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Regulatory Bias

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  1. Ruth Thomson

    Susan, you are an angel on earth looking out for our furry children! Thank you so much for all you do & continue to do for them! We feed our rescued pit bull, Miss Kitty, Primal freeze dried raw & Stella & Chewy’s freeze dried raw, & only made in the USA pure chicken chews & treats. We do this thanks to your site & all your research in pet foods over the years. We also feed her on occasion tiny amounts of very select, home cooked chicken & beef with nothing added. Oh & yummy & healthy yams!

    You taught us so much over the years & we now have a very healthy dog with no stomach problems.

    You are amazing & so tireless in all you do for us & our furry loves. Thank You Thank You Thank You

    Ruthie in Arizona

    1. Susan Thixton Author

      Thanks Ruthie!

  2. Terri janson

    Thank you Susan from the bottom of my heart

  3. Kelly

    Thank you Susan for staying on top of them! We need more people like you!

  4. B Dawson

    I wonder what the consumer’s original complaint was. Testing showed the food was deficient in Thiamine. Thiamine deficiency in a cat would hardly be noticed after a single bag of Primal frozen food.

    So did the consumer complain about other problems – vomiting, diarrhea, lethargy? Or maybe did another company find the deficiency and decide to tarnish Primal’s reputation?

  5. Ann

    Being so completely tired of the FDA not investigating a pet food when hundreds and hundreds of complaints exist, but reacting to one incidental complaint, is ridiculous and insulting! Beneful is but one good example. Susan makes a perfect point with a list of questions to the FDA. Does the Agency favor the mainstream Pet Food Industry? Of course the FDA is used to ignoring her, especially when she is making a point, so it’s doubtful there’ll be a response. Yet her time and effort was once again put into play. The question is, how long are we, the consumers, going to permit this treatment. If it weren’t for Susan think of the mistakes we’d all be making when it comes to feeding our pets! We’d never know any of this trash was happening.

    Having worked in Customer Service for a Fortune 100 company for 10 years one thing always worked. When a complaint reached senior management (the higher the better) no time or expense was spared in dealing with the problem. Bottom line instruction was get rid of the nuisance or else. I suggest we put our POLITE, respectfully stated questions directly to the head of the Director of the Center for Veterinary Medicine, namely Bernadette.Dunham@fda.hhs.gov.

    Sure it’s great to have a staff ombudsman paid to handle the flack. But better yet is for a little inconvenience to accumulate where it really counts (at the executive’s desk) to speak volumes.

    Go ahead, phrase your concerns, issues, complaints. Write independently and individually, meaning you’ve NOT been coerced as part of any official“movement.” Just express your heart! But also let them know you’re not going away either. You’re proud that an Association for Truth in Pet Food is doing all the work. And it’s important to support that. So it’s time the FDA realized (physically speaking) there’s not just ONE Pet Food Consumer Advocate, there are HUNDREDS of concerned consumers and tax payers out there.

    That means you!

  6. Lilly

    Susan,
    Thanks for taking the time to look further into the Primal recall and point out this very important discrepancy that this recall was the result of a single consumer complaint over a non-life threatening low vitamin level. As you have mentioned in your post, since NRC/AAFCO nutrient recommendations are “based on the utilization of nutrients in ingredients commonly produced and commercially available in dog and cat foods” which are all based on synthetic crap that is hardly digestible. Therefore, they highly inflate the minimum recommendations of these vitamins and minerals because in reality many of them have a 25% digestibility value at best. When consuming raw, whole food ingredients from real foods our pets can readily digest and more easily assimilate these micro-nutrients, so they need much less compared to over-processed, synthetic garbage loaded with toxins. Even though Primal’s cat food came up low on thiamine as compared to NRC/AAFCO recommendations in reality there may be no cause of concern because the bioavailability of that vitamin is going to be much better in the raw, minimally processed whole foods. Something for us to consider. Thanks again for all of your dedication and time to educate consumers and help our pets live better lives.
    You’re the best!!

