One single consumer complaint to FDA led the agency to test a pet food which resulted in a recall. Hundreds of consumer complaints (many of which are reports of dead pets) over several years leads the agency to no testing of a pet food and no recall. Clear regulatory bias.
To FDA and State Department of Agriculture (at least the ones that I am familiar with through AAFCO meetings), pet food is mass produced kibble or can – that’s it. Pet food made with food (not feed) ingredients is considered unorthodox. Pet food made with anything other than bulk China sourced vitamins and minerals is considered unorthodox. From my experience, regulatory authorities don’t understand, recognize (as pet food) or even like the non-traditional pet foods (raw, cooked, whole food – anything other than waste ingredient synthetic supplement pet food).
And what do some people with power do with a pet food they don’t understand, recognize or like? They attack it.
As example only – not to be interpreted as an endorsement of this pet food – is the very recent Primal Pet Food recall. From the Primal Pet Foods recall announcement posted on the FDA website “FDA tested product in response to a single consumer complaint.”
The FDA took the action to test this pet food because they received one single consumer complaint. Wonderful that FDA took swift action for this consumer – that is as long as the agency takes the same or similar action with all other pet food complaints received. But, we know this is not true. As example, FDA has received hundreds of Beneful Dog Food consumer complaints over several years – including numerous pet deaths – yet to our knowledge the FDA has not tested one batch of Beneful Dog Food.
So what would have triggered alarm bells at FDA to go running to test this pet food from one single consumer complaint that did NOT result in a pet death?
Everything below is as I interpret the FDA’s reasoning to test a pet food based on one illness report (this is not my thinking)…
FDA Reasoning #1
Primal Pet Food is a raw meat pet food – it is a non-traditional pet food. This poor misled consumer (feeding a dangerous raw meat pet food) has certainly put her pet at risk. Let’s test this pet food.
FDA Reasoning #2
This pet food uses food sources to meet the required thiamine levels – not the standard synthetic bulk supplements. This is wrong, just wrong. FDA knows food can’t provide vitamins (Big Pharma tells us this). Test this pet food.
FDA Reasoning #3
Primal Pet Food? Who are these people? Are they members of the Pet Food Institute? No?…well, then there’s a problem. We don’t know these people, they don’t take us out to lunch or visit with us on a regular basis – they can’t be trusted. Test this pet food.
Do you know why – in our pet food test project we did not test for vitamin content in our twelve sample pet foods? Because our scientists shared that vitamin testing of pet foods is surrounded by significant controversy. Testing results for vitamin content can vary with each method used. FDA is fully aware that different vitamin testing methods can result in different testing outcomes.
FDA or AAFCO has not established nutrient requirements for whole food pet diets. The existing nutrient requirements accepted by FDA and established by AAFCO were developed based on “the utilization of nutrients in ingredients commonly produced and commercially available in dog and cat foods”. In other words, the nutrient requirements for all pet foods are based on waste ingredient meats with added synthetic supplements.
And one more thing. Pet Food manufacturing members of the Pet Food Institute (lobby/trade group representing Big Pet Food) visit with FDA on a regular basis (on record, FDA website). These same manufacturers socialize with representatives of FDA and State Department of Agriculture twice a year at AAFCO meetings. I have witnessed first hand at AAFCO meetings where industry trade association members finish sentences for regulators (State and FDA). When something is unknown, it has been (in my experience) common for regulatory authorities to ask for the sole opinion of these industry representatives for answers. At a recent meeting, three veterinarians spoke out against the approval of a new zinc ingredient pushed by industry – for safety concerns. Each AAFCO member – including FDA members – approved the ingredient without notice to legitimate veterinarian concerns.
The following letter was sent to Dr. Bernadette Dunham, Director of the Center for Veterinary Medicine, FDA…
Dear Dr. Dunham,
We are writing you with great consumer concern.
Primal Pet Foods – a non-traditional pet food manufacturer – recently issued a voluntary recall due to FDA testing finding low thiamine levels. While ATPF is pleased that FDA took swift action for this single consumer, we wonder if the agency treats all consumer complaints with the same actions? Has FDA tested Beneful Dog Food? And does FDA typically test pet foods with each single consumer complaint received? If yes – to the last two questions – will FDA publish these results publicly on your website?
Currently, all pet food nutrient requirements are based on the NRC research partially funded by the Pet Food Institute. The NRC research was “based on the utilization of nutrients in ingredients commonly produced and commercially available in dog and cat foods”. ATPF asks FDA if these nutrient requirements are appropriate to cover all pet foods? Especially considering that many pet foods now utilize whole foods (non-common pet food ingredients) to provide complete nutrition to the pet.
As a pet food consumer advocate who regularly attends AAFCO meetings, it is my opinion that FDA and AAFCO members have concerning close ties with the major manufacturers of pet food. Numerous inappropriate incidents have been witnessed between industry and regulatory officials at these meetings.
As consumers have learned that FDA openly allows pet food to utilize hideous waste as common pet food ingredients (animals that have died other than by slaughter or diseased animals, chemical contaminated foods, pesticide contaminated foods – all allowed through FDA Compliance Policies), suspicion begins. Pet ‘foods’ that are legally not food (they are feed) being allowed to make billions with misleading marketing (including but not limited to ‘food’ being stated on the label when no legally defined food is in the bag or can), suspicion rises. And then when FDA takes action when it receives just one single non-life threatening consumer complaint as we (consumers) have waited for 8 years for answers to Chinese jerky treat pet deaths, hundreds of Beneful Pet Food pet deaths, and numerous other reports through the years of sick/dead pets linked to other brands, suspicion rises to an all time high.
And pet food consumers have waited for 6 years for FDA to implement what Congress required the agency to complete by September 2009.
No pet food consumer wishes to be distrustful of FDA, AAFCO or State Department of Agriculture – unfortunately, the greatest majority of us are seriously distrustful. We have been put into this position because of lack of regulatory enforcement – equal and fair enforcement of law and because of an extreme lack of transparency from regulatory authorities and industry.
Pet food consumers wish to understand – without detailed investigation – what they are feeding their pet and trust officials are assuring the pet food is safe. We have none of this now. The future of pet food is in your hands – will you put the safety and health of our pets as your first priority?
Representing the Pet Food Consumer Members of
Association for Truth in Pet Food
If you would like to send the FDA your own message – you can do so by contacting the FDA CVM Ombudsman.
Marcia K. Larkins, D.V.M.
FDA Center for Veterinary Medicine
7519 Standish Place HFV-3
Rockville, MD 20855
Phone: (240) 276-9015
Fax: (240) 276-9060
Please – if you wish your message to be considered, be polite (believe me, I understand this is not easy to do).
Wishing you and your pet(s) the best,
What’s in Your Pet’s Food?
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The 2015 List
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