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Pet Food Consumer Input Requested

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Comment50

  1. Madeleine

    I want to be assured that the food I feed my pets, whether canned or bagged, is safe from toxins, and any and all risk ingredients that will affect the health of my cats negatively causing disease which is often heart breakingly fatal and which causes unnecessary expense which I and many can ill-afford.

    I want the foods I feed my pets to be grown here, processed here, and packaged here not China, a country which has proven ill-suited for this. They have continually been the source of foods causing our pets’ ill health ending in their avoidable deaths.

    I want honest and independent oversight of the Pet Food Industry by concerned private citizens with no connection to the industry and I want those people to be rotated often to assure that there is no connection. And I want our input to be taken seriously as we are the real experts about what our pets need and the payer of the vet bills that sick animals incur.

    And I want no less than what is stated above. The Pet Food Industry has their bottom line in mind. I have my cat’s health in mind.

    Thank you,
    Madeleine Fisher Kern

  2. jb

    I want TRANSPARENCY!

    Just like what I buy for myself, I want to know the SOURCE of ingredients & the manufacturing process.

    I am sick & tired of inferior ingredients & questionable sourcing, not to mention the GMOs & carcinogenic oils/ingredients used in food.

    I am doing what I can to feed my companions using “humane grade meats”. It is not enough! The mainstream grocery store meats are garbage. But, it is superior to what is found in commercial pet food.

    I have posted this article to my Facebook in hopes of feeding Susan with ammunition.

    Thank you Susan for all your hard work. It is appreciated.

  3. cathy

    I expect pet food to nourish my pet’s body with quality ingredients and no harmful ingredients.

  4. Judi

    I want to know the origins of the contents of the dog food ingredients. For example, it isn’t enough for me to just read “salmon meal” on the list of ingredients. But, from what country is that salmon meal? I want to know where each of the ingredients come from, right beside each item. There should be no “proprietary” ingredients that are not disclosed.

  5. MARY LEE OLIPHANT

    I WOULD LIKE TO SEE CARBOHYDRATE CONTENT % LISTED ALONG WITH PROTEIN, FAT, ETC.
    I WOULD LIKE TO SEE ANIMAL PROTEIN SEPARATED FROM PLANT PROTEIN.

  6. Dennis Matejka

    Pet food must be safe, safe from chemicals, fillers, anything from China. It must be nourishing and contain all the recommended nutrients needed for a healthy meal. It must be safe around children should they get hold of it. It must be non toxic to humans if ingested by humans. It must contain the proper balance of vitamins and minerals and have natural preservatives. Honest labeling, complete and country of origin of all ingredients. On another note, I will never buy pet food that contains anything from China or any foreign country.

  7. Roger Rittenhouse

    As a retired federal attorney, I know that regulations are only as strong as the penalty consequences for failing to follow them. If regulations set a standard that must be met but do not provide a remedy or penalty if the standard is not met, then there is no incentive for industry to meet the standard. My concerns as a consumer are what can be done to enforce the standards of the act and who has the power to enforce the standards. Is the government the only entity that can enforce the regulations or are consumers allowed to sue for enforcement if the standards are not followed. Also, what are the penalties for failing to follow the standards? Forced recalls of the products? Consumers suing for damages? My guess is that AAFCO wants the weakest possible penalties and the smallest possible consequences for failure to meet a standard, while consumers want stronger sanctions. Due to budget constraints, there are way too few food inspectors for human foods and I doubt the government is willing to hire more inspectors to expand them to pet foods. I personally don’t trust many pet food companies to do their own inspections. As a consumer, my concerns would also go to how independent and impartial any inspections will be. Let’s face it, AAFCO is a industry oriented group and not a consumer oriented group, but if they truly have nothing to cover up they should theoretically be for independent and impartial inspections.

    1. Christine

      I second this! The fact that FDA even states that some (very ugly) violations are not actionable is egregious

    2. TJF

      Very, very good points and its obvious that you are an attorney and have a good grasp of how all this stuff works….thank you so much for adding your comments to this, because in reading them, I learned something about the ins and outs of this industry and why things happen as they do.

