Four Years Later, FDA Rejection Letter to Consumers
Four years ago, pet food consumers filed a Citizen Petition with FDA basically asking the agency to enforce the law (law the agency is already supposed to enforce). It took them four years, but they finally gave us their response. They said “No“.
For pet food consumers, one of the most difficult to understand actions by FDA is the agency allowing pet foods (pet feeds and all animal feeds) to violate federal law. For a federal agency – a tax dollar supported federal agency – to openly allow big industry to profit from legal loopholes provided by said federal agency (to violate federal law), it’s a bit difficult to swallow (no pun intended). And to top it off, to allow big industry the opportunity to violate those federal laws while making consumers believe all pet food products are legal – that all pet food manufacturers are abiding by law – well, it is impossible to understand.
The laws are the Federal Food, Drug, and Cosmetic Act; the very laws the FDA are assigned to enforce. The violations of law that FDA provides the pet food (feed) industry allowing wastes – such as meats from diseased or euthanized animals, chemical or pesticide contaminated foods – are provided via numerous FDA Compliance Policies. These FDA Policies were intentionally written by FDA administration to give the animal feed manufacturing industry the privilege to bypass the law.
So, four years ago consumers used the only official tool available to ask the FDA to please enforce the law, to stop allowing pet foods/treats to contain meats from diseased or euthanized animals. We sent them a “Citizen Petition” – which was received by FDA on August 5, 2010. And yesterday July 14, 2014 – almost four years later – the FDA gave us their response.
The FDA’s response to consumers: “this letter is advising you that FDA is denying your petition without prejudice.”
In other words, the tax supported government agency refuses to enforce the federal laws their very existence was developed to enforce AND they will continue to allow pet food manufacturers the opportunity to use illegal ingredients – violate federal law – without informing consumers which pet foods/treats are using illegal ingredients.
The last paragraph of this FDA response to pet food consumers is the most absurd…
“Your request for FDA to consider any pet food/treat manufacturing sourcing ingredients from “dead stock” renderers and/or USDA rejected meat or meat products or “4-D” animals (rendered or otherwise) to be adulteration high risk, requiring frequent FDA inspection and burden of evidence of compliance from the manufacturer, is denied because your petition does not provide sufficient data and information to support this request. Therefore, we believe that this requested action is not warranted at this point in time.”
Actually, we provided FDA the perfect “sufficient data and information” – we provided them federal law.
One last sentence from the FDA rejection letter: “Furthermore, decisions with respect to enforcement actions are generally made on a case-by-case basis and are solely within the discretion of the Agency.”
I interpret this as FDA stating they will continue to do what they want to do, it doesn’t matter what pet food consumers think, want or deserve.
FDA, you can reject us time and time again – but guess what? We are never going away. We will never stop fighting for our pets.
Wishing you and your pet(s) the best,
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