FDA and USDA recently announced a “formal agreement to bolster coordination and collaboration” between agencies. With the formal agreement, FDA should have no problem coordinating with USDA regarding human grade pet foods manufactured in USDA inspected human food plants.
Most consumers are not aware that sister federal agencies USDA and FDA rarely ‘talk’ to each other. Each are keenly aware of the other’s ‘turf’ (jurisdiction) and they don’t cross the line into the other’s turf (they don’t talk about the line, they don’t even look at the line). These sister agencies were sort of like family…family that only sees each other at Christmas (and even then isn’t happy about it). This was a problem in food safety – and, part of the problem with the challenge to Human Grade pet food.
The definition to Human Grade pet food was challenged – basically – based on the previous ‘family’ history between USDA and FDA. The challenge presented complained of jurisdiction, that pet food falls under FDA jurisdiction but because Human Grade pet food was/is currently required to meet the same laws governing human food – manufacturing fell under USDA jurisdiction.
Add another ‘family’ member to the regulatory oversight of pet food – State Department of Agriculture. FDA is in communication with the State authorities, but USDA was/is not. Pet foods manufactured in a USDA facility (either human grade cooked foods or raw pet foods made when inspector is present) became a sore spot for State Department of Agriculture because of respecting jurisdiction.
But now…maybe…the regulatory ‘family’ are going to start to talk with each other. Work together. FDA and USDA have filed an official Memorandum of Understanding agreement.
From the FDA press release about the agreement:
“U.S. Agriculture Secretary Sonny Perdue and FDA Commissioner Scott Gottlieb, M.D. announced at the White House today a formal agreement aimed at making the oversight of food more efficient and effective by bolstering coordination between the two agencies. The formal agreement outlines efforts to increase interagency collaboration, efficiency and effectiveness on produce safety and biotechnology activities, while providing clarity to manufacturers.”
“This agreement is the agencies’ newest initiative to expand those efforts and take new steps to streamline regulatory responsibilities and use government resources more efficiently to protect public health. It aims to increase clarity, efficiency, and potentially reduce the number of establishments subject to the dual regulatory requirements of the USDA and the FDA. For example, when a facility, such as a canned soup facility, produces both chicken noodle soup and tomato soup, it is currently subject to regulation by both agencies. The agreement tasks both government organizations with identifying ways to streamline regulation and reduce inspection inefficiencies, while steadfastly upholding safety standards for dual-jurisdiction facilities. This can reduce costs on industry and free government resources to better target efforts to areas of risk.”
For pet food consumers that are concerned about the potential changes to the Human Grade pet food definition/requirements, a segment provided in the agreement itself explains the jurisdiction of USDA and FDA. This should be sufficient evidence for AAFCO that USDA is the proper governing authority for Human Grade pet food:
“FSIS (stands for Food Safety Inspection Services, division of USDA) is responsible for implementing and enforcing the Federal Meat Inspection Act (21 U.S.C. 601, et seq.), the Poultry Products Inspection Act (21 U.S.C. 451, et seq.), and parts of the Egg Products Inspection Act (21 U.S.C. 1031, et seq.). In carrying out its responsibilities under these acts, FSIS places inspectors in meat and poultry slaughterhouses and in meat, poultry, and egg processing plants. FSIS also conducts inspections of warehouses, transporters, retail stores, restaurants, and other places where meat, poultry, and egg products are handled and stored. In addition, FSIS conducts voluntary inspections under the Agriculture Marketing Act (7 U.S.C. 1621, et seq.).”
“FDA is responsible for implementing and enforcing the Federal Food, Drug, and Cosmetic Act (21 U.S.C. 301, et seq.), the Public Health Service Act (42 U.S.C. 201, et seq.), the Fair Packaging and Labeling Act (15 U.S.C. 1451 et seq.), and parts of the Egg Products Inspection Act. In carrying out its responsibilities under these acts, FDA conducts inspections of establishments that manufacture, process, pack, or hold foods, with the exception of certain establishments that are regulated exclusively by FSIS. FDA also inspects vehicles and other conveyances, such as boats, trains, and airplanes, in which foods are transported or held in interstate commerce.”
The official agreement states FDA and USDA will keep an updated list of contacts between agencies, maintain a list of “dual jurisdiction establishments” and agree to notify each other should one agency discover a food safety problem.
While this sounds like something that should have been in existence for decades – it hasn’t been. But we have officially opened the door now. This is good news – for human food and human grade pet food.
Wishing you and your pet(s) the best,
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