    3. Amanda

      Yes. Exactly my views as well. I need to know that if companies violate standards, mislabel, falsely advertize etc that they will be called out, reprimanded and be monitored during their process of rectifying the situation. There needs to be FDA involvement in enforcing these rules!

      I personally think that all ingredients should be species specific. No “meat” or “poultry.” I also think that each ingredient should be specific in what part of the body it is, so we can do away with the whole term “”by-product.”

      I also think that there should be the same rules or regulations when it comes to claiming that a food or treat will treat or improve an illness. I’m sick of seeing “prescription” foods that say they treat diseases yet have nothing approved by the FDA to do so in their ingredients. I’m also sick of all the so called tartar control treats or food that make loads of claims and have zero evidence to back them up. I would like to see pet products labeled and advertised to the same standards as human products when they claim to treat or cure an illness.

  8. Kelley

    What are my expectations regarding the implementation of the Food Safety Modernization Act with pet food!?

    Dear FMSA Committee Chairperson.

    I shouldn’t even be asked this question. Whatever input I have, or a 1000 other consumers have, will continue to be ignored and dismissed. The changes I want I shouldn’t have to be made in the form of a “request.” What I WANT, which are quality and safety improvements, should be an expected standard implemented by the government which is tasked to protect and serve the public; meaning there be an intention to generate a norm that becomes an established “best practice.” But because pet food is BIG business, then no matter what the consumer “wants” is dwarfed by the pet food industry’s political (lobbying) influence. Responses from those in charge of this modernization act will conclude the following: that consumer requests are unrealistic, unnecessary, impractical and too expensive.

    Therefore my summary response is this: If the government is going to “modernize” food safety then it has decades of catching up to do, and the changes better be significant enough to last through the next decade! Or the effort and expense undertaken will be a waste! Understand that pet food consumers are informed and experienced when it comes to pet food defects, and the effects on their animals. So respect their input, and respect the pet food advocate (delivering this information to you) who is even far better informed and experienced, and who only wants to do the right thing for all concerned. Unbelievable as it seems, this pet food consumer advocate, does not work for any profit or publicity gain.

    Below is the short list:

    1. Compliance Policies are in violation of the FD& C (Federal Drug & Cosmetics) Act for any food. Don’t allow pet food (PF) to be exempt when implementing the FMSA (Food Modernization & Safety Act).

    2. No business (annual revenue threshold) should be exempt. Risk at any level is risk and defeats the entire plan.

    3. If the FDA (Federal Drug Administration) is truly guided by FMSA and FD&C Act there should be no difference between rulemaking of animal food and human food.

    4. Furthermore pet food (for dogs and cats) should be categorized more stringently than “livestock feed.”

    5. This is because PF is used in a household, along side human food, by consumers who are at risk whenever the product is improperly handled, or whenever they are exposed to significant manufacturing mistakes and quality lapses.

    6. Warning labels and safe handling labels need to be part of packaging.

    7. The category of “waste” currently used in PF must be redefined to exclude material that is not nutritious, and which can be hazardous, especially when improperly finished (such as the failure of high heat processing).

    8. Refrigeration (including transportation & storage) must be implemented to protect perishables and to retard degradation of ingredients (particularly on a seasonal basis).

    9. Mycotoxin toxicity (obtained from poorest quality grain, when impossible to prevent) as a danger threshold must be recalculated from PPB per individual serving to the effect of accumulating (bulk) toxicity from on-going, recurring (daily) dietary ingestion, and also upon pets who have particular systemic weaknesses.

    10. Until 3rd Party ingredient suppliers are equally regulated, PF manufacturers must be held accountable for all ingredients, and disallowed from “passing the buck” of responsibility and liability to a subsidiary party.

