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Pet Food Regulations

The Most Absurd

Imagine an hour long conversation with a federal agency defending its action of ignoring law. That was what happened yesterday with our FDA meeting.

Imagine an hour long conversation with a federal agency defending its action of ignoring law. That was what happened yesterday with our FDA meeting.

For the first 15 minutes or so of our hour long meeting (3/10/16), the FDA listened to our evidence proving the serious risk to FDA’s practice of allowing 4D animal material into pet food – which by the way, is a direct violation of law (that FDA is charged with enforcing). For the following 45 minutes, the FDA defended their ‘aiding and abetting’ practice of allowing pet food to violate federal law.

We provided the FDA with evidence that their sister federal organization – the USDA – was concerned about the risk to pets when dead livestock is rendered into pet food. The USDA feels decaying animal carcasses are a risk to pets due to the cooking process producing endotoxins; “these toxins can cause disease and pet food manufacturers do not test their products for endotoxins”. FDA was unconcerned. The FDA stated “some of this material is safe”. (Notice they did not say ‘all’.)

We shared that Donald R. Strombeck, DVM, PhD, Professor Emeritus, University of California, Davis, School of Veterinary Medicine has stated endotoxins in pet food can cause “damage to the liver”. FDA was unconcerned sharing “We are aware of his research and his feelings about dry dog food.”

FDA told us we have a “theory” that perhaps can be investigated, but shared it would be a multi-million dollar testing project that is not within the FDA budget; it was suggested we ask Congress to give FDA more money. A little guilt was thrown in to deflect us, FDA sharing to test the risk of 4D animal material to pets a “terminal study” would need to be performed. A “terminal study” means dogs and cats would be killed to determine how the illegal pet food material actually effects the pets consuming the foods.

We shared with FDA ‘no millions of dollars needs to be spent; no pets need to give their lives. The ‘fix’ to this is FDA enforcing the law. Stop allowing bacteria filled, putrid (and illegal) dead livestock into pet food.’

(brace yourself) FDA stated (a direct quote): “So 3 billion plus animals should go to landfills?”

To which I responded (a direct quote): “So you want pets become living landfills? Is that what you are saying?”

Another FDA representative quickly stepped in and deflected the conversation. At this point, FDA stated that all meats even for human consumption contain endotoxins.

Again, we steered the conversation back on track stating the true risk to pets is not low levels of endotoxins (our bodies and pets bodies have natural methods to safely handle low levels of endotoxins) – we again told FDA high levels of endotoxins in rendered 4D animals, as warned by the USDA, is the risk we are bringing to their attention.

And FDA again steered the conversation away from the fact that illegal bacteria contaminated material is being dumped into pet food stating ‘Endotoxins are not just from just one potential source – I don’t think you can blame that one source.’ (Meaning FDA doesn’t feel dead livestock that has laid in the field for days prior to rendering, contaminated with bacteria – resulting in dangerous levels of endotoxins – resulting in pet death – are more of a risk that rendered bits and pieces from a slaughtered animal. The law does, but not FDA.)

FDA adamantly stated they will not do a testing project that will kill pets to determine if dead livestock are a risk.

FDA was reminded that their sister federal agency – the USDA – has stated endotoxins cause disease in pets. FDA was unmoved except suggesting that perhaps USDA should be the one to do the testing (reminder, it is FDA responsibility – not USDA’s – to assure consumers pet foods are safe).

Besides myself in this FDA meeting, there was a pet owner whose own dog died from eating a pet food he firmly believes was highly contaminated with endotoxins. This pet owner gathered more scientific evidence than anyone can image – all of that evidence was provided to FDA. He provided FDA the clinical lab results from his dying dog matching every symptom of endotoxemia, he provided studies proving that some pet food ingredients (example propylene glycol) increase the absorption of endotoxins into the blood stream, study after study was provided. My patience with FDA stopped quickly when FDA kept asking this pet owner for more (more studies, has the pet owner tested the pet food himself, necropsy results).

I interrupted FDA and told them ‘This is a pet owner, it is not his responsibility to test pet foods, it is not his responsibility to provide FDA with data proving illegal ingredients are a risk to pets. That is FDA’s responsibility. It is our responsibility to bring serious concerns to FDA’s attention and we certainly hope you listen to us.”

