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FDA Proposed Pet Food Regulations

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    1. Susan Thixton Author

      Thanks Carl!

  1. Mollie Morrissette

    Good job Susan! It was a doozie – picking through the 400+ page document for omissions. Everything had to be verified, a triple checked. My notes were so extensive, I decided to break up my analysis into parts: Part I, Part II, Part III and so on. My fear is, no one will take the trouble to read them. I usually don’t fret over what people will think (obviously!), but this is so important – I want them to understand it. Our job is to distill all that information into a digestible format. Because, if they can’t comprehend it (hell, I had a hard time understanding it) – they’ll get frustrated and move on. And we so desperately need consumers to weigh-in (comment on the proposed rule), that I have been agonizing over how best to encourage them to do that. I suppose I can always resort to begging. So here goes: I implore you, anyone who has a pet, a farm animal, anyone who eats meat, eggs or dairy – this rule is for you. If you care about our future, our animal’s future, their health, indeed your own health, you are obliged to make a statement. Our government needs to hear from you. Let them know, in your own words, why this is important to you. It may be decades before another rule like this is presented to us. So, please, join us in making your voice heard – comment on the rule. We may never have another chance again to speak up for animals and the food they eat.

    1. Susan Thixton Author

      Mollie is so right – “We may never have another chance again to speak up for the animals and the food they eat.” Please send FDA your comments!

      1. Pacific Sun

        I know we’re all in agreement that PF consumers must speak up. And I’m sure we’d all like to try to do so. (I’ve spent 35 yrs in the corporate world). But this is a very complex document, mainly because it’s industry specific (not in layman’s terms obviously). And we the Readers don’t have nearly the background of Susan and Mollie. You’ve imersed yourselves in PFI history, conflicts and consequences for so long now. And you also have access to other professionals who’re making their own comments.
        .
        One way we tackled the analysis of proposed technical documents (my field) at my company was to use the following type of comparison format. To give users a reference point or some kind of context.
        .
        Could it be helpful for this document? Example:
        .
        Comment (wording) – existing status (or N/A status) versus proposed status (i.e., is it a change, a delete or an addition)?
        .
        Major areas of concern (i.e., as in the structure of the regulation) – such as Safety, Oversight, Enforcement, Penalty, Reporting, Record Keeping.
        .Other questions:
        Is Pet Food (companion animal) a sub-set of Animal Food (livestock) or are these regulations applicable to the whole?
        .
        Do we need Pet Food to BE a sub-set of Animal Food and why?
        .
        If average readers who are the consumers, can barely interpret what this law is about (officially speaking), how will the PF consumer ever be able to track its effectiveness or practicality once adopted and in use?

        1. Susan Thixton Author

          Is what I wrote hard to understand? I’d really like to know. I tried to make it as short as possible – but including every point that needed to be addressed. If anyone has any questions, please let me know.

          1. Elizabeth

            I found your summations/explainations very simple direct and easy to understand, and helpful. Thanks!
            I also found PacificSun’s organizational listing interesting to help read and sort the kind of verbage used in proposals of this kind, if I had to read it myself.

  2. Tim Stanley

    Gee,this would be great on 60 minutes!

  3. Marge

    Super job Susan and will be sure to share!!

    1. Susan Thixton Author

      Thanks!

  4. Jo

    Tim, what a great point! We need media coverage–and lots of it–to call consumers’ attention to it, which hopefully would result in more people speaking out on behalf of the animals! Susan and others on the committee, do you and/or your acquaintances have media connections so this issue can get some airtime? I would be happy to donate to support such an effort.

    I will also plan to write the FDA as I’ve done in the past (to which they responded). I also wonder, though, if we should also bring it to the attention of our political representatives. I can remember Illinois’ Dick Durbin being very vocal during the melamine fiasco, and encouraged pet owners to communicate with him. I even donated to his campaign because of it and I do not live in his state..

    Interesting, Susan, that you request no FDA bashing. I agree with that, as I believe it would be very detrimental to getting the FDA to listen to us and respect our position. I love and agree with Mollie’s opinions, but someone needs to get her on board with that strategy before it’s too late! Sorry, Mollie, absolutely do not mean to offend.

    1. Susan Thixton Author

      Jo – I think that is a smart idea to contact Representatives in Congress. It’s important to note – that Congress required FDA to complete these revisions to pet food regulations by 2009 (the dog ate their homework). We’ve got 100 or so days left to comment. We’ll do more on this – including media if any media is interested in learning more.