    11. The manufacturing company (including co-packer) must be accountable to implement preventative controls implemented by FMSA (and made to adhere to all regulations) to demonstrate the facility (including transportation and employees) are in compliance.

    12. All Veterinarians should be motivated and incented to report suspected pet food related illnesses, and for the intention of on-going enforcement practices.

    13. The FDA must acknowledge (for the purposes of drafting FMSA Regulations) that manufacturers could introduce (either intentionally or not) risk product hazards that are potentially motivated by financial gain.

    1. jb

      Well stated Kelly! Honesty is the food industry would solve a tonne of medical issues today for people & our companions.

  9. Kenneth

    If I was still buying pet food (It’s too late for me now, feeding raw and never going back), I would like to see full HACCP implemented all though the chain of pet food manufacturing, including all outsourced companies for any ingredient, with all documentation of inspections including any violations being publically available online.

    If you don’t know HACCP look it up on say, wikipedia.

  10. Suzy

    I want what is listed as ingredients to match what is in the bag. (This is referring to the Chapman’s University protein DNA test that shown what was advertised did not match what was in the bag.) It is sickening that pet food companies can advertise something to be 100% turkey but really it is beef or pork or chicken.

    1. Christine

      This is a very important point. Consumers whose pets have allergy issues/food sensitivities rely on these companies for ingredient panels that are true. If other ingredients are found, this should be an actionable offense, and the public should be notified.

    2. Sage

      Suzy – I totally agree of course that the ingredients written on the label should be exactly what is in the package and nothing else.

      I think it is outrageous that pet food PACKAGING can depict photographs or illustrations of gorgeous meat and poultry and beautiful fresh fruits and vegetables when nothing close to the package IMAGES is actually in the package. Obviously it stands to reason the pet food manufacturer isn’t actually grilling that meat or chicken BUT they should NOT be allowed to depict it using an image of grilled meat and they should not be allowed to state on the package that it is grilled or to make any of the other false advertising claims that appear on the package and in digital and print promotions. Why are there no laws against this?!

  11. Suzy

    This will never happen but I would like to see the real nutritional value. For example, crude protein is composed of digestible protein (muscle meat, etc) and non-digestible protein (feather, etc.). Non-digestible is useless to an animal.

    When I was looking for a new food to feed my cats, I contacted various companies asking how much of the crude protein was digestible. Some companies refuse to answer but others did and their responses was anywhere from low 40% to low 90%.

  12. Debi Cohen

    Wonder why pet food isn’t being regulated honestly like it should be, why do the big corporations insist on harming our pets through the food that they consume? pet food companies should want to create healthy fare so that our pets could be sustained for a longer time, many people that lose an animal because of poisoned pet food ingredients decide never to acquire another animal………….ever, so, that would mean a loss of income for any company that serves up, either ingredients from China, or moldy, aflatoxin, mycotoxin and salmonella riddled food, to name only a few poisons, from this country or any other. Get real and get honest and give us some decent regulations that you will follow, adhere to and let us know that this is true by the health of our pets for many years going forward.

  13. Debbie

    The six previous comments cover it all, especially the problem with products from China. I believe Chinese manufacturers are only concerned with obtaining our dollars without regard for the health and well-being of our pets or their owners. If I know a product is from China, I don’t buy it.

  14. Carole Cerase

    I want to be sure the food I am giving my pets does not come from diseased or contaminated food sources. I also want to know where these ingredients are from, not just who distributes them. I just want the truth. I believe I am adult enough to make my own decisions given the whole and truthful facts. I want the FDA to abide by and enforce all of their rules and regulations for every manufacturer and make public all findings.

  15. Marsha

    I would like what is on the front of the bag to be the full truth. Meaning if it states “Grilled Chicken” as the pictures show, then it should be there. Quit portraying items on the front of the bags, cans and however it is packaged. Remove all lies on the front of the package and commercials.

    Also remove beet pulp and tomato pomace!

    I also want proof that diseased or contaminated food sources are not used or anything from China! I do not even buy toys from China anymore. I have no idea what is actually in them that could harm my pets.