We asked FDA what they are going to do about the very serious risk of endotoxins. They told us “we might” add it to the testing schedule for 2017, sharing they would only test “a handful” of products. FDA stated perhaps this could be a multi-year project.

I thanked FDA for this effort, but shared I felt sorry for all the pets and their grieving families that are going to die between now and then due to illegal, endotoxin contaminated pet foods. At this point, FDA reminded me (scolded me) for a statement (which I still stand by) said at an AAFCO meeting 8 months ago. I made a statement to the chair of the Pet Food Committee that they as individuals might have pets of their own, but they are nothing like the pet owners I represent. (AAFCO members and FDA representatives that own a pet are in a position to do something about a bad pet food that might sicken or kill their pet. Pet owners that I represent don’t have that benefit.) FDA told me they are pet owners too, and they didn’t appreciate my accusations they are not. My response: ‘No accusations intended – I simply stated I feel sorry for the pets that ARE going to die between now and when FDA decides to do something about this. One of those pets that die could be one of yours – depending on what pet food you feed’ (hopefully leaving them with something to think about).

And lastly I directly asked the FDA – “Is FDA going to continue to allow non-slaughtered, dead livestock – that are a direct violation of the Federal Food, Drug and Cosmetic Act – into pet food?” The FDA told us “We’re going to allow animals that have died other than by slaughter that are further processed, we will allow those ingredients in pet food.” The FDA openly admitted they will continue to allow pet food to violate federal law.

I openly admit I wasn’t the most pleasant person on that phone call. The pet owner on the call remained composed, even under direct assault by FDA. I did not. To this pet owner – my sincere thanks for your composure, and your very skilled knowledge on the topic of endotoxins. What a pity (what a crime) FDA did not take heed to the evidence you presented.

To FDA, I thank you for your time. I adamantly disagree with your opinion that 4D material is safe for pets to consume and I will continue with my battle asking FDA to enforce federal law with pet food. I will continue to question every authority on the planet if need be. I will be knocking on your door again and again – for as long as it takes.

Furious doesn’t even explain it. The simple truth of this situation: with the aid of FDA, the pet food industry is allowed to make billions of dollars each year selling adulterated pet foods to unknowing consumers, and pets are dying because of it. Some would call that aiding and abetting a criminal.

We are not done with this battle.

 

Wishing you and your pet(s) the best,

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

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29 Comments

29 Comments

  1. Sigrit Morghen

    March 11, 2016 at 1:13 pm

    Susan I Really admire your fortitude in this battle. Don’t know what we would do without your willingness to take them on. Hopefully more people will support your efforts. THANK YOU SUSAN…Sigrit…

  2. Nora

    March 11, 2016 at 1:25 pm

    Susan, I applaud everything that you’re doing to see that our beloved pets live long and healthy lives. I worry that the “powers that be” will see the deaths that they’re causing. I wonder what they feed their own pets???!!! Susan, I do hope you persevere and that a breakthrough will come soon. In my opinion your efforts will not go unheeded. I do think though that you should start your own pet food factory. I would be the first to purchase your products. Right now I do feed my cat Wellness and some Purina wet food but most of the time I feed her human meat either cooked or not depending on what she prefers…raw chicken hearts, cooked chicken drumsticks (no bones), a little cheese, sardines packed in water, pink canned salmon, raw ground beef, etc. She is thriving not just surviving. On top of that she catches her own mice, birds (sorry bird lovers), squirrels, etc. Keep up the good work Susan. God bless you!

  3. Duncan Ness

    March 11, 2016 at 1:28 pm

    Oh Dear: our tax money at work!

    • Jude

      March 11, 2016 at 5:29 pm

      Our tax money at work? It would be nice if our tax money was, indeed, at work. Unfortunately, I think it’s the pet food money at work to maintain the status quo. I’m going to send this to my senators and reps to give them a head’s up on what they probably already know about, because I really want to get their responses.

      It makes me so mad that the citizens of our country have lost control of having a regarded say on how our country is being run. Just because it’s been this way for eons doesn’t mean it has to continue.