      Mollie speaks from her heart – and I respect her so for doing that. Believe me, when you are as immersed in this as much as we are (live, eat, breathe pet food) – plus when you hear gut wrenching stories on a daily basis of a pet death or serious pet illness as both of us do – it’s a real challenge to curb your tongue (I guess curb your tying fingers in this case). I’m sure Mollie won’t be offended – I just wanted to explain how truly challenging it is at times.

  5. Melanie McCain

    I submitted my comments tonight, including how my pet was sickened and ultimately lost due to the recalled melamine tainted food in 2007. I don’t want another family to suffer as we did, and I never want to lose a pet that way again. Thank you, Susan, for your extensive review. It was very helpful in compiling my comments.

    1. Susan Thixton Author

      Thank you Melanie. I do think it is important for FDA to hear those personal stories. I think they have forgotten what it is like to be a pet food consumer – what we are up against.

  6. Jay Smith

    Susan,

    Can you hear me applauding from California?

    Jay Smith
    freshfetch Pet Foods, Inc.

    1. Susan Thixton Author

      I wondered what that noise was 😉 Thanks Jay!

  7. Peter

    What consumers need to demand is labeling that is
    decipherable, a prohibition on the practice of breaking down ingredients into components (so that they appear farther down the list of ingredients), and the end to the use of FAKE terms such as “Brewer’s Rice” which are made-up AAFCO names used to disguise junk ingredients.

  8. charles

    the amount of effort on your part is overwhelming looking at the detailed analysis; however, i am overwhelmed by your analyses. it will not take “a few moments” to respond unless i just cut and paste your points. how do you think that will be viewed if everyone does this? should we just wait for the collective response? are you going to ask for signatures for the collective response.

    1. Susan Thixton Author

      Charles – I will do more posts on this – and highlight the most significant parts. But the trouble is, they are all important. Even with livestock feed (and those animals don’t have anyone speaking up for them). How can our own food be safe if cattle and poultry are forced to eat nasty waste (with added vitamins and minerals from China)?

      When you just scan all 400 pages of proposed regulations, it seems pretty positive. But then you look closely. Then you read the carefully crafted sections that just neglected to include (important) parts of federal food safety law. Such as declaring a food adulterated and illegal if it contains any part of a diseased animal. So…long story short, every point is important.

      Now, that said. I will work on a much shorter version. I wanted to get all of the details out there, because main stream media was making these FDA proposed regulations sound like it was the greatest thing since sliced bread…I wanted pet food consumers to know the truth.

  9. Lill Marks

    I agree 100% with the monitoring of small businesses and keep them responsible to any and all laws of the big pet food manufacturing companies. We have a small business in our town that makes his own raw in an open area and has now installed a dehydrator. He is a loose canon and these things should not be allowed to continue. The FDA should monitor any and all manufacturing establishments!

  10. Tami

    I agree with Charles; it would take more than a “few moments” to respond. It would be great to have a collective response template summarized from your information of the most significant parts. I feel there would be a much larger submission of comments on the Regulations.gov website if we had this available to copy and submit. Even though the comments would be the same, the power of volume in voices heard will have a greater impact on their decision.

    1. Susan Thixton Author

      I’m going to work on that – very much appreciate the input.

      1. Jo

        I agree with this approach–a petition type strategy with a heck of a lot of signatures. Just look at how successful Starbucks’ recent government shutdown-related online petition was! We could do the same. Surely the FDA understands that much of the general public isn’t going to understand and/or have time to read, decipher and respond to a 400-page government document; therefore, a petition showing our collective response as written by our Angel, Susan, and electronically signed by consumers would get their attention.

        1. charles

          if you do a petition type of response, if you are not familiar with change.org, it could be placed there and would i think allow a broader response.