    Everyone else has stated what I would like to see done int he Pet Food Industry.

  16. Christine

    Step one of any food safety measures should be to enforce rules that are already written, both AAFCO and FDA. Second, ingredients should be food grade, not feed grade, or labeling must clearly reflect the difference. I’d like to eliminate the practice of disallowing statements on the label that reveal the quality of the ingredients (companies using human grade ingredients/approved for consumption by humans/USDA inspected and approved should be able to say so)

    1. B Dawson

      Remember that States can chose to accept and follow AAFCO guidelines or not and AAFCO has no regulatory authority. In my opinion, AAFCO has it’s own set of issues as it is very biased against supplements such as glucosamine and herbs. That is unlikely to change now that they have a formal relationship with the FDA.

  17. Lorraine

    All the previous post just about covers what I would like to see done. We need safer commercial dog food products and we need to know what’s in the dog food and where it come from. If ingredients come from China, we have a right to know that. No more BS of “Made in the USA” when the ingredients came from China.

  18. tascha

    hTs is in reference to section 402 of the FD & C Act-2. How is it legally possible to provide Compliance Policies and not uphold them? In doing so, this is in direct violation of its own laws of the FD&C Act, in regards to pet food, s per CPG Sec.675. 100, CPG Sec.675 200, CPG Sec.675. 300, CPG Sec.675 400 and CPG Sec 690. 300. If pet food contains contaminants, all contaminants should be listed on the pet food label. Consumers have the right to know what they are feeding their pets, as they are subject to become ill, as do humans. Our pets are family. Would you knowingly feed your family contaminants? I think not. As a consumer, I want a choice. I want to know where the ingredients have come from, if those ingredients are contaminated, and if they are upheld to the laws and regulations that are given to human food, so I can make my own choice as whether I would feed this to my animal. I have a cat in renal stage failure and it is imperative that I know what I am feeding my cat so as he can live a long, healthy, pain free life. The quality of the food and the ingredients in each and everything I feed him? is of the utmost importance, to me and the health of my animal! Thank you for allowing me to share my point of view and comment on this very important law.

    1. MK

      It’s time consuming, but I cook all of my dog’s food because he is in congestive heart failure and there are not any commercial foods targeted to low sodium diets. I wanted more control of what he eats so I do the best I can with preparing his food. He looks wonderful now.

  19. tascha

    I just spent 45 minutes writing a wonderful post for this very important matter and I do not see it published on this page. Is there a delay in the time that I posted it and it will show on this page?

  20. Marsha Browne

    I want complete transparency in all ingredients and manufacturing processes of all pet foods. I want to know where every ingredient is sourced including the country of origin (if not USA). I want to know the grade of meats are that go into my dog’s food. I want to know if there are any inspections of the products and produce that go into my pet’s food by a governing body or independent body. I want to know where all produce is sourced including the presence of GMO’s, chemicals, insecticides, fungicides, etc. or if it is produced organically I want to know the country source. I would like to know if the supplements that are added into pet foods are synthetic or food-based and also free of GMO’s. I want to make manufacturers responsible for any and all toxic or over-supplementation ingredients and for manufacturers to try to use third-party labs to sample their ingredients to make sure nothing is harmful. If manufacturers find a product that is toxic or even potentially toxic, I expect them to inform the PUBLIC over all media sources so pets will not be unduly harmed in any way! I want all pet food outlets to IMMEDIATELY REMOVE ANY AND ALL RECALLED PRODUCTS! And I want the health of pets to be of the same importance as any other sentient creature and companion animals. I also want a larger variety of sources for pet foods and different price points as everyone cannot feed their pets at the same economic level! I expect nothing less from my pet food than I do from my own food. I would also like to make it easier for locally-owned producers of meats, milk, etc. to be able to market their products to the PUBLIC without excess regulations from such agencies as the FDA, Agriculture, etc. who are in charge of food rules. Because my ability to source raw foods and products for my pets has gotten so restricted it’s ridiculous! I also want funding for this as I have said before this is just as important as my own food sources! Thank you for your consideration.