  7. Kathryn

    there is something odd about this single complaint based on a single unit of product. Lack of Thiamine in the product would [should] not have caused spoilage, discoloration, any visual or olfactory changes that would have been noticeable to the purchaser/consumer. The pet ( it was a ‘cat food’) might possibly have detected a ‘difference’ in scent/taste as they are much more discerning that either humans or dogs about what they eat. As this was a single product – not a years worth of product – there would have/should have been no diagnosable damages to the cat by being fed a diet deficient in thiamine for a prolonged period of time. Something just doesn’t sound ‘right’ to me about this — Usually they FDA requires an attending veterinary statement as to the affects of eating the food, the owner has to have lots lot ‘ducks’ in a row to even submit the form/product for testing. Something is rotten here, and it’s not the food!

  8. Mel

    Letter sent. Wonder if I will get a reply?

  9. Christine

    I’m almost finished reading “Evidence of Harm-Mercury in Vaccines and the Autism Epidemic: A Medical Controversy” by David Kirby and I recommend it to all in order to get a good grasp on the inside workings of “our” government and agencies like the FDA. All I can say is my suspicions about government, the FDA and any other alphabet government agency is verified. While there are many good people who work in these agencies do not doubt the corruption, lies and greed. Money and power talks and the pet food industry is pouring tons of money into politician’s coffers and they have many lobbyists who influence the politicians who have no conscience.. No different than big pharma. The FDA does not care about children and you can bet they don’t give a hoot about animals. It is beyond comprehension but then again, the love of money is the root of all evil.

  10. Ann

    Money and power talks. So does awareness and being involved. Politicians and those appointed, which IS the government, count on one thing. Deceit and apathy. Bad stuff happens behind closed doors. But once vetted it is up to the population to fight it. Through communication and repetition. Social Media is a very powerful tool! But most people still treat it as entertainment. Not true. We can’t count on commercial communication anymore (the media). But once we know the reality of a bad situation then WE have a responsibility (not just “them”) to take action. Or we have no right to complain.

    Susan has been campaigning consumer advocacy for years. Where else can you read so much about the PFI and lack of regulation. Most of us think oh I can only change my pet’s food. But these politicians and agency staff need to hear our complaints. They may be paid by Lobby interests to favor the PFI. But if the politicians weren’t in office in the first place, then they wouldn’t be getting any pay off. So what do you think they fear the most. My guess is their job.

    Express your disgust with your Vote and make it clear you’re tired of supporting people that do not work for YOU.

    That is, if you care.

  11. Ellen

    I agree with a previous comment that “Something is rotten here, and it’s not the food!” Testing a food after only one “supposed” complaint, while hundreds (if not thousands) of complaints about other foods result in nothing being done, is “rotten” indeed! This situation is a consequence of the inextricable link between government and industry. The bottom line is always at the heart of every issue; how tragic that the health of our pets doesn’t seem to enter into the equation.

  12. Carla

    Thank you Susan, as always, for verifying and notifying us about these issues and also your advocacy. I do have a small issue though with raising the “Big Pharma gambit” with “FDA knows food can’t provide vitamins (Big Pharma tells us this)” when you just got through saying the synthetic vitamins come in bulk from China.

    Do you have any evidence that “Big Pharma” (whatever that is, that is a too unspecific and value-laden term to mean anything) makes a whole lot of its money supplying synthetic vitamins to pet food manufacturers? And if so, is there any evidence that they are in some kind of conspiracy with the FDA and the pet food manufacturers to force them to use synthetic vitamins and to discredit the non-pet food institute manufacturers?

    I just feel like you damage your credibility using the Big Pharma idea. I don’t think safe pet food advocates should make intimations and use buzzwords like this that will get them lumped in with the anti-science (alternative medicine, anti-vaccine, etc) crowd, because then you are not taken seriously.

    1. Susan Thixton Author

      My reference to ‘Big Pharma’ is a common language reference to massive industries that produce drugs – this reference is made all the time, I assumed most understood it. My statement was on the line of thinking that FDA doesn’t understand or accept alternative pet foods that use no supplements (or very little supplements). Also – my statement was in reference to current pet food nutrient requirements that are established on waste ingredient pet foods using supplements. One size fits all regulations does not fit all.