  11. Pacific Sun

    I made my comments on the FDA.gov website about FSMA, summarized below:
    .
    1. Pet Food should be regulated separately from Livestock Feed. It must be formulated and guided to be long term, life time, optimal nutrition, based on manufacturing best practices, safety and quality.
    .
    2. Pet Food Industry (PFI) must comply with the existing definition of unacceptable waste (when it defies the health and safety of humans and pets). Toxic (cancer producing) substances are unacceptable.
    .
    3. As long as the FDA’s Compliance Policies exist, the integrity (positive effects) of this Regulation is undermined. The 3 D’s (dying, dead, diseased) rendered animals (included under the provision of “waste”) must be controlled and regulated, so that Rendering Plants are held accountable to this Regulation. Waste must exclude diseased (cancerous, euthanized, BSE tainted, companion animal) carcasses, and those ridden with injurious excessive toxins (Ethoxyquin, Phenobarbital, etc.).
    .
    4. The PFI and its business relationships (producers, manufacturers, 3rd party suppliers, distributors, storage) must comply with the Regulation to ensure seamless enforcement of health and safety standards. Size and Revenue thresholds must not excuse compliance, otherwise the integrity (effectiveness) will be undermined. All consumers are affected by all providers.
    .
    5. If or when manufacturers are not mandated to follow the Regulation guidelines, they must be required to use “warning” labels, regarding all ingredient content, origin, and production standards (i.e., as in non human grade). Definition to be stated.
    .
    6. Ingredient labels must be in “fundamental” terms, such as “rice” being rice, and not “brewer’s” rice. No fracturing of ingredients on labels.
    .
    7. Health jeopardizing allergens must be addressed, and labeled on PF.
    .
    8. Consequences for failure to comply with FSMA’s (so-called) “recommendations” (that is, as long as they are not mandated) need to be defined. Conversely, manufacturers should be “rewarded” for compliance, perhaps be being labeled as “FSMA Compliant” or some form of “seal of approval”.
    .
    9. Veterinarians should be involved in reporting, tracking, and data gathering pet illnesses when they are the result of FSMA’s failure to regulate a product, and a manufacturer’s failure to intentionally comply.
    .
    10. Transparency between consumer (Pet Owner) and protection agency (FDA) and manufacturing (PFI) must be bridged, and communication tools need to be formalized either through website portals, and/or being given representation at regulatory and industry meetings.
    .
    In Summary, it must be recognized by these entities the growing trend of many consumers who are resorting to (home produced) and “human grade” pet food diets, whether cooked or RAW, or by choosing selective (boutique) PF brands. Further deterioration of trust in the PFI, aggravated by production mistakes, recalls, and other ill or deadly effects upon pets, can only hurt the entire marketplace. The FDA and PFI must recognize this opportunity to improve product standards and safeguards, in order to improve future consumer reliance upon the products. These Regulations (therefore) should be considered a “Plus” rather than a “constraint” and “economic hardship”.
    .
    In the end, it behooves everyone to just do
    “the right thing” … which has been long overdue since 2007!

    1. Susan Thixton Author

      Thank you Pacific Sun!

  12. Eigen

    Here’s my receipt number for my public comments: 1jx-88se-rew5

    I hope it helps.

    Keep it up!

    Eigen

    1. Susan Thixton Author

      Thank you very much!

    1. Jeri

      Far more die from pathogens found in kibble, antibiotic residue, and other foreign matter present in pet food choices these days. I don’t define good health as absence of death, moreover. The increasing incidence of chronic and serious health issues speaks to this and cannot just be put down to “coincidence”. Most pets are fed these diets. The idea that there is anything “outrageous” in expecting high quality and an end to compliance policies which flout the laws is in itself outrageous. Many are choosing to go the home-cooked/raw route, and no wonder. They are tired of seeing the endless recalls for “oops, don’t know how that got in there!” ingredients from the big pet food manufacturers. The FDA regulations may be “adequate” as written, but only if they are FOLLOWED!

