FDA says ‘Dog Ate Homework’
You are well aware of the pet food recall of 2007. You are well aware that due to that recall thousands of pets died, and thousands more became ill. You are probably aware that the FDA held a public meeting on May 13, 2008 to seek input from stakeholder groups – including consumers – for the future safety of pet food. But you are probably not aware that the FDA seems to be giving the U.S. pet owning public and Congress the same excuse school children often use…
A little background information first…In September 2007, Congress passed into law FDA’s Amendments Act (FDAAA). FDAAA was established by Congress to protect all foods – human and pet, but for our purposes here I am just giving you a brief explanation of the pet food section. Section 1002 (a) of FDAAA requires the FDA to establish pet food ingredient standards and definitions, processing standards for pet food, and provide updated standards for the labeling of pet food that include nutrition and ingredient information. Briefly, FDAAA asks for a total reform of the existing pet food regulations. These new standards and definitions must be established within two years (September 2007-September 2009). FDAAA Section 1002 (b) applies to an early warning system and notification system during a pet food recall. This section regarding to a recall warning and notification system must be in place within one year (September 2007 – September 2008). FDAAA was initiated by Congress in response to the deadly 2007 pet food recall and numerous human food recalls – a complete over hall of the existing FDA system was required. In fact, the mandate from Congress for the FDA to implement FDAAA was the purpose of the May 13th pet food safety meeting – to obtain input from consumers and stakeholders.
So…what we have so far is this…
FDAAA Section 1002
New Law developed to reform and improve
Existing pet food safety regulations
Completed and in working order by September 2009
Great. FDAAA became the possible light at the end of the tunnel for pet owners. That is until…
You would think that Congress’s efforts to pass the Amendments Act would initiate a new effort towards pet food safety regulations from the FDA – especially considering the horrible pet food recall last year. After all, the bill was passed wanting reform – but that’s not what is happening. Instead of working on reform, the FDA is relying on an incomplete five year old program that is chocked full of loopholes and gaps to meet the requirements of FDAAA. In fact, the day BEFORE the May 13th pet food safety meeting, the FDA released the latest version of this dated program implying this dusty ill-effective work meets the requirements of FDAAA. The five year old dated program is called Animal Feed Safety System or AFSS. It’s confusing – just to clarify…FDAAA is the legislation that requires the FDA to reform the pet food ingredient, production, and labeling safety system. AFSS is a five year old program that is full of loopholes the FDA refers to as ‘gaps’ and is full of more problems for pet owners.
For starters, if you’d like to read the latest AFSS edition (there have been many over the last five years) here is the link – http://www.fda.gov/cvm/AFSS3rdDraftFramework.html.
But, in case you read the above document and get lost in the bureaucratic jargon (it’s very easy to get lost!) – here are a few highlights of what a mess this FDA solution to pet food safety is…
“Although the title Animal Feed Safety System may be new…” – Nope, it’s not ‘new’. The AFSS program has been in the works for five years now and during that time frame we suffered through five large pet food recalls (2005 Diamond pet food due to aflatoxin contamination, 2006 Ol’ Roy and others due to canning problems, 2006 Merrick due to metal found in product, 2006 Royal Canin due to vitamin overdose, and 2007 due to gluten contamination). I think the AFSS has proved it is ineffective at preventing pet death and illness.
“The AFSS, with its strong emphasis on prevention, figures prominently in the Food Protection Plan.” Hmmm, ‘strong emphasis on prevention’? AFSS is relying solely on pet food manufacturers to determine pet food risks and for pet food manufacturers and pet food suppliers to provide a solution for these risks. Interesting…pet food regulations that approve the fox guarding the hen house. The ‘operating principles of the AFSS’ specifically state rules provide flexibility to individual pet food producers. (Wow, wonder if the IRS would consider adopting AFSS?) And again, this is not reform – existing regulations and AFSS provide manufacturers the power to basically govern themselves.
With regards to ingredient definitions, the AFSS completely accepts AAFCO (American Asssociation of Feed Control Officials) ingredient list…”AAFCO regulations aimed to keep pace with industry desires and public interests”. No reform here…Again…current AAFCO regulations do keep pace with industry desires since on every advisory board of AAFCO sits a pet food manufacturer representative. But AAFCO regulations do not keep pace with public interests as they claim. Public interest is safe pet food – the long list of pet food recalls, pet illness, and pet deaths over the years of AAFCO proves pet owner interests are NOT addressed.
This could go on forever, but one last important point. AFSS has been in the works for five years and the latest version acknowledges 14 significant gaps. There is NO end in site. AFSS seems it will not meet the September 2008 and September 2009 FDAAA deadlines.
Part of FDAAA also asks for input to establish a “Third Party Certification Program” for pet food safety. This could be a method for a consumer group to be established – looking out for the interest of pets instead of pet food profits. Interestingly, the PFI (Pet Food Institute – a lobbying organization representing a majority of pet food manufacturers) responded stating “the importance that private-sector third parties are free of financial conflicts of interest.” In other words the PFI – who DOES profit from existing pet food regulations – wants to make sure consumer groups aren’t profiting from pet food safety. This is classic ‘the pot calling the kettle black’. The PFI is certainly not free of ‘financial conflicts’ themselves – pet owners would definitely be.