    2. B Dawson

      Whoa Carla, did you just put alternative medicine into your “anti-science” category? That is an outrageous statement. As a practicing herbalist, I prefer the term complementary medicine. As a biologist, I can say definitively that there is PLENTY of science to back up herbal medicine, homeopathy, acupuncture and so on, including double blind peer reviewed studies.

      I see no problem with the term Big Pharma. It is not unlike referring to Cargil & Monsanto as “Big Ag” or Walmart as a ‘Big Box” store. It is a slang term that is in wide use.

      As to the vitamin issue, every dry and canned pet food is made with what the industry calls a “vitamin pre-pack”. The only exceptions are some of the raw food producers and very small high quality kibble companies. Extrusion of dry food and the use of meat meals (which are spray dried in ovens) leach significant amounts of nutrients out of the core ingredients. In order to meet AAFCO required levels of nutrients, supplementation MUST occur. Many companies also spray a vitamin+flavor coating on the outside of kibble to address oxidation of vitamins and improve palatability. Knowing that this is a wide spread practice, there can be no doubt that anyone who manufactures vitamins stands to make major money. APPA (American Pet Products Association) estimates that pet food alone will rack up $23 BILLION in 2015 in a market that enjoys total expenditures of $60 BILLION. Here’s the link to the report: mhttp://americanpetproducts.org/press_industrytrends.asp.

      Anyone who is involved in the industry knows that regulatory agencies walk a tough line between keeping consumers safe while not aggravating manufacturers. In order to make the best use of a budget that allows for minimal inspections and little testing and still be able to prove to Congress that you’re doing your job, FDA targets the easy marks, i.e. small companies. A huge company like Purina, owners of the Beneful brand, have in-house lawyers who can delay enforcement and subvert government regulation. Need proof that big companies do that? Look no further than Wall Street. The same tactics are used in the highly competitive world of pet food.

      Consumers are demanding healthier choices for their pets. It is the cover story on trade rag after trade rag. The small companies that have always offered healthy food are seen in only two ways by the old school companies like Mars, Purina and Nestle who now what to jump on the band wagon and claim their market share – buy up the little guys or run them out of business using any means possible.

      1. Tina P

        I’m unsure where I’m supposed to direct my angst:

        FDA, because even though they took action to keep my pets safe I’m offended at a perceived bias? That seemingly contradicts everything we request of FDA, which is more action. Can’t have our cake and eat it too.

        While I understand Susan’s hypothesis, I don’t concur. In this case, I believe action as taken specifically because Primal Pet Food markets and champions “Raw” pet food, which the FDA openly opposes and posts such opposition on its website.

        Therefore, any bias by FDA against raw foods is to be expected. Whether or not one choses to feed raw or agrees with FDA’s conclusions, it’s not the same as other kinds of complaints as far as FDA is concerned.

        Instead of watching big pet sit back and laugh at us while we point fingers at each other and argue semantics of vitamins, etc., let’s be happy that a potential problem was eliminated in this case. Isn’t that what this is all about?

        http://www.fda.gov/AboutFDA/Transparency/Basics/ucm206814.htm

        “Is it safe for me to provide my pet with a raw food diet?

        FDA does not believe raw meat foods for animals are consistent with the goal of protecting the public from significant health risks, particularly when such products are brought into the home and/or used to feed domestic pets; however, we understand that some people prefer to feed these types of diets to their pets. For the protection of both you and your pet, the FDA recommends the following when handling or using raw meat, poultry or seafood, for use in a pet’s diet:

        Keep raw meat and poultry products frozen until ready to use.
        Thaw in refrigerator or microwave.
        Keep raw food diets separate from other foods. Wash working surfaces, utensils (including cutting boards, preparation and feeding bowls), hands, and any other items that touch or contact raw meat, poultry or seafood with hot soapy water.
        Cover and refrigerate leftovers immediately or discard safely.
        In addition:

        For added protection, kitchen sanitizers should be used on cutting boards and counter tops periodically. A sanitizing solution can be made by mixing one teaspoon of chlorine bleach to one quart of water.
        If you use plastic or other non-porous cutting boards, run them through the dishwasher after each use.
        If you are interested in starting a raw food diet for your pet, please consult with your veterinarian.

