originated exclusively from a single species: the gray wolf (Canis lupus) of central Asia.
  • DNA study proves that there was just one domestication event, and all domesticated dogs today descended from an ancestral wolf-dog, as wolf taming was an important cultural trait.
  • Despite the fact that dogs were first domesticated thousands of years ago, most dog breeds were developed within the last few centuries. 
  • The idea that dogs and cats should not eat raw meat came about in the mid-1800s when the Industrial Revolution led to a growth of the middle class and with that came many societal changes. One of which is that dogs and cats more commonly became pets and often lived in the house. Many people believed they should be “civilized,” and since wild and working dogs ate raw meat and cats were kept as mousers, pets should eat cooked food. Since the middle classes also were more affluent they were a ready market for commercially prepared foods.
  • Kibble (dry, crunchy food) first came about with Spratt’s Patent Meal Fibrine Dog Cakes, a biscuit first commercially produced in England in 1860. The dog food industry was slow to develop. Then, in 1931 the National Biscuit Company (Nabisco) bought the F.H. Bennet Biscuit Company, which was the first company to manufacture dry puppy food. It was Nabisco that put dog biscuits and food into the grocery stores and out to the masses.
  • The dry dog food industry got a real boost thanks to WWII. By 1941 canned dog food, around since the 1860s, had 90% of the market share. When the US entered WWII, metal and meat were both rationed. This was really launched cereal-based dry food. Consumers were delighted: dry food was easier, less messy, definitely less aromatic. And, like plain crackers, flavor coatings were sprinkled and sprayed on the dry food so dogs and cats gobbled them up.
  • It wasn’t until 1951, when the Ralston Purina Company (a company that began as Purina Mills in the US corn belt) experimented with their breakfast cereal extruders to create a more palatable dog food. The cat food industry followed right along with the trend.
  • The Pet Food Institute, a pet food industry lobbyist launched ad campaigns in 1964 in an effort to convince consumers that the only good food to feed was commercially prepared food. The campaign was hugely successful. The advertising industry has been so successful that most people today wouldn’t know what to feed their dog or cat if kibble wasn’t available.

Raw Models

There isn’t just one possible raw food diet for dogs. There are three main variations:

  1. Meat with Bone Diet. Veterinary Surgeon Tom Lonsdale, was one of the earliest advocates of feeding animals a species-appropriate diet and detailed it in his 1992 book “Raw Meaty Bones: Promote Health”. While Dr. Lonsdale recommends that the bulk of the diet should consist of “raw meaty bones” or carcasses when available, it also allows for table scraps, both cooked and raw.
  2. B.A.R.F. [Biologically Appropriate Raw Food] Diet. Ian Billinghurst proposed that in order to maximize your dog’s health, longevity, and reduce allergies and vet bills, you need to Give Your Dog a Bone. The BARF diet consists of 60 to 80 percent raw meaty bones, meaning bones that are about 50 percent meat. The remaining 20 to 40 percent should be comprised of fruit and vegetables, meat, offal, eggs, or dairy foods.
  3. Prey Model Diet. This diet’s goal is to simulate the proportions of prey animals that would naturally be eaten in an animal’s diet in the wild. Whole prey is used whenever possible, including chickens, game hens, turkeys, and whole rabbits. The diet recommends 80 percent meat (including some organs), 10 percent bone, and 10 percent organs (half is liver). The Prey model advocates feeding dogs meats from a wide variety of animals. Small amounts of vegetable matter are also included to help simulate the consumption of stomach contents.

There are varying opinions and questions about the components of a raw dog food diet for companion dogs. Judging the relative merits needs to begin with a clear-eyed view of the benefits of raw food for dogs overall.


AAFCO is the American Association of Feed Control Officials. 

