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Is it Really just a Wording Problem

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  1. ellie

    Not a day goes by that we do not have to watch our huge ineffective government agencies waste millions in tax payers dollars. It seems they get paid to take up space and block any movement toward progress.

  2. Lynn Utecht

    If I performed this way at my job I would be fired….4-almost 5 years late on getting a task finished? wow…and we pay these people(FDA)….

  3. Debi

    Good job Susan, good luck, we can’t wait for the outcome of this “meeting” with Dr. Dan McChesney, hope it is fruitful, and more importantly, makes a modicum of sense.

  4. BC

    Another eXample of the corporate power in America having the government do their bidding to the determent of “We the People”. For example the US Chamber of Commerence and various other corporate acronyms of the corporate lobbies is pushing the DOJ to make an employees use of a company computer a felony thru the 2007 Computer Fraud Legislation. And we thought that legislation was for bad guy hackers and those stealing our info- I wonder how many of you are aware that they slipped wording into that bill that say for instance, if you were order something on eBay on your work computer it is now a misdemeanor
    Our government hates us and any values we may have- we are a work unit to their benefactors..

  5. Ian

    “It depends upon what the meaning of the word ‘is’ is.” -Bill Clinton

    Susan, thanks for trying to understand this and follow through on it. From what you’ve written so far, it does seem like a bid by the industry to write their own definitions and standards… the fox guarding the hen house again. Appreciate your work as always shining the light of day on these issues in a public forum.

  6. Roger

    I am a retired federal agency attorney and practiced administrative law all my career. Congress passes law but then it is the administrative agency, in this case FDA, that has to implement the law by writing regulations governing how the law is defined and administered. Frequently Congress places time limits in the law for implementation but then does not fund the agency with enough money to implement the extra work created by the law. I did not work for FDA, but my guess is that they are seriously understaffed and underfunded, like most agencies. I was working 10 hour days, 6 days a week, and my agency wanted me to come in and work on Sundays also. Instead of having a heart attack from work, I retired. I don’t think the delay is the FDA’s fault, it is probably due to the cut backs from Congress, particularly the sequestration. That being said, the FDA accepts comments on proposed regulations from everyone, industry groups as well as individuals. I think the problem is with the wording in the law Congress passed. It is not written very well and their choice of wording, ingredient standard, leads to confusion, which the FDA must sort out. The wording implies that there is an ingredient standard, which does not really exist under the law. Hopefully, the FDA will not cave and accept what industry wants. It is good that they hear from consumers and concerned pet owners as well.

  7. Buck

    Without wishing to sound arbitrary or capricious, this matter is an issue of priority within the FDA. The FDA Administrator sets the priority. If this problem was a top priority, the Administrator would use existing resources (time, money and people) to produce the solution. Whether underfunded and or understaffed does not negate the fact that we are still waiting for the fix. The FDA has failed to produce the solution regarding pet food standards and pet food ingredient definitions and this is particularly egregious when one takes into consideration the Act was passed in September 07 and the FDA had until Sep 09 to complete. We would all do ourselves well by contacting our elected representatives and ask them to get involved with producing a solution this to problem.

  8. Ann

    This jumped out at me:
    “AAFCO strongly supports this legislative effort and urges your support as well. Otherwise, the development and introduction of new feed ingredients to the marketplace will become even more burdensome and likely jeopardize AAFCO’s production of its OP.”

    It suggests that feed ingredients under development and introduction (like feathers, GMO, higher antibiotic levels, who knows what else for example) are perhaps being delayed from marketing by the lack of clarity or conflicting language surrounding standards and ingredients. The legislative fix is certain to pave the way forward for the feed industry to increase profits with their “innovations”, likely to the detriment of the consumer and pet. The legislative fix is also likely to limit the corporate liability from any future harm caused by the feed ingredients. It will have to be closely read and monitored thru the legislative process to prevent last minute changes from being added.

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