  21. Jessica

    I want to see –
    *packaging that reflects what is really in the bag or can
    *clear ingredient definitions
    *risky ingredients should be elimanated
    *GRAS means nithing to me
    *COO displayed publicly whether on packaging or company websites
    *swift action when a problem is reported
    *Mandatory testing of foods and ingredients by an outside company and/or FDA with results made available to the public
    *Unannounced inspection of foreign companies/plants that ship their ingredients here, if you have to schedule an appointment t perform an inspectio that shoul raise a red flag. We do not need to do business with companies like that
    *Companies with a history of problms thoroughly investigated before any of their prducts return to the market. Violations need to impact their bottm line if their behavior is ever to chane.
    *Stop allowing waste to be made into “food”
    *Enforcement of all rules, why have them if you do not plan on enforcing them
    NO ONE SHOULD HAVE TO WORRY ABOUT WHAT THEY FEED THEIR ANIMALS!
    Thank you Susan for helping our voices be heard.

  22. Ann Vanderlaan

    1) Country of origin for all ingredients
    2) Country of preparation for all ingredients
    3) Guarantee of drug-free meat ingredients
    4) Elimination of blanket terms like meat meal when you mean spoiled, ground up roadkill, slaughter offal, or diseased animal parts.

  23. dana sanders

    Plain and simple…my pets are my family.I want to know that what I give them is no less than what I would feed the other members of my family. 🙂

  24. Al

    Obviously, revisions to the FSMA is being pushed by the AAFCO. What are the revisions requested and why the need to revise the ACT? This consumer want to see the FSMA implemented now as the pet food industry has stalled long enough.

  25. Deborah Kaeder-Carpenter

    First I’d like to say that all of my comments and concerns mirror those of Susan’s. I wouldn’t have been able to draft this list of comments without all of her hard work on behalf of our pets.
    Pet food should be classified as “food”, not animal feed.
    It should have the same safety standards in every way as human food, same rule makings.
    All manufacturers, small and large, selling commercially should be required to have record keeping accountibility.
    All manufacturers food storage facilities should be required to uphold good manufacturing practices, hazard analysis, and risk based controls.
    No exceptions should be allowed to section 402 of the FD&C act.
    Do not allow potential hazards which are intentionally introduced for economic reasons
    When a consumer returns a fetfood to a retailer due to pet illness, the food should be held for testing, and a The FDA should take significant consideration to animal health, such as foods that provide quality nutrition not “adequate” nutrition.
    Pet food labels should be written in the same nutritional label as human foods.
    “waste” should not be allowed in pet food.
    No exemptions. All pet food should be required to include co-packer information on product labels.
    FDA must not allow manufacturers to self police. 3rd party inspection services must be properly certified.
    Company contact information & country of origin & where the product is manufactured should be clearly stated on the label. No products or any type of supplements sourced from China should be allowed.
    All raw materials should be inspected and no contaminants should be allowed.
    No silent recalls allowed.
    There should not be selective enforcement of section 402 of the FD&C act. All should be enforced.
    Everything in the food should be required to be on the label, including additives.
    If a picture of the food is on the label, it should accurately portray the food that is in the package.
    There should be regulatory maximums established for protein, fat, & many vitamins & minerals in pet foods.
    The FDA must enforce the laws that are written. The practice must end of consulting groups being made up of industry insiders with only only one agenda: profit.

  26. Andrea

    I believe that I have the right to know the country of ORIGIN of ALL ingredients in the food I feed to my animals, not just the country of manufacture. I also strongly believe that diseased or rotten meat and moldy or otherwise spoiled ingredients have no place in pet food. All ingredients should be fully disclosed. If it states on the label that the protein source is rabbit, it should be rabbit and not chicken, beef, or whatever.

    In other words I would like to see, full and honest disclosure of all ingredients, quality control, stricter regulation, and enforcement.