  • It’s the body that sets standards for pet foods and animal feeds in the US.  The committee designs, reviews and modifies their standards on a continual basis.
  • Dog food that claims to be “complete and balanced,” means it meets AAFCO dog food standards. “Complete” means a food contains all nutrients that AAFCO classifies as essential for a dog. “Balanced” means the food contains nutrients in proportions that are currently approved by AAFCO. 
  • Well-known Australian vet Dr. Ian Billinghurst has a different opinion on AAFCO standards. He’s famous for creating the concept of BARF (Bones and Raw Food or Biologically Appropriate Raw (or Real) Food). 
  • Dr. Billinghurst says that the  AAFCO standards are based on flawed science and are not designed to keep animals in good health. 90 to 95% of dogs who get diseases like cancer, autoimmune diseases, allergies, renal failure or irritable bowel diseases developed their diseases after a lifetime of eating foods that passed AAFCO standards.
  • Dr. Billinghurst calls commercial processed pet foods Fake Industrial Foods (FIFs). They are highly denatured products with ingredients from industrial food waste. They depend on carbohydrates (mainly grains or other starches) for energy.
  • According to Dr Billinghurst, “Careful examination of the AAFCO guidelines reveal them to be a collection of compromises, guesses and opinions – and the writers freely admit it throughout the text!” The guide makes no mention of whole raw foods. At best it’s a guide to help processed food manufacturers make industrial food out of substandard material, and it’s of no value to anyone who wants to give their dogs genuinely healthy food.
  • AAFCO standards are based on what they call “commonly used ingredients.” These ingredients are specific sources of carbohydrates, fat, fiber and protein, chosen for their cheapness. In nearly every case, these foods need to have vitamins and minerals added. Otherwise they would never pass AAFCO standards.  Some examples of these commonly used ingredients include:
  • Meat and bone meal
  • Animal byproduct meal
  • Fish meal
  • Chicken liver meal
  • Peanut hulls
  • Cellulose
  • Soybean hulls
  • Vegetable oils… and more

These and other common ingredients are all nutritionally poor, especially because they’ve been subjected to extreme heat before and during the manufacturing process. Fats become toxic due to heat damage, and the heat causes chemical reactions between ingredients, producing substances that are often toxic and sometimes carcinogenic. The heat also means the bioavailability of these foods after heat processing is highly questionable. 

How Foods Meet AAFCO Standards

Processed food manufacturers can meet AAFCO standards in two ways.

  1. The Analytical Method - In the analytical method, the food is chemically analyzed to prove it meets AAFCO standards. A food made of cardboard, shoe leather, sump oil, blood and bone fertilizer with a vitamin and mineral premix will pass these standards with flying colors!
  2. The Feeding Trial Method - Astonishingly, the AAFCO rules say that if a food passes the feeding trial method, it doesn’t matter whether or not it passes the analytical method.  The protocols for the feeding trials are as follows:

  • There must be eight animals in the trial (not a statistically significant number)
  • Of the eight, two can drop out (for any reason) so only six need to complete the trial
  • Breed or sex is irrelevant
  • The trial length is 26 weeks
  • The animals are only fed the food being tested
  • They must have unlimited water
  • The animals must be pronounced healthy in pre- and post-trial veterinary exams
  • Four blood values (hemoglobin, PCV, alkaline phosphatase and albumin) are measured and the averages are compared to specified minimums
  • There’s no examination of urine, stools or any other blood measurements that vets routinely use to assess health.

So a food will pass the feeding trial as long as it keeps 6 out of 8 dogs alive for 26 weeks, one of more of them don’t lose more than 15% bodyweight and no blood values are below the specified minimum.  REALLY??????????

It would have to be an extremely poor food that would fail these parameters.

Evolutionary Nutrition

  • Dr. Billinghurst uses the term Evolutionary Nutrition to describe a fresh whole raw food diet.
  • Evolutionary nutrition: Feeds animals the diet they evolved to require. Formulating an evolutionary nutritional program depends on knowing the range and balance of whole raw foods an animal evolved to eat over the millions of years of its genetic adaptation.

