This recent AAFCO meeting (July 2014) was the best and the worst AAFCO meeting I’ve ever attended – all in one 3 day experience. AAFCO is an impossible situation. But…the impossible will prove to be possible. Change of attitude and shift in direction.

This is not a quick read article. What is said here cannot be stated briefly/quickly. But it is VERY important and has a extremely good ending. The parts explained in detail below are…

The Impossible Situations

Four major impossible situations of pet food regulations (AAFCO related).

FDA Suggestion – fix it ourselves.

How we can and will!

Contest – win an AAFCO pen!

Seriously…you can win an AAFCO pen!

The gist of the story… Instead of fighting those that have no intention of ever changing law or ever providing full disclosure to the quality of pet products they sell, we can choose to work differently. Discovery of the good, supporting them, and letting all others fight amongst themselves.

Impossible situation number 1.

I’ve lost count of the number of State Department of Agriculture employees (AAFCO representatives) that have told me their departments – pet food or animal feed – don’t have the staff they need. Two or three State Department of Agriculture employees are the only people to investigate sick pets or sick livestock due to a food/feed. The same two or three inspect all pet food or animal feed manufacturing facilities of their state, inspect all pet food/animal feed retail outlets, inspect and approve 5,000 to 10,000 different pet foods and treats (dog, cat, hamster, rabbit, ferret, bird…) labels and another 1,000 different animal feed labels (cow, pig, sheep, horse, chicken, duck…) sold within state boundaries each year. The same two or three are responsible for understanding the nutritional requirements of each species of animal their state sells or manufacturers pet food or animal feed for, what can cause a nutritional health concern for these animals, and how to properly investigate a suspicious food/feed incident. Responsibilities that should require a team of veterinarians, toxicologists, and investigators are often the job of one or two State Department of Agriculture employees.

Impossible situation number 2.

The same two or three employees of most State Department of Agriculture also hold the AAFCO responsibilities of their state too. They hold the power to approve or disapprove a nutritional change for an animal or a new pet food/animal feed ingredient. But most that hold this power are agriculture people (having background in agriculture), they are not veterinarians or toxicologists. An already overworked government employee is put into situations that require them to make decisions that are (frankly) out of their realm of expertise and they have little time to investigate (read the science) prior to voting to approve or disapprove a change in law that could seriously change the life of an animal. Responsibilities that should fall on the shoulders of a team of veterinarians, toxicologists and nutritional experts become the responsibility of the same two or three State Department of Agriculture employees.

Impossible situation number 3.

The laws that govern pet food and animal feed in each state are as diverse as the geographic regions of the U.S. they make up. Just as example…Arizona has no pet food specific law, Colorado does. Delaware has minimal requirements for pet food – such as inspecting the guaranteed analysis statement on pet food labels. Idaho and Louisiana have pet food regulations but they “prioritize” enforcement based on animal safety. Nevada has no pet food specific law and South Carolina’s pet food laws haven’t been updated since the 1970’s. How can each state protect the pets and animals within their state boundaries if there are no laws or antiquated laws to base that protection on?

And lastly…Impossible situation number 4.

Add all of the above impossible situations together and you’ve got an overworked state government employee with incredible responsibilities on their shoulders with little to no state laws to back them up (and this is just referencing those honest people trying to do the right thing). In walks industry – powerful industries with even more powerful trade/lobby groups. They befriend, pressure, and offer to ‘help’ make the impossible situations of the overworked state government employee with incredible responsibilities go away. They use every tactic known to man in order to sway that vote on a new ingredient or a change in nutritional requirements. The tired, overworked, out of their realm of expertise state government employee often just takes the path of least resistance…they vote yes (agree with industry).

And then we have those that are not honest. To date there is no public evidence that State Department of Agriculture/AAFCO representatives have been ‘under the table’ influenced by industry or trade groups. But…this wouldn’t be the first industry to ‘buy’ the inspection report or lab result they wanted would it? Many ‘things’ happen when huge profits are on the line.