        1. Susan Thixton Author

          Tina – my complaint was not that FDA took this action. My complaint is that FDA does not take similar action with other adverse event reports. The agency singles out raw food – any pet food that is not the standard kibble or can. I want FDA to take the exact same action with every adverse event report they receive. I think this is what everyone wants.

          With FDA warning on raw meat pet food, the FDA issued this warning based on bacteria risk. The same risk of bacteria remains with kibble foods too. But FDA has never issued a warning to consumer handling of kibble foods.

          So again, the bias I talk about is lack of consistency with FDA. I want them to protect the consumer (and our pets) – I just don’t want them to pick and choose at their discretion what they enforce and who they test.

          1. Tina P

            I still think there’s a misunderstanding:

            No one doubts the sincerity or value of the work of this site. This site is devoted to the safety of pet food, for the sake of pets. While FDA may have oversight over pet health, its number one mandate will always be safety of people, not pets. FDA has devoted an entire site with multiple links discussing its opposition to raw feeding, as advocated by the brand in question.

            As such, we shouldn’t be upset over this “bias”. Its to be expected and not the same category as pet food quality and danger of such to the pet, which is what most if not all other complaints relate. Is it fair? No. It is reality, yes.

            My point is rather should stay focused on what matters, which is changing perception of quality of food and FDA’s role in how we enforce it. Sniping over bias such as this makes the movement look weaker, IMO.

            http://www.fda.gov/ForConsumers/ConsumerUpdates/ucm403350.htm

            “…Raw Foods Can Also Affect Human Health

            Consumers also run the risk of getting sick if they handle contaminated pet foods and accidentally transfer the bacteria to their mouths.

            “If you’re going to handle raw foods, you need to pay particular attention to good hygienic practices,” Burkholder says. “Wash your hands and anything else that comes into contact with the product with hot, soapy water for at least 20 seconds.”

            Feeding raw food to a pet also increases the risk of contaminating food contact surfaces and other places.

            “Even if the dog or cat doesn’t get sick, they can become carriers of Salmonella and transfer the bacteria to their surroundings, and then people can get the disease from contact with the infected environment,” Burkholder says.

            Once Salmonella gets established in the pet’s gastrointestinal tract, the animal can shed the bacteria when it has a bowel movement, and the contamination will continue to spread.”

          2. Susan Thixton Author

            I understand what you are saying Tina – but there still remains the fact that kibble foods can affect human health as well. The 2012 Diamond Pet Food recall (all kibble foods) resulted in numerous human illnesses (from handling the pet foods). But there is no FDA warning specific to kibble foods. The exact same risks are present in both styles of feeding, so why only warn consumers to the risks of just one?

            The FDA selectively chooses which laws they enforce. Food is legally defined as what is consumed by humans and animals. Food is also legally defined as adulterated should it contain any part of a diseased animal or animal that has died other than by slaughter. Yet ‘pet food’ is allowed to utilize meats from diseased animals and animals that have died other than by slaughter. Pet foods that chose to use all actual food ingredients and state such on the label, had to go to court to fight for the right to disclose the truth to the consumer. Today – actual food grade pet foods have to jump through FDA hoops (Letter of No Objection) to disclose to consumers their use of food grade ingredients. These companies are abiding by federal law – when others are not. It feels to me, that there is significant FDA bias. And pointing that out here is what I believe is a way to hold them accountable for their actions. To me, their bias hurts pet food consumers (and our pets).

          3. B Dawson

            Tina –

            You are correct, the majority of FDA pet food recalls are due to concerns over human exposure, not the pets’. FDA uses Vet supported criticisms of raw foods to justify watchdogging raw pet food companies with greater alacrity. But acknowledge bias as a fact, accept it as “unfair” and move on? Sorry, it’s part of the problem.