So that light we saw at the end of the tunnel to all this pet food recall mess was actually just a reflection of the same old #%&@. It is perplexing how Congress can pass a new bill (FDAAA) which requires the FDA to update and reform pet food safety standards, yet the FDA seems to ignore this. Perhaps they told Congress their patented excuse…”we don’t have the funding or the manpower to get this done” as to why they are using an outdated ineffective system instead of the mandated reform. Sounds similar to a child telling the teacher “the dog ate my homework” – except in this case the ‘excuse’ is working.
Things are tough everywhere – higher gas prices, higher grocery prices, deflated housing prices. Yet U.S. pet owners don’t have the privilege of telling our bosses ‘can’t come into work today, don’t have the funding – instead I’m going to dust off a five year old report and give you that’.
C’mon FDA, quit telling Congress and 74 million U.S. pet owners the ‘dog ate your homework’. We don’t care to hear your excuses – do your job, reform the existing pet food ingredient, production, and labeling regulations as FDAAA mandated you to do. Quit relying on a $26 Billion dollar a year industry to regulate themselves. This is personal – this is our family.
If you would like to tell the FDA you are tired of excuses – please use the following list of pertinent contacts. Send them an email and tell them ‘the dog ate my homework’ doesn’t cut it. Example letters and suggested recipients are below.
William J. Burkholder, DVM, Ph.D. Center for Veterinary Medicine Division of Animal Feeds FDA/CVM Rockville, MD 20855 Telephone: 240-453-6865 Fax: 240-453-6882 E-mail: firstname.lastname@example.org
Cathie Marshall FDA HFV-232 7500 Standish Place Rockville, MD 20855 Telephone: 240-276-9217 Fax: 240-276-9241 E-mail: email@example.com
President of AAFCO
Ricky Schroeder Office of the Texas State Chemist P.O. Box 3160 College Station, TX 77841-3160 Telephone: 979-845-1121 Fax: 979-845-1389 E-mail: firstname.lastname@example.org Key Members of AAFCO:
Eric Nelson Feed Specialist Wisconsin Department of Agriculture, Trade and Consumer Protection P.O. Box 8911 Madison, WI 53708 Telephone: 608-224-4539 Fax: 608-224-4656 E-mail: email@example.com
Dave Syverson Regulatory Consultant Commercial Feed Program Dairy and Food Inspection Division Minnesota Department of Agriculture 625 Robert Street North St. Paul, MN 55155 Telephone: 651-201-6506 Fax: 651-201-6119 E-mail: David.Syverson@state.mn.us
Example letter to FDA/CVM
I no longer wish to hear that you ‘don’t have the funding or manpower’ to do your job. I don’t have the privilege of telling my boss that – and since I am a U.S. tax paying citizen – you can’t tell me that any longer either. FDAAA Section 1002 was developed by Congress to assure pet owners the FDA would ‘reform’ pet food ingredients, production, and labeling regulations – not to dust off your five year old incompetent work AFSS. Get back to business – reform pet food regulations so that I can sleep at night not worried when the next pet food recall is going to happen. I’m not interested in your old work – that’s proven not to keep pets safe. Provide U.S. citizens with new, effective, innovative pet food safety reform. Establish a Consumer organization that has the sole interest of pets – not profits – in mind. Big business cannot regulate themselves. We are counting on YOU for that.
Example letter to AAFCO:
FDAAA was established for pet food regulation reform. Continuing with the same industry input, same ‘recommended’ quality control, same nutrient information, and same ingredient definitions is NOT reform. AFSS is NOT reform – it’s five years old and the current ‘update’ has 14 gaps stated by the FDA. It also states that AAFCO “keeps pace with public interests”. To my count, there is ONLY one consumer representative on just ONE of your Advisory Boards. Yet every Advisory Board contains several members of pet food manufacturing or lobbying. AAFCO should be looking out for pets – not profits of pet food manufacturers. Get an equal amount of consumer representatives as industry representatives on every single pet food advisory board. Embrace what Congress mandated with FDAAA – reform. What pet owners have now is NOT reform and it is not working.
Example letter to your local media:
As you may or may not be aware of, the FDA held a public meeting on May 13th, 2008 seeking input from stakeholder groups to assure pet food safety. The FDA was required to do this because of the bill passed by Congress known as FDAAA (Section 1002 refers to pet food). But what you are probably not aware of is that instead of developing pet food safety reform – the FDA is trying to tell the teacher the ‘dog ate my homework’ by turning in to Congress a dusty, ineffective work that is five years old.
Times are difficult for everyone. Pet owners are tired of hearing the excuse ‘we don’t have the manpower or the funding’ when the FDA doesn’t do their job. ‘The dog ate my homework’ didn’t work in second grade – and it doesn’t work for the FDA. I urge you to investigate this issue and report to our community that the FDA should do as Congress mandated them to do with FDAAA – reform pet food regulations. A couple of pet advocate organizations that are working on this are www.DefendOurPets.org – Mike Floyd and www.TruthAboutPetFood.com – Susan Thixton.
Wishing you and your pet(s) the best,
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