Final Notes AAFCO Summer 2016 Meeting
Another AAFCO meeting is done. This past meeting in Pittsburgh, PA marked the 11th AAFCO meeting I’ve attended (unfortunately, just a drop in the bucket to what it takes for us to achieve change). Here are detailed notes of what happened.
A little less than 400 people attended this AAFCO meeting, mostly industry. Your tax dollars sent 20 representatives of FDA to this meeting (estimated $30,000 to $35,000 expense). The two most significant meetings for pet food consumers are the Pet Food Committee Meeting and the Ingredient Definitions Committee Meeting. Notes from each meeting below.
In years past, our friend Dr. Cathy Alinovi has attended AAFCO meetings being another voice for pet food consumers. At this meeting (and in the future) that has changed, but only a little. Dr. Cathy has become the voice for quality small pet food manufacturers through her newly formed Next Generation Pet Food Manufacturers Association (http://www.ngpfma.org/). Though we’ll will miss her being a consumer advocate, quality minded small pet food manufacturers need a voice at AAFCO and I believe our (consumer) wants are closely aligned with quality pet foods. Dr. Cathy – ‘Next Gen’ – has promised to work closely with consumers; I am confident she will.
Pet Food Committee Meeting
Because AAFCO is developing model bills that will become future law, attention to detail is required. During the Pet Food Committee meeting we learned that the American Feed Industry Association (AFIA) went through the AAFCO rule book (Official Publication) and submitted to AAFCO various ‘details’ they felt should be changed. Why did this trade association do this? Rumor is they are ‘working’ Congress to adopt the AAFCO Official Publication into federal law. We can safely assume they want all the ‘details’ worked out before they do their ‘work’ on Congress.
One of the details that AFIA found was the definition of ‘pet’in the AAFCO Official Publication (the rule book). AAFCO currently defines pet as: “The term pet means dog or cat.” AFIA suggested to add the word ‘domesticated’ to the definition; domesticated cat or dog. There was discussion that not all cats or dogs consuming pet food are domesticated, such as feral cats.
Carbohydrate disclosure (amount of carbohydrates) on pet food labels has been in discussion for many years. Several years ago AAFCO initiated a working group of industry and regulatory (no consumer advocates) to develop regulations regarding carbohydrate disclosure statements on pet food labels. The working group provided their report to the Pet Food Committee and the report was accepted. There was no real discussion of the report; it is posted on the member side of the AAFCO website and is open for discussion by members until September 30, 2016. The full carbohydrate working group report cannot be shared publicly here, but will be posted on the Association website for members (sorry, AAFCO rules). What I can share here is that the report is not all bad. If what is in the report is accepted into the model bills (future state law), it would allow pet food manufacturers the opportunity to disclose carbohydrate content in the Guaranteed Analysis on the pet food label. When that will finally happen is unknown.
The Human Grade pet food discussion occurred again. AAFCO seems quite nervous of this foreign style of pet food (sarcasm). The North Carolina Department of Agriculture Representative stated they use the certificate of inspection provided by the approved authority such as the Health Department or FDA. Human Grade pet food is so foreign to regulatory authorities because State Department of Agriculture representatives have never in the past had any dealings with ‘food’; they regulate ‘feed’. Human Grade pet food is – simply put – food; the only pet food that is actual food.
Discussion on Human Grade pet food continued that the product must be “pet edible”. It was stated that “first and foremost” the product claiming Human Grade must be a pet food and meet all requirements of pet food (such as including ingredients meant for pet consumption) – and if the manufacturer chooses to make the additional claim of human grade, “you can do that too”. The Pet Food Committee made it clear to the audience that Human Grade claims on pet food were a “voluntary claim”. In other words, pet foods are not typically food (human grade), pet foods are not required to be food (human grade). They are called ‘food’, termed as cat food or dog food, but not required to be food (human grade). Confusing. Truly, the only pet foods that are actually food (meet the legal requirements of food) are Human Grade.
The Committee acknowledged that some styles of pet food don’t meet the AAFCO definition of human grade (such as raw pet foods processed under USDA inspection). FDA shared they “put this out to industry” for proposals on how to make verification of human grade claims for foods that don’t meet the current regulation. The Committee urged “them” (manufacturers who don’t meet the current Human Grade claim) “to come up with a proposal for us to consider”. In other words, raw pet food companies and other pet foods that want to make the human grade claim must do some AAFCO work to get that important claim on their labels.
With Human Grade pet food, the term ‘edible’ was mentioned frequently. Industry wasn’t happy with the ‘edible’ discussion and stated “edible and inedible is only appropriate for human food”; she wanted the word ‘edible’ removed. Edible and inedible are terms used (mostly) by USDA in reference to food. Edible would be approved as food (for human consumption), inedible would not be approved as food. No change was made, ‘edible’ was not removed. FDA shifted the conversation back to ‘edible for pets’ giving the example that a (human) cookie with xylitol is human edible but should not be consumed by pets.
It is important to note for consumers, discussion also stated that all regulations for the Human Grade claim apply to pet food company websites. No human grade claim on pet food websites should/can be made unless they meet all regulations. If a consumer sees the claim on a website and wonders about the validity of the claim, ask your State Department of Agriculture.