The Principles of Evolutionary Nutrition

  • The food is raw and unprocessed. This makes nutrients completely bioavailable to the extent the body needs them.
  • The material used duplicates or mimics whole raw foods that the animal’s ancestors would have eaten.
  • There’s no list of required nutrients! This information isn’t necessary and isn’t actually known. What the animal evolved eating contains by definition every nutrient it requires, both known and unknown. The body’s homeostatic mechanisms ensure proper nutritional balance … the body takes what it needs.
  • There are no requirements for detailed rules. Just feed whole raw foods the animal evolved to require.
  • There’s no cooking so the components can be ground and mixed together with no likelihood of chemical reactions between the components.
  • It doesn’t depend on the opinions of a committee of nutritional experts but relies on feeding a wide range of whole raw foods an animal evolved to eat. There’s no big book!
  • No changes are needed, All the principles are constant and remain valid.
  • There’s no conflict between the principles and any feeding trials (contrast this with the FIF paradigm).
  • The foods are legally and biologically complete and balanced! They’d pass the AAFCO feeding trials and meet biological needs because raw food provides nutrients we know to be essential – and others like important phytonutrients, which AAFCO completely disregards.

The bottom line is when you raw feed your dog, you meet all their nutritional requirements without having to understand any modern nutritional science whatsoever.  

This is how dogs have survived and thrived throughout their evolution. Evolutionary nutrition is the gold standard. It allows the animal to reach his genetic potential for health, longevity, physical activity and reproduction. The further an animal diet departs from the evolutionary diet, the more health problems are likely to develop.

Dr. Billinghurst recommends feeding meats, bones, vegetables and organ meats. You can also add other healthy human foods like eggs and milk products. Supplements such as Essential Fatty Acids, probiotics, kelp, alfalfa, various herbs help replace what a dog would consume in nature.

Dr. Billinghurst wishes more raw food manufacturers would participate in the AAFCO feeding trials, so that vets and others can see that raw diets do in fact meet the standards for “complete and balanced.” He says that every dog he’s ever owned passed the equivalent of the AAFCO feeding trials. They’ve only ever eaten raw whole foods and they’ve passed vet exams and blood tests. They’ve maintained their weight and have rarely required his services as a vet.

Pet Food Safety & The Industry

There’s a lot of fear about raw pet food … you will hear it from kibble manufacturers, TV and newspaper stories, conventional veterinarians and of course the FDA (US Food and Drug Administration). The FDA warns consumers about pathogens like Salmonella, Listeria and monocytogenes, which they say could not only put your pets at risk of disease, but also your human family members.  However, pathogens (such as Salmonella) – while being many raw-feeders top concern – is one of the lowest risks associated with raw food. This is because these bacteria are pathogenic to humans but, generally speaking, not to dogs and cats. Pets’ stomachs have higher levels of acid than humans, making them hostile to bacteria, and their digestive tracts are shorter, giving bacteria less opportunity to mulitply. This is why pets routinely, without harm, eat items that would make a person sick.  Please take a moment to think about everything you have seen a dog eat and be just fine. However, pets with undeveloped or weak immune systems (I.e., puppies/kittens, older dogs, sick dogs) may have some risk. In these cases, we recommend cooking the food lightly (i.e., to 165 degrees) to help eliminate pathogenic risks.

These bacteria (especially Salmonella) are naturally present in meat – particularly poultry. So their is some risk of pathogens to humans who handle raw food. These risks can be minimized by using the same safety procedures that you would use for handling any raw meat products - such as cleaning surface areas exposed to raw food and washing your hands thoroughly after coming into contact with the food.

The Food and Drug Administration (FDA), which regulates pet food, acknowledges on their website that dogs and cats are generally not affected by pathogens like Salmonella unless they are already ill with some other condition. However, the FDA has a standard of “zero-tolerance” for such pathogens, which is a stricter standard than the US Department of Agriculture (USDA) sets for human food. So while the “human-grade” raw materials that companies like Raw Wagon use for pet food would be acceptable for people to eat, in many cases those same ingredients are not be acceptable to the FDA for raw pet food.