            There are recalls that result from FDA/USDA plant inspections and there are recalls that result from manufactured products – either random purchases by regulatory agencies or consumer complaints.

            This current recall was in response to a consumer complaint – one complaint. Salmonella on dry food can just as easily sicken a human, yet hundreds of other complaints get filed for future consideration.

            FDA seems to allocate a substantial amount of their extremely limited funding and inspectors’ time to plants that manufacture raw pet food. I have that straight from raw food company owners. Those plant inspections have generated only a few recalls since 2008. According to FDA’s website (http://www.fda.gov/AboutFDA/Transparency/Basics/ucm194242.htm): “The (inspection) frequency is based on the type of facility, the type of food processed or handled at the facility, and the public health risk associated with the product.”

            Speaking as a business woman, the only way to justify the cost benefit analysis for the inspection frequency at raw food companies is that FDA believes there are problems with raw pet food. This would seem to be an unjustified assumption based on their own statistics and that raises red flags about potential bias.

            If changes in definitions of pet food, improvements to ingredients & labeling and sensible regulation of the industry is the goal, there must be a defined problem to resolve. Bias is not something to ignore, it is something to be challenged.

        2. B Dawson

          “Instead of watching big pet sit back and laugh at us while we point fingers at each other and argue semantics of vitamins, etc., let’s be happy that a potential problem was eliminated in this case. Isn’t that what this is all about?”

          Yes we want regulatory agencies to assure that what is in the bag is safe, nutritious, and as guaranteed on the label. FDA however, has a history of bias against anything that doesn’t come from the mainstream. This is the agency after all who raided health food stores, confiscating Celestial Seasonings SleepyTime Tea because the name made a “health claim”. This misplaced act of consumer protection sparked the outrage that resulted in DSHEA. FDA, AG’s and CDC are quick to jump on the “anti-science” bandwagon in an effort to taint consumer confidence. Remember that bad news always makes the front page, but the retraction is buried on page 10.

          These conversations are important to have on blogs like Susan’s because there are lots of people who don’t understand the relationships between manufacturers, their lobbyist and the agencies that are supposed to be on the consumers’ side without product bias. FDA is funded by Congress, right? Sort of, out of a roughly $4B budget, about $2B comes from “user fees” paid by pharmaceutical companies to expedite drug reviews. So who is talking to those officials who approve budgets? Here’s just one “follow the money” trail as an example:

          PIJAC (Pet Industry Joint Advisory Council) appointed Mike Bober as VP of Government Affairs in 2013. From PIJAC’s website: “Mr. Bober comes to PIJAC from the National Republican Congressional Committee (NRCC), where he served as Coalitions Director. Handling strategic communications, Bober managed the committee’s efforts to engage outside individuals and organizations at the federal and district levels. In addition, he was a key advisor in more than 100+ campaigns on outreach efforts, endorsement opportunities, and issue briefings.

          …..Bober served as the Executive Director of the House Conservatives Fund (HCF), a Political Action Committee supported by more than 100 Members of Congress. ….. he was responsible for all aspects of operations, from fundraising and communications to candidate vetting and contributions. He tripled the Fund’s individual donor rolls,…..engaged activists in more than two dozen districts across the country, and raised more than $1.1 million dollars in the 2008 election cycle.”

          Do you think this guy has a few markers to call in? Do you think he has Congressional Committee members on speed-dial? Take a look at who is on PIJAC’s BoD – puppy breeders, Petco, and one of the largest pet food/supply distributors in the US. Under “Association Representatives” we find someone Susan will recognize – Duane Ekedahl from the Pet Food Institute.

          YUP, THE DECK IS STACKED AGAINST A LEVEL PLAYING FIELD AND THAT’S THE ISSUE HERE. The word conspiracy tends to drag FreeMasons into the mix, so let’s use a different term – smoky back rooms. They are not a thing of the past. The movie “Thank You For Smoking” was clever and funny, but it is scarily close to reality.