During the Pet Food Committee meeting, Big Heart Pet Brands gave a presentation on the word ‘meaty’ used on pet food labels. Their complaint – basically – was that one State is refusing to allow them to use the term ‘meaty’ on a chicken product and a seafood product (49 states are allowing the term, 1 state is not). She complained that big retailers such as Walmart and Petco would not accept Big Heart products when they could only be sold in 49 states. She asked the Pet Food Committee to become more “aligned” on this term.
FDA spoke up alluding that the term could be “misbranding”. It was suggested to Big Heart brands to include a qualifier with the term ‘meaty’. Such as ‘Meaty Chicken’.
I provided consumer input to Big Heart stating consumers believe ‘meaty’ should mean meat, a significant amount of meat. And that consumers believe it is a misleading term. I explained to Big Heart “your examples of finding that (the term meaty) everywhere are what pet food consumers have to deal with on a regular basis. The word meat, pictures of meaty. I can relate to your concern, but I’m in a ‘different ballpark’ because of the consumer concern.”
The Big Heart representative asked if she could respond to my consumer input. She then provided me with the dictionary definition of meaty sharing “their example is meaty tomatoes. They also give examples of ‘meaty fish’.” And then asked me “where’s your confusion?” I felt her response to consumer opinion was snarky and missing the point of misleading ‘meaty’ claims.
The Pet Food Institute spoke up stating ‘meaty’ is “a culinary term” used to describe a product.
Big Heart’s presentation and discussion never offered the Pet Food Committee a resolve to their problem.
The last discussion of the Pet Food Committee meeting was regarding cannabidiol treats for pets. Cannabidiol treats for pets (treats that contain marijuana-derived ingredients) are not approved for interstate sale by FDA. My guess is that FDA will begin being very strict with this, and the brief discussion was a warning to those selling the treats. FDA directed anyone with questions to their website (item 13). Click Here for that FDA webpage.
Ingredient Definitions Committee Meeting
During this meeting I sat next to ‘the mineral guy’. For those that have read my AAFCO meeting notes years past, you might recall my sharing about AAFCO approving a zinc ingredient that three veterinarians spoke out against. The industry representative that wanted the ingredient approved, after the meeting was over, tried to begin an argument with me, and later argued with Dr. Cathy Alinovi and Roxanne Stone. Unlucky me, my position at the table for this meeting was right next to ‘the mineral guy’. Because of my close proximity to him…I can tell you exactly what he had for lunch (just prior to the meeting)…because he belched it for the first 30 minutes. I was surrounded by a green cloud of sausage and onions. Not a good start.
The Ingredient Definitions Committee typically has massive amounts of ingredients to define. There is typically more ingredient for livestock feed than pet food ingredients. As example in this meeting ingredient definitions approved were “L-Methionine, Deoiled corn distillers dried grains with solubles, solvent extracted, Bovine Colostrum, Zinc Hydroxychloride”. It is a little maddening (more than a little). We truly need an advocate specific for all of these feed ingredients, as consumer advocates focus mainly on ingredients that can be used in pet food. But they are all important.
During the discussion of Zinc Hydroxychloride, it was mentioned this ingredient could have several other names (didn’t document the other names), but FDA made it clear they would not approve other names for this ingredient. FDA pointed out a Compliance Policy that requests only the original ingredient name to be used on the pet food/animal feed label. The example given was the pet food ingredient Brewers Rice and Chipped Rice. Brewers Rice is a secondary definition to Chipped Rice (original). FDA wants industry to use the original name (in this case Chipped Rice) on labels.
FDA stated they had been working on the future use of the term animal food. They stated the agency believes ‘animal food’ is synonymous with feed. FDA also noted that the term food is not defined in AAFCO. The decision was made to form a working group to work on defining food and animal food.
Also during this trip, I was invited to speak to pet owners at an event hosted by an independent pet food store(s) in Pittsburgh – http://www.healthypetproducts.net/. It was so wonderful to meet consumers face to face. And wonderful to meet the other speakers, who also attended the AAFCO meeting; veterinarian Dr. Doug Knueven (great guy – a vet that understands pet food), Billy from Answers Pet Food, and a representative from Nature’s Variety Pet Food. And a special thank you to Allison of Healthy Pet Products who also attended AAFCO and with Dr. Doug helped us find great food in the evenings.
My 11th AAFCO meeting done. The next AAFCO meeting will be in January in Mobile, Alabama – but, it looks like I will be unable to attend. There is something else that is more important for pet food consumers scheduled around the same time that I have decided to attend instead. More details on that ‘something else’ soon; I’m hopeful many of you will be able to join me at the ‘something else’.
Thanks to all for your ongoing support enabling me to represent you at AAFCO.
Wishing you and your pet(s) the best,
What’s in Your Pet’s Food?
Is your dog or cat eating risk ingredients? Chinese imports? Petsumer Report tells the ‘rest of the story’ on over 4,000 cat foods, dog foods, and pet treats. 30 Day Satisfaction Guarantee. www.PetsumerReport.com
The 2016 List
Susan’s List of trusted pet foods. Click Here
The Other List
The List of pet foods I would not give my own pets. Click Here
Have you read Buyer Beware? Click Here
Cooking pet food made easy, Dinner PAWsible
Find Healthy Pet Foods in Your Area Click Here