Many in the industry believe this is not the appropriate standard for raw pet food, especially as reported cases of people becoming sick from feeding raw food to their pets are extremely rare.

One of the primary benefits of feeding raw meals is that it provides a higher level of benefit than meals which are more processed, such as “good” bacteria and a higher level of nutrients. Some companies choose to control pathogens by applying a “kill step” that eliminates all bacteria. Examples of kill steps are cooking the food thoroughly, irradiation and High-Pressure Pasteurization. Even some raw pet food companies use kill steps. However, using a kill step means that “good” bacteria (which aids the digestive system) are eliminated along with pathogens.


High Pressure Pasteurization (HPP) might sound like a good idea because the purpose of HPP is to eliminate risky bacteria, like Salmonella or Listeria, in the food. It’s touted as a great solution for high quality, safe, raw commercial pet foods. If your veterinarian is uncomfortable with the idea of you feeding raw to your dog, he or she may try to steer you towards HPP foods to protect your dog from scary bacteria. However, it is important to first understand how HPP was “sold” to the pet food industry.

HPP is a patentable technology so there’s money to be made from encouraging consumers to buy HPP products. And there’s a benefit to the manufacturer and marketer who can claim their foods are safer than other raw pet foods. No company wants to be responsible for poisoning you or your pets. The real reason for the growing use of HPP is the FDA’s Food Safety Modernization Act (FMSA). FMSA was signed into law by President Obama in January 2011. The act was an attempt to take a more proactive approach to food safety issues, focusing on prevention. Before FMSA, the FDA didn’t do anything about food safety issues until they happened … for example, the melamine-tainted pet food that sickened or killed thousands of pets in 2007 wasn’t investigated by the FDA until after the fact, in 2008. Manufacturers started to panic when they knew FMSA was coming, even though the FDA isn’t forcing any manufacturer to sterilize or pasteurize their foods. In fact, an FDA document called Guidance for FDA Staff on salmonella in foods for animals states that it “Contains Nonbinding Recommendations” and represents the FDA’s “current thinking on this topic.” Nonetheless, FMSA sent manufacturers rushing to HPP and the practice is far more common than it used to be, despite its shortfalls … and the fact that there have been very few cases of salmonellosis in humans from pet foods.

The CDC (Centers for Disease Control and Prevention) has reported only two instances in the last 30 years of humans contracting salmonellosis from pet foods … and both those instances were from dry kibble:

  • Dry Pet Food (2012) – Diamond Pet Foods, Gaston SC, Salmonella infantis, 49 people affected in 20 states (2 in Canada), 10 hospitalized, no deaths reported
  • Dry Pet Food (2007) – Mars Pet Care, Pennsylvania facility, Salmonella schwarzengrund, 62 people affected, 10 hospitalized, no deaths reported

There have been no Salmonella outbreaks associated with any brand of commercial raw pet food.

The FDA even tested 78 samples of raw pet foods (35 frozen, 31 freeze-dried and 12 dehydrated) and found only five samples contained Salmonella and/or Listeria monocytogenes.  Just because they found salmonella in the samples doesn’t mean they’d make people sick. The science isn’t that simple and there are many variables. The tests are very sensitive and can pick up minute amounts of bacteria … even one viable cell. And they don’t distinguish between different types of Salmonella, some of which are non-pathogenic. All the samples tested negative for E. coli and STEC (Shiga toxin-producing E. Coli). 