Under existing conditions, AAFCO and their State Department of Agriculture members cannot effectively protect animals without the support from their respective states. State governments are expecting these people to be veterinary experts, toxicology experts, nutrition experts, law enforcement and investigators all wrapped up in a two or three person staffed office. Why does anyone bother to develop laws if only a handful of states are implementing them and even fewer have the resources to enforce them? What started more than 100 years ago as a handful of manufacturers producing a few livestock feeds has grown into multiple multi-billion dollar a year industries covering thousands of different foods, treats, and supplements made from GMO, non-GMO, national and international ingredients, chemicals, pesticides, dyes, preservatives and denaturing agents. All of these products are governed by too few, out of their expertise, overworked individuals  – some of which are good people trying their best to do the right thing, others are not so good people willingly manipulated by industry. It is an impossible situation.

I by no means forgive any of them for not doing their jobs completely. Regardless to a two or three person State Department of Agriculture staff facing tremendous circumstances, this is not meant to be an excuse for these agencies. This ‘truth’ is meant to clearly define the problem every pet food consumer faces. I have suggested to many a State Department of Agriculture they have no business approving products for sale if the state cannot properly protect the pets consuming them. Our pets provide state government an estimated $6 billion dollars a year in revenue (sales tax and product registration fees alone). We certainly are not getting our tax dollar money’s worth.

FDA Suggestion – fix it ourselves.

In our meeting with FDA, essentially the FDA admitted it is an impossible task to change federal law and the laws within each of the 50 states. It is admittedly impossible for government to provide consumers information on which pet foods are made from legal by definition food ingredients and which pet foods are made from illegal by definition food/feed ingredients (such as 4D meats, pesticide contaminated ingredients, meats from rejected for use in human foods, and so on). But…and this is big…the FDA suggested that we can do it ourselves – we can be the ‘fix’ ourselves.

We can scream until we are blue in the face at AAFCO, state government, FDA and anyone else that will listen – or we can take the proverbial bull by the horns and change things ourselves. Instead of battling to change law, we change our direction. The perfect example – the Non-GMO project.

Educated consumers wanted to know what foods contain GM ingredients – they petitioned, pleaded, and begged lawmakers to require GM labeling of foods. When that didn’t happen, one determined group addressed the problem themselves. They developed the non-GMO project – a certification system providing consumers with trusted proof a food is GMO free. Today they have verified thousands of products to be GMO free, each displaying a simple Non-GMO Project Verified symbol on the label alerting the consumer to the non-GMO status.

So, we (pet food consumers) can continue to fight an impossible situation. We can tackle each state government laws and federal laws one by one, along with tackling the billions of dollars of influence that multi-billion dollar a year industries and trade groups can buy. Or – we can change our perspective and just do it ourselves. We can raise the bar in pet food to a whole new level by taking the Pledge to Quality and Origin and making it a certification program – certifying to pet food consumers the (certified) pet foods are made with legal food ingredients (not made from the hideous wastes allowed in pet food) and certifying the country of origin of each ingredient.

Personally, there is no other option. We have to do it ourselves. Without billions of dollars and well established lobby experts behind us, continuing on the same path is fighting a losing battle. Personally, I’m tired of beating the same dead horse (that will end up being rendered into pet food anyway). I am ready to turn a new page and leave all those impossible situations behind. We all deserve better – our pets deserve better – and I’m certain we can get it through pet food certification.

If you are familiar with the Non-GMO Project – you already have a good understanding of what we will be developing (if you aren’t familiar with this program – please read on their website – it is fabulous). But very basically our certification will be 1) USDA inspected and approved ingredients, and 2) verification to country of origin of all ingredients – the two very basic pieces of information that all pet food consumers should be assured of, but are not. The certification program will be part of Association for Truth in Pet Food (not

One last thing…a contest. The prize – this beautiful AAFCO pen (barely used). You’ll be the envy of all your pet food consumer friends with this!   AAFCOpen

Here’s how can you win this beautiful AAFCO pen…

What should be the name of our certification program? The Non-GMO project uses ‘Non GMO Project Verified’. What should ours be? We will be certifying a pet food/treat’s use of legal food ingredients and certifying the country of origin of all ingredients. The best suggestion (ok, maybe two – I have another pen) will win the pen(s). (No guarantee the winning name will become the official name of our certification project – but I do guarantee at least one of you will win a pen.) Post your suggestions below in comments – and make certain to use a valid email address if you really want that AAFCO pen!

The future of pet food is going to get better. As the FDA suggested, we – consumers – are going to make it better! More details of our project soon (hopeful by month’s end).


Wishing you and your pet(s) the best,

Susan Thixton
Pet Food Safety Advocate
Author Buyer Beware, Co-Author Dinner PAWsible
Association for Truth in Pet Food

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