Clean Label Project’s Response to Whole Dog Journal

Clean Label Project’s Response to Whole Dog Journal

 by Jaclyn Bowen, MPH, MS Executive Director

The Clean Label Project believes in looking beyond the label and evaluating products on the basis of real, scientific data. I’m writing this today to set the record straight and to re-affirm what we’ve always said here at the Clean Label Project: Less environmental and industrial contaminants in the food we feed our families (including our pets) is better than more.

Contrary to the absurd litany of inaccuracies within the Whole Dog Journal post about our pet food list, Clean Label Project believes that:

  1. Food that is healthy and nutritious and low in industrial and environmental contaminants and toxins should not be a novel concept
  2. Consumers make more informed choices when armed with data, science, and transparency as opposed to marketing
  3. That brands should be held accountable for the products they put on store shelves
  4. That the very best products deserve to win in the marketplace

Clean Label Project rates products using a methodology that is comprised of toxicology testing and on-pack label review. The toxicology testing makes up 80% of the overall algorithm and includes 60% for heavy metals, 20% for by-product contaminants, and 20% for process-contaminants. The remaining 20% is the evaluation of nutritional content using the on-package ingredient deck claims.


I’m going to respond to this post by using an illustrative example. First, a few facts to set the stage:

  1. Arsenic is a toxic metalloid. It can be naturally occurring, as it’s found in the earth’s crust, but it can sometimes be found in higher concentrations due to human activities– namely the breakdown components of harmful persistent pesticides. Arsenic was once used in rat poison because of its efficacy in quickly damaging the digestive system, heart and nervous system, and causing kidney failure and ultimately death. Suffice it to say, arsenic is bad for living things.
  2. The maximum amount of arsenic that is allowed in drinking water per the Environmental Protection Agency (EPA) is .01 parts per million (ppm) or 10 parts per billion (ppb).Note (*): Why are we comparing it to drinking water? Because there are no regulations for toxins in pet food. So for a frame of reference, we use the EPA drinking water limits, as they are the most well-known source of measurement of concern.
  3. Hazardous waste is a product, that if not transported, managed, and disposed of in a responsible way could seriously threaten human and environmental health and safety. When it comes to the disposal of hazardous waste, the EPA allows for only a certain concentration of so-called “RCRA 8” metals (Resource, Recovery, and Conservation Act), above which special steps must be taken when disposing of the material. Why? Because these 8 metals (arsenic, barium, cadmium, chromium, lead, mercury, selenium, and silver) are extremely toxic, even at low levels.  For arsenic, that magic concentration level is 5ppm (mg/L) or 5000ppb.

Now, for the example: It is concerning that Whole Dog Journal “recommends” two brands with at least three products that, based on our independent laboratory testing data, exceed the hazardous waste level on its “2018 Approved Dry Dog Food” List. This means that Whole Dog Journal is recommending its readers buy a product so contaminated with metals that, by all logic, it should be disposed of using the special rules that govern toxic waste. Whole Dog Journal, you have a lot of nerve to tout, “The food you give your dog plays a critical role in his well-being, both on a daily basis and long-term. He needs a diet with the right nutrients to keep him active, happy, and healthy.” I don’t know about you, Whole Dog Journal readers, but “hazardous waste” doesn’t sound healthy to me.


Let’s take another example. Here’s some background:

  1. The maximum amount of lead allowed in drinking water per the EPA is 15 ppb.*
  2. During the Flint, MI drinking water public health travesty, a notification was issued to pet owners to give their dogs bottled water in areas where the lead contamination levels exceeded 150 parts per billion.

Again, you can find four of the brands with products that exceed the Flint, MI lead action level for pets on the Whole Dog Journal’s 2018 Approved Dry Dog Food list.

But don’t just take my word on this. There is a current class action lawsuit that is taking place in California on WellPet and its parent company Berwind. The plaintiffs allege that unusually high levels of heavy metals are present in these dog foods, and they have independent laboratory testing data to back it up. The defendants (Wellness) supposedly market their products as having “Uncompromising Nutrition” and “Unrivaled Quality Standards,” which, the suit argues, would lead consumers to believe that the pet food is free of toxins. The plaintiffs argue, however, that the food they fed their dogs contained over 1,000 ppb (parts per billion) of arsenic and over 200 ppb of lead, as reported in independent lab tests. The lawsuit labels arsenic as “a known cause of human cancer” and claims that lead can build up in the body over time and cause “severe brain and kidney damage, among other issues, and ultimately cause death.”

Again, Whole Dog Journal refers to “WellPet’s Wellness” as a “regular” on its approved dry dog food list.

Clean Label Project does have a testing and certification program – a certification program that does come at a cost consistent with certification models associated with the market forces like Certified Gluten-free, Certified Organic, and Certified Non-GMO Project.

On Clean Label Project’s website, all of these products mentioned above are rated as one-star because, to my thinking, the purity of a pet food cannot be assumed, which is why we don’t trust the marketing — which is not regulated — and instead have products tested. The purpose of a marketing department is to sell more products, which means a savvy consumer should always take a claim made “on pack” with a grain of salt. Yet Whole Dog Journal appears to base its decisions entirely on the label. But let’s remember, the pentobarbital found in Evanger’s in 2017 wasn’t found by reading the back of a label. It was found by conducting rigorous analytical chemistry testing. At the end of the day, when given the choice between marketing puffery and hard data, Clean Label Project will take the data every time.

Perhaps the most baffling part of the Whole Dog Journal article is the section on acrylamide – a known neurotoxin, carcinogen, and source of birth defects. Whole Dog Journal may not be aware of any evidence linking acrylamide to harm in dogs, but as we’ve already established the Whole Dog Journal does not appear to be willing to dig any deeper than the surface when making decisions. There are scientific studies linking exposure to acrylamide to neurological issues in dogs going all the way back to the 1980s. Acrylamide is a dangerous compound for living creatures, the effects of which can build up over time.


When all is said and done, the readers of Whole Dog Journal have a choice: they can choose to believe that the claims brands put on their labels is the truth, the whole truth, and nothing but the truth – despite their being direct evidence to the contrary – or they can embrace our call to action and demand that members of the pet food industry do better.


Whole Dog Journal, we agree with one aspect of your 2018 Dry Dog Food Approved List: not all dog foods are created equal. I would venture to say that not all pet food evaluation websites are created equal either.


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