The HPP Process

HPP isn’t just for pet foods. It’s used to prevent spoilage and extend the shelf life of many common grocery store products like guacamole, juices, hummus or fruit purees. During the HPP process the final packaged product is placed into a vessel of water. The vessel may also contain oil or propylene glycol to keep the equipment lubricated (but it doesn’t touch the food in its packaging). The food is then subjected to a high level of isostatic pressure (300–600MPa (megapascals) or 43,500-87,000 psi), transmitted by the water. These are extremely high pressures that disrupt the cell membranes of microorganisms in the food. They die and viable cells can’t survive. While HPP kills bacteria in the food, it does not kill spores. To understand the amount of pressure applied to HPP foods, consider that it’s five times the pressure at the deepest place on earth … the Mariana Trench, nearly 11,000 meters below sea level and deeper than Mount Everest is tall. So when HPP marketing says it’s a “natural” process … how can it be, when there is nothing on earth with that kind of pressure? And what does that extreme pressure do to the food?

Problems With HPP

Companies marketing HPP claim that while the HPP process kills bacteria, it doesn’t affect the nutrients, flavor or color of the foods. There are studies showing the contrary. There has to be a loss of nutrients because we know that heat reduces nutrients in foods. George Flick Jr, PhD, University Distinguished Professor Of Food Science and Technology at Virginia Tech University, is a recognized authority in HPP. In his publication Thought and Substantial Lab Research Required: High hydrostatic pressure processing has potential in the meat industry (Fleischwirtschaft International, Journal for meat production and processing, ISSN 0179-2415, No 3, 2009), Dr Flick states: “Basically, the effect of high pressure on microorganisms and proteins/enzymes was observed to be similar to that of thermal processing.” Yet HPP proponents insist that the food is still raw after the HPP process. The discrepancy may lie in the definitions published by AAFCO (the Association of American Feed Control Officials). AAFCO defines “raw” as “food in its natural or food state, not having been subjected to heat in the course of preparation of food.” Because heat is specifically mentioned, many consider that HPP doesn’t “cook” the food. In fact, in HPP there’s a 5.5°F rise in temperature for every 100 MPa and HPP is performed at 300 to 600 MPa. HPP food looks cooked on the surface because of this thermal change of up to 33°F. Lipid oxidation is a known negative effect of the HPP process. There are several research studies showing that high pressure treated samples oxidize more rapidly. Lipid oxidation means the fat in the food becomes rancid, making it potentially toxic to your dog. In humans, studies have linked lipid oxidation to disease states such as atherosclerosis, IBD and kidney damage. This lipid oxidation may be due to the cooperative effect with the denatured protein in the meat. We know that HPP denatures protein and there are many associated chemical reactions that aren’t fully understood.  It is also important to understand that because HPP is considered a “natural” process, it can be used for organic foods. So if you’re buying an organic raw dog food, don’t assume it’s fresh and natural … because it could be high pressure pasteurized.  There is also the potential of transfer of phthalates to HPP food. Phthalates are chemicals compounds in food packaging and they are known endocrine disruptors, linked to thyroid issues and obesity in both pets and humans. Because the HPP process is performed in the packaging, it seems likely that phthalates may be transferred to the food during processing. Phthalates are very fat soluble so the fat in meat makes the tendency for migration more likely. There are no studies suggesting this happens … but neither are there any studies saying it’s safe. And we know that phthalates can be transferred during heating or freezing, so it seems logical to conclude the same thing may happen when you apply 87,000 lbs of pressure!

A joint 2011 study into HPP benefits and limitations by three universities in Spain, the US and Mexico found “The possibility of packaging components, and packaging degradation substances formed during high temperature and pressure processing, transferring into foods where they can experience further chemical changes has to be investigated.” Spore-forming organisms like Clostridium botulinum (responsible for botulism poisoning) are not eliminated by HPP. One study concludes: “…spores of bacteria remain the most difficult problem to eliminate for making HPP-treated low-acid foods stable at room temperature. Eliminating all spores in a low- acid commercial food while maintaining non-thermal processing conditions is not possible at the present time.” The FDA is aware of this problem and doesn’t consider HPP a valid process for higher pH foods. Spores are common in meat and seafood. 


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