Feedback to FDA on Pet Food Safety Video
During the AAFCO meeting the FDA previewed a pet food safety video. The following is the feedback I sent to Eric Nelson of FDA on the video.
You should know – that FDA’s Eric M. Nelson (Center for Veterinary Medicine, Division of Compliance, Director) was very friendly and very willing to put up with my endless questions during the AAFCO meeting. It is my intention to maintain this open dialogue with him/FDA.
After the video was previewed, Eric Nelson asked for input to be sent to him. The following was my input and was emailed Saturday 1/21/2112.
Hope you made it home safe. I’m VERY glad to be back to warm weather – I came home to sunny skies and 70 degrees! I’m happy again.
Now for the bad news. The video that was previewed…I have many thoughts –
If left as is, I can assure you it will anger many pet parents. They won’t just be upset, they will be downright angry; justifiably so. If you doubt this, I’d challenge you to do a one or two day preview of the video on my website and you can read the comments as they come in – it won’t be pretty.
Statements made in the video that struck me…
“pet food follows the same regulations as people food”
Nope, this is not a factual statement; that is unless ‘people food’ has FDA compliance policies that I’m not aware allowing 4D animals, euthanized animals, and rodent/bird feces infested ingredients into people food. Pet food does not follow the same regulations as people food. I guess it could be stated that pet food should follow the same regulations as people food – but certainly you must know they don’t.
“pet foods are truthfully labeled”
Again, no. Pet food labels and advertisements are as misleading as it gets. Images of choice cuts of meats, fresh vegetables on the label – turn the bag or can over and you see nothing that comes close to choice cuts of meat in the ingredient panel. Again, it could be stated ‘pet foods should be truthfully labeled’ – certainly you know many of them are not.
“everything used to make the food must be listed on the label”
No again. Additives to ingredients added by the ingredient supplier do not have to be listed on the label. The perfect (and dangerous) example is ethoxyquin added to fish meals and fish oils. Fish meal suppliers add ethoxyquin prior to the meal becoming a pet food ingredient – ‘e’ is not listed on the label.
In reference to the video urging consumers/petsumers to report a pet food related incident, the statement the FDA can then take “quick action to eliminate the problem” is a concern. While I agree all pet food related or suspect pet food/treat related incidents should be reported to FDA and to State Dept of Agriculture (and by the way I encourage everyone to do this) – the statement the FDA takes ‘quick action’ to eliminate the problem is not factual – at least not from a pet parent perspective. I have personally followed up with dozens and dozens of pet owners that have reported a pet food/treat related incident to FDA. Many of them shared that the FDA investigator was very kind and helpful – however, almost 100% of them have also shared that no follow up or no ‘quick action’ occurred. All of these pet owners were left with a sick pet or a dead pet, significant vet bills, and no action by FDA. Making that statement in the video would do nothing but hurt countless thousands of pet parents.
If FDA’s goal with this video is to shorten the great divide between petsumers and FDA – the entire video should be scrapped. As it is, it will only strengthen the belief of educated petsumers that FDA does not care about our pets. Might I suggest…a video following the investigation procedure of (as example) five different pet food related incidents reported to FDA. Show in the video the investigative trail that FDA goes down. Meeting with the pet parent, testing the pet food, speaking with the veterinarian and so on. And be honest – don’t make it ‘Hollywood’ or ‘Once upon a time’. Show the challenges of testing and trying to determine if it was a contaminant or a manufacturing issue and so on. Perhaps provide pet parents with some assistance on how to determine what the contaminant or issue is. Give us – as example – what the symptoms are of vitamin toxicity, mineral toxicity, and/or mycotoxin poisoning. Give us helpful information! The more we learn, perhaps we (pet parents) can be of greater assistance in future reporting issues and in turn, perhaps the contaminant will be found (saving lives).
On a different note, day one of the AAFCO meetings a Dr. Ferrah (not sure about that spelling) stated to me that FDA meets with a pet owner advocacy group “several times a year”. He said it was Pet Food Safety Alliance. The only organization I know of similar to that name is Pet Food Products Safety Alliance – Don Earl. I contacted Don to confirm this and his response was no – FDA has never met with him or anyone from his organization. So, can you provide me with the name of the consumer/petsumer organization that FDA meets with “several times a year”? Would FDA be willing to meet with me and a handful of our pet parents several times a year? As well, can you provide me with the proper spelling of Dr. Ferrah’s name and his contact information; I would like to follow up with him.
On those nasty FDA Compliance Policies, can you provide me with the FDA science that proves ingredients sourced from 4D animals, euthanized animals, and rodent/bird feces infested foods provide nutrition to pets. I’m not asking for the measurement of fat or protein of these ingredients, I’m asking for the science that FDA uses to determine these ingredients are safe for pets to consume and provide nutrients to pets.
And sorry – one more thing. Can FDA make public the product pull information on pet foods – and promptly? I believe it was you that shared with me a manufacturer is required to report to FDA within 24 hours of a product pull (when there is a health risk), can FDA please post this information for the consumer/petsumer’s protection?
I hope you take the above feedback into consideration and I hope you will continue to keep the dialogue open.
I’ve already heard back from Eric Nelson, below is his response…
Susan, we must not live in the same part of the country. I returned to snow freezing rain and chilly temps. Your comments are detailed which will require a little time to ponder. Hopefully I can get back to you before the end of the month.
Thank you to FDA’s Eric Nelson for promptly responding. I’ll keep everyone posted as I hear more.
Wishing you and your pet(s) the best,
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