  27. Chris

    I expect all pet food to be manufactured to human grade standards of consumption and sourced with zero products from China. They should be manufactered in facilities also meeting those of human grade consumption. All pet food should be tested by third party companies with no ties to manufacturers or their suppliers and with the rigor and frequency as those of human grade food.

    Listings of all ingredients no matter how small should list every country(country of origin) they are sourced from on the packaging. Location of manufacturing should be listed on the packaging. Manufacturing company should have direct web address listed to specific page on all packaging where all violations of their products must be listed and retained for a rolling 10 years. No silent recalls should be allowed.

  28. Dawn Munson-Detloff

    I want my pet food to be HUMAN GRADE ingrediemts. Not second or third hand or even worse. Not ingrediemts that have no nutritional value. Not moldy grain that once ingested, the liver cannot get rid of the aflotoxins, and will lead to liver cancer, or worse, will kill my dog quickly. Or meat that has been peutrified. Or chicken feathers. If food has gone bad, instead of still trying to make profit by feeding it to our pets, or livestock. THROW IT AWAY, In fact, I’d like pet food to be superior human grade. Organic, with no GMOs. Their bodies are smaller, most the time, and they can’t handle the toxins. If I knew what I know now, my dog would still be alive. And what’s with the vetenarians pushing this toxic food. Sick pets are more profitable I suppose. I am so thankful to Susan Thixton for her work. It’s time we honor our animals, they are great spiritual beings that quietly help us through life. They deserve good, honest, fresh, nutritious food. E:x

    1. Dennis Matejka

      WOW, You couldn’t have said it better. I want all the same things for pet food. And you’re right about vets and pet food, they don’t care. Human grade is what I want for my best friend.

  29. Tryniti

    1) No more food from China. Period.
    2) Information about how healthy the food actually is right on the bag/can. (Look up “Old Yeller” dog food. That should NEVER be allowed)
    3) Cat food kibble needs to be transparent about how little moisture it is providing to cats, which descended from desert animals who EAT their moisture. All these people with cats who have FLUTD don’t know that if their cats simply had more moisture in their diets they would not be sick.

  30. TJF

    I, as a concerned pet owner, want what everyone else here wants: high quality, human grade foods for my pets that are safe, that pass an HONEST, third party inspections and contain nothing that will make me or my animals sick.

    In addition to all the other concerns voiced here, I have three pets and have, for a long time, put their china and pottery dishes in my dishwasher with my own china, glassware and silverware.

    Upon reading Susan’s findings, I will have to separate their dishes and wash them separately by hand, in fear that I could be exposed to salmonella, or god knows what. Even though, when I asked my VET if this combined washing was ok, he said ” oh sure, not a problem.” And he is a very high end vet with a 25 year, very popular practice.

    But this contamination factor due to unsafe food practices in animal food has been all over the newspapers for a very long time, so its not new. We just now have it from a source that has no hidden agenda to sell anything.

    The whole pet food industry has to be based on TRANSPARENCY….and up until now, its obvious that they are not being honest or are spinning things to sell their products. Over the years and all the bad things that have happened, it is to the point where people don’t TRUST Big Pet Food and Big Ag, and when it hits them in the wallet, maybe they will pay attention.

    Thank goodness I never, at least at this point, lost a pet to poisoned food, but my last two dogs died of cancer, although given the better pet foods, so who knows how long they would have lived if their food was REALLY high quality and products we could really TRUST.

    I know that Big Pet Food’s concern is that if they give us these products the price will skyrocket and no one will buy their products….but I think that their checks and balances should at least come up to human standards that we have now, for humans.

  31. Sydney

    Had an emergency C-Section Saturday and missed this. 1 day notice?