    2. Pacific Sun

      I wonder how many years of a dog’s or cat’s life a kibble is built to support? Minimum, average or maximum.
      .
      Do we as owners feel lucky or entitled if our pet lives beyond 18+ yrs? My question is this, have modern PF companies studied the effects of basic formulations in order to understand the diet’s impact on the lifespans of different sized dogs (and cats)? Are PF companies (PFCs) satisfied with average term lifespans, or to they aim for maximum? Not just in theory, or as a positive side effect? But definitely as becomming one of the companies’ main goals? And then, can the PFC even set out to prove such findings scientifically?? With all the brand-formulas out there (over 3000+ now), and amongst the intricacies of competitive advertising in order to get you to buy in the first place, there is not a LOT of emphasis put on longevity actually. And I think to make the decision, to make that claim, implies that some PF (either way) has or doesn’t a longevity advantage (as in fact it should). Or else, designing the concept of longevity begins to put doubtful thoughts in the consumers’ mind to begin with. After all, wouldn’t everyone be shopping for the brands that seem to “promise” the longest life with ultimate good health?
      .
      It should be recognized that pet food for companion (household) animals is a subset of animal feed (livestock) although it is not regulated differently or is produced (necessarily) with any inherently advantageous properties that we as loving owners recognize as important. Such as extending and prolonging life in a vital, healthy way for our “pets.” Therefore Livestock feed is contructed to sustain the animal, and to support the animal through slaughter, and to support it through secondary food production purposes (like milk, beef, eggs, whatever). Even if the PF Industry has conducted such long term studies, or embraced cumulative findings, then the next question is, would what they’ve learned in terms of increasing the highest values of the PF for that goal, either pay them (profit wise) to make it that way? And would doing so become a such a higher price point in the market place that consumers would buy in volume? Another thought is (advertising wise) how in the world would a PF company even begin to “market” a difference in their formulas by saying, “here’s one (being more costly) that our company has found is most likely to give your animal the longest, healthiest lifetime possible!” Now remember also, that the “assumption” of “long-life” is already built-in to PF advertising. Because no one is going to buy any food that intentionally is permitted to do the opposite (allow your pet to die prematurely or of a chronic disease). However no scientific claims (or studies) are actually being pushed (published) in order to support any real truth to the assumption. It’s a tricky, very subtle slope. But in the end, are the animals that we consider to be part of family, being fed any differently than Livestock? And, are we all okay with that reality, at least in terms of how “regulations” are enforced?
      .
      In the 60’s, when you would assume that PF formulas weren’t very sophisticated, I remember many neighborhood dogs and cats living long lives, being pretty healthy until the days of senility, and often passing away simply from “old age.”

  13. Jim Emerson

    OK, I’ll try to keep it simple. Many products (edible and otherwise, like Tom’s of Maine body, skin and hair products) list ingredients (on their labels or on their web site) with the following information:

    1) name of ingredient (organic, if applicable)
    2) source of ingredient (specific food/mineral source — e.g. pig ears, beef ribs — and country/state of origin)
    3) purpose (why is this ingredient used? Fiber? Protein? Preservative? Filler?)

    Pet food should meet the same standards.

  14. Darkstar

    I was fortunate in that I did not lose any of my beloved four footers during the frightful plague of melamine, but I did lose many my dogs’ friends and some acquaintances. I had a bitch in a clinic fifty miles from my house and went there every day after work and stayed with her all evening and into the early hours of the morning. During that time I met three to twelve dogs a day who came to the clinic with their humans who were holding them and cans of dog food in their hands. There were three German Shepherd dogs who came in with their family and were hooked up to four intravenus lines each meant to flush the toxin from their bodies. They had all passed over by the next day, leaving three young children heartbroken. I met some of the sweetest dogs and their crying humans and few suvived. It was heart breaking. The hardest was a lovely English Bulldog named Winston. While in the waiting room he kept moving toward me on the communal bench while I waited to see my girl. He inched over until he could lean on me and finally made it up into my lap. I became very attached to Winston and his humans. He fought bravely. I visited him briefly for four days. On the fifth day his room was empty and when I looked toward the vet tech with hope she shook her head no. I cannot describe my anger with the perpetrators of this plague and they way in which they destroyed such promising, innocent lives of dogs and crushed their families.

    A month or so after I brought my girl home my husband came home from work and said he’d like to have a talk. He told me that for years he’d thought I was just a tiny bit crazy because of the way I researched everything that our dogs ate ( I am, after all, a libraian and research everything ). He had worried that I was too obsessive. He said he now had to apologize. He was the only person in his group of three hundred+ engineers who didn’t run to his computer first thing in the morning to see what dog food had been recalled due to melanine having been found in the food they fed. He didn’t have to, because he knew our dogs were safe because of my research.

    Bless you, Susan for doing such good work for all of us and letting us disseminate the information. I will read this when I get home from work and I will write to whoever needs to hear this.

    Thank you.

  15. Susan

    Didn’t have time to study your entire comments but my thoughts are on # 2, 3. There should be no exemptions period. The food should be human grade, period. It should be labeled as to content, country of origin of ingredients, if gmo ingredients have been used and if it has been radiated. People have a right to know what is in their food and in the pet’s food and where and how it has been processed. There should also be a mandatory reporting system put into place for food borne illnesses and the offending food should be sent to a lab for testing. It is my opinion that following the same regs for pet food as for human food is the minimal requirement. Those are certainly lax enough!

  16. Ramon Vilchis

    Hello Susan. Do you know if allergens into petfood are already at any FDA rule? Today

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