          I probably owe y”all a disclosure statement at this point. I own Noah’s Apothecary, a herbal and nutritional consulting business that I started in 1992 to help humans take the best possible care of their companions including advocating for raw diets. I owned a holistic pet supply by the same name for 10 years where I learned enough about the pet food industry to become disillusioned. I am not anti-pharmaceutical, believing that holistic means using whatever works for the individual’s needs. I am not a Vet, nor do I play one on TV.

  13. Ann

    B. Dawson, I am grateful for all your that your comments contribute to Susan’s Blog, especially this explanation. As you explain, it does seems overwhelming doesn’t it. So how do we walk the fine line between feeling defeated by politics and bureaucracy and keeping people motivated to DO something. As written before, the government (politicians) and the PFI (and their minions) count on consumer ignorance and if they do become enlightened then they expect their apathy. They keep the discussions confusing, behind closed doors, they ignore complaints and inquiries.

    All this stuff has been going on for so long now. While more pets are affected. We have to pick a target. To simplify it. Like a representative, an election, a time and a place for PF consumers to react as an organization and be vocal. We know enough that’s wrong. It’s our job to demand fixes. That it won’t happen immediately or be easy is no excuse. The crime is when they just don’t hear from us.

    1. B Dawson

      Changing things is a task for Sisyphus, it is never ending. After fighting to get DHSEA passed the first time, I though we were home free. The NY AG has proven how wrong that was. We are back fighting the same battle that I thought was over in the 1994.

      Thomas Jefferson wrote in the Declaration of Independence:
      “…accordingly all experience hath shewn, that mankind are more disposed to suffer, while evils are sufferable, than to right themselves by abolishing the forms to which they are accustomed. But when a long train of abuses and usurpations, pursuing invariably the same Object evinces a design to reduce them under absolute Despotism, it is their right, it is their duty, to throw off such Government, and to provide new Guards for their future security.”

      I think those of us who are unhappy over the lack of transparency (did I really use that weary term?) that is our regulatory agencies need to take a page from 1994. Citizens saved their right to purchase supplements without prescriptions by a grassroots movement that benefited from two allies – Sen. Orrin Hatch (R) and Rep. Bill Richardson (D). We flooded every officials’ phone and mailbox with calls & letters demanding support for their bill that ensured our right to health choices. Congress was so taken aback at the national ferocity of the campaign that the two very powerful Senators who sponsored the bill to outlaw over the counter sales were set back on their heels and had to rethink their position. Quite a feat when you consider those Senators were Ted Kennedy (D) and Chris Dodd (D). Out of that movement grew several trade organizations that now maintain their own lobbyists who continue to stand up for freedom of health choice. Part of me is uncomfortable with the idea of becoming part of the system, but it is the only way to gain traction and be heard. Make no mistake, the supplement industry still has charlatans to deal with, but at least people sympathetic to supplements are putting programs in place to deal with them.

      So I think the question is how does ATPF get more clout, membership and a stronger voice. Susan has already procured several seats on advisory committees – an astounding accomplishment. You would think that in this day of viral Youtube videos and crowd funding it would be easy, but motivating people who haven’t witnessed a pets’ demise from tainted food is difficult. Susan needs numbers to put weight behind every thing she says in those committees. I must fess up and say I’ve stepped away from the battle, having convinced myself that I have done my part and its time to let someone else take up the fight. I may have to reassess that decision.

      I admit to not knowing that much about the organization so this is presumptuous on my part, but if I were to create a wish list for ATPF it might look like this:
      1) Outreach and Publicity assistant
      2) Social media assistant
      3) Grant writer
      4) Membership coordinator

      One thing that anyone can do is vote with your wallet. Some who lost pets have put their foot down and started their own companies to offer alternatives so that no one else has to suffer that heartbreak – Bravo! for example. Support those companies if you can afford it. Strike up a conversation with anyone who gets within an arms’ length of you and has a pet. Talk about what good nutrition looks like.

      As critical as I am about the regulatory folks, please remember that there are some good, caring people in FDA, CDC, USDA and the pet industry. When they stand up for what’s right, we need to cheer them on very publicly. They risk a lot by speaking out.

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