  32. Linda Melichar

    I would like to have the Pet Food Industry produce pet food that respects their consumers desires to have their pets live a long healthy life. The Pet Food Industry needs to keep in mind that without us their business will close. I for one will not trust a pet food that has been proven to be harmful ever again. I share all details about recalls, proven harmful ingredients, etc., with my FB friends & family. I print out reports & mail them out to Vet Clinics in the hopes that they will post the information and warn their customers. I don’t understand how the Pet Food Industry fails to knowledge the value we place on our pets. Today it is so easy to research what they are doing & failing to do. I have crossed many off my list & I’ll never use their products again. I’m also a person who does not trust anything FDA approves! Pet Lovers are taking a stand to protect their LOVED ONES & the Pet Food Industry would be wise to take notice.

  33. foodguy

    I’ve had the pleasure to speak with an active AAFCO President in the past. Unfortunately, he cannot enact any of the changes, nor answer any of the questions you will be asking- at least not in actuality. He might provide a response- but unfortunately he is nothing more than a figure head to an organization that does not accept a single modicum of responsibility for anything that happens, or doesn’t happen, within pet food.

    Unless we hire lobbyists, and spend millions of dollars targeting specific individuals (him NOT being one of the people), there will be no change. If there is change it is simply for their convenience, not for a positive affect towards all of our end goals for pet food.

    Good luck.

    1. DENNIS MATES

      So you had the “pleasure” of speaking to AAFCO president. How pleasurable was it talking to an empty suit who will not change the pet food industry. Any pet food company who misleads or puts un healthy ingredients in pet food should be made to eat the same garbage they sell as pet food. My dog is my best friend and you don’t want to mess with either of us.

      1. foodguy

        Clearly, you do not understand the sarcasm presented with the word pleasure…

      2. jb

        I often wonder WHAT big wigs at Monsanto, Dow, DuPont, FDA, Dept of Agriculture eat.

        Do they really eat the toxins they create & endorse?

        Are they really that ignorant?

  34. Maxine Schmidt

    I want to see source ingredients as well as where the product is made. I want pet food to be human grade quality and the nutrition values and what they are from clearly placed on each bag of food (i.e. chicken breast rather than chicken meal). I don’t want to lose another dog at 4-1/2 yrs. old to lymphoma because the food I provided to her poisoned her. In other words much stronger control of what is put into the dog food. I want to be able to trust the manufacturer that the food I put into my dog’s bowl to be food of a quality that each AAFCO representative would be comfortable if picked off the shelf and put into the bowl of their own animal, and be comfortable with their animal eating that food for a month or more.

  35. Geff R.

    I haven’t studied this closely since the big recall, so this will be a general statement:

    Pet Food should be held tp at least the same standards as human food (probably higher, since most pets aren’t as intelligent as we supposedly are, & would likely eat food that is in a condition that a person wouldn’t.)

  36. Jane Eagle

    Under Background – “A. Current Approaches to Animal Food Safety 2. Section 402 of the FD&C Act – 2.” All of the Compliance Policies listed below are in violation of FD&C Act for any food.
    CPG Sec. 675.100 Diversion of Contaminated Food for Animal Use
    CPG Sec. 675.200 Diversion of Adulterated Food to Acceptable Animal Feed Use
    CPG Sec. 675.300 Moisture Damaged Grain
    CPG Sec. 675.400 Rendered Animal Feed Ingredients
    CPG Sec. 690.300 Canned Pet Food
    These FDA Compliance Policies remain a violation of federal law and FDA HAS NO AUTHORITY to pick and choose which laws it enforces. If FDA truly wishes to improve the safety of animal feed/pet food, the FD&C Act should be enforced as it is written.
    FDA should not pick and choose which food safety law it enforces.

    If the Food Safety Modernization Act applies “food” to include animal food and the FD&C Act defines “food” to include food for animals, how can FDA conclude there are any differences between human food and animal food? If FDA is truly guided by FSMA and FD&C Act (instead of acting independent of law), there should be no differences between rulemakings of animal food and human food.
    ” Many pet food consumers pay high prices for specialty foods to address the allergy needs of a pet. Should one of these allergy foods contain an ingredient not listed on the label, the food should be deemed adulterated as in human foods.”

    And, for example, a few years ago, I had a dog in liver failure. My vet prescribed Hill’s Science Diet for him. I read the ingredients, most of which are GMO, which have been shown in animal tests to CAUSE liver failure. WHY IN THE WORLD ARE PET FOODS ALLOWED TO PROMOTE THEIR PRODUCTS AS DRUGS???

    If the FDA insists on allowing products made with FD&C Act illegal ingredients (such as rendered animals that died other than by slaughter or euthanized animals), these products should be required to provide a SPECIFIC warning statement on the label for the consumer. i.E.: THIS PRODUCTS CONTAINS EUTHANIZED ANIMALS or whatever specifically is allowed in the ingredients.

    Under Background “Section C FDA Food Safety Modernization Act, Item 2 Requirements for Agency Rulemaking, subsection f” “…The Agency also requests comment on when an economically motivated adulterant can be considered reasonably likely to occur.”Please: businesses mostly tend to be greedy, and willing to make money by any means possible; ESPECIALLY if allowed by law! Perhaps I am mistaken, but the vast majority of American taxpayers/voters are under the impression that the FDA’s sole purpose for existing is to protect us from corporate greed in our “Food”s and “Drug”s and to make sure that the products we are buying are as free from harm as possible. Any inclusion of any adulterant should be prosecuted to the fullest extent of the law! And in that spirit: when a pet food is believed to make a pet ill, the consumer returns the food to the place of purchase for a refund. It should be required that all pet food retail outlets – when a food is returned due to a pet illness – report every incident to FDA with customer details and hold the food to be tested.

    Proposed 507.1(d) refers to “waste” from human food facilities. ““Waste” that is USDA inspected and approved is welcome in pet foods; rejected for use in human food “waste” should not be allowed in pet food. Proposed 507.1 (d) should reflect allowed “waste” to be only USDA inspected and approved.” And since neither cats nor dogs can digest grains, all grains should be considered “waste” or at best, empty filler.

    As I was going through this, I realized I was flagging the same issues over and over; so here it is, in a nutshell:

    First and foremost, I demand safety in pet foods; and since they are handled on my kitchen counters, that apparently must mean HUMAN GRADE FOODS ONLY.
    Due to foot dragging and outright obfuscation by pet food manufacturers and regulatory agencies, anything less will mean continued danger to myself as well as my pets.
    What, then, is the point of the FDA?
    NO business should be exempt from OUR safety laws.
    ““Facilities solely engaged in the storage of packaged animal food that is not exposed to the environment.” must be held to the same high safety standards!
    OTHERWISE, WHY EVEN HAVE AN FDA OVERSIGHT IF PRODUCT SAFETY HAS LOOPHOLES? We could save a lot of tax money but cutting back an FDA that does not do the job we pay it to do.
    I am already getting the picture that all these “regulations are nothing but loopholes, exceptions, and negligence.
    One alternative to the FDA having to actually do the work is to simply require that all pet food which is not human grade food, carry a warning label, similar to that on cigarettes, notifying consumers that the “product may contain diseased components, dangerous pathogens and fungal contaminants, which are a health risk to humans and pets”.

  37. Sage

    According to a February Food Safety News article
    http://www.foodsafetynews.com/2014/02/lawsuit-brought-against-fda-regarding-food-additives/#.VLoHZUshuME
    FDA doesn’t properly regulate GRAS Human Food additives and because of that they are being sued by the CFS / Center for Food Safety. The last sentence sums it up and could also apply to PET foods
    “It has been 15 years since FDA handed authority to determine GRAS status over to the corporations it is meant to regulate,” said Andrew Kimbrell, CFS executive director. “FDA has an obligation to provide the regulatory scrutiny the public deserves.” Maybe a class action suit by consumers for failure to enforce Pet Food regulations (examples as pointed out by Jane Eagle, above) would encourage them to simply enforce the regulations that are already written.

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