      GO, SUSAN. WE’VE GOT YOUR BACK!!!!

  4. Kristi Clark

    March 11, 2016 at 1:34 pm

    This meeting made me furious to think about the millions and millions of our tax dollars that are spent on FDA bureaucrats and operational costs, as they refuse to do their job to protect people and animals from harmful food and drugs. This brought tears to my eyes about the pets and their families who will continue to go through the heartbreak, pain and expense of disease as a direct result of the FDA’s refusal to stand up and declare that no pet food shall contain non-slaughtered animals. What are we paying these people for? Hey, FDA, show us you are not corporate puppets, but instead professionals with integrity!!!!! I stand proudly with Susan, Truth About Pet Food and all pet parents. Enough is enough!

  5. Barb

    March 11, 2016 at 1:42 pm

    Thank you for all of your efforts, Susan!

  6. Laurie Raymond

    March 11, 2016 at 1:55 pm

    On the question “So you want to see billions of animals in landfills?” the correct answer is, there is a solution to biological waste on this scale, and it has to do with employing mushrooms to convert decomposing animal tissues into soil-enriching material. What to do with dead beings, including ourselves (other than convert them into cheap and potentially deadly “feed” for other animals) is a serious question that deserves serious attention — NOT to be used as an excuse for corporate intransigence in pursuit of short term profit.

  7. Cheryl Mallon-Bond

    March 11, 2016 at 2:27 pm

    Would any group of lawyers even consider taking on litigation of the FDA? It is blatant obstruction of LAW! How the hell can they get away with this?!!!!!!!!!

    I just love how they completely disregard & disrespect the USDA! When a branch agency of the gov’t is even vocal about these endotoxin concerns, & the FDA’s response to that, is trying to throw it on them, “maybe the USDA should do the testing” when they damn well know it’s their job to do! it is totally infuriating!!!! Then to add insult to injury, the FDA says, if they tested the food, they would only test a handful of foods! WTH!? Oh, I see, they spend a ton of money completely unjustifiably , testing a whole bunch of raw pet foods, yet many many brands of “feed”, millions of pounds, were shown to be contaminated with micotoxins, but thats just no big deal! Now they have slim to none concern about the endotoxins as well.

    The FDA is as corrupt and negligent as you can get! I trust them, NOT!!!!!!

    I wish it could have brought up to the FDA, the issue about euthanized pets in pet “feed”.
    That issue, is something that is beyond a horror story!. I swear, when I talk to people about that issue, people look at me like I am making up a story! They can’t believe it could be true…just like a lot of people wouldn’t believe that the FDA BLATANTLY is turning a blind eye, just as they clearly know that 4D animals used in pet “feed” is causing illness & death due to endotoxins. Clearly violating government laws!

    ***SUSAN—IMPORTANT!*** Several blogs ago, there were many people speaking of how we can expose many of these issues on a grander scale, in an expose. Well, I just had a pretty good idea. Please consider contacting Bill Maher. He is a huge animal advocate, & he is executive producer of VICE, on HBO. The show does exposes on many relevant societal issues. Of course, a full length documentary is what needs to be done, but if the topic was first introduced on VICE, it could elevate the issue more wide-spread & maybe Bill Maher could help be a catalyst to open doors & possibly even help partially finance a full documentary on the plight of the struggle uncovering toxic “petfeed” & how it’s sickening & killing our beloved pets. It can’t hurt to try!

    • M Jones

      March 11, 2016 at 8:31 pm

      Excellent idea!

  8. Casey

    March 11, 2016 at 2:46 pm

    It’s all down to profit. They see profit in the non-slaughtered animals, but only if they are fed to OUR pets. Our pain and loss does not factor one whit.

    What we need is new leadership there. New leadership that puts consumers before special interests.

  9. Caron

    March 11, 2016 at 3:07 pm

    This is truly horrifying. I wonder if these FDA employees are getting kickbacks from Big Pet Food? I would love to see a documentary and expose on what is going on behind the scenes.

    Thank you for standing up for us.

    I am speechless.

  10. Cathy

    March 11, 2016 at 3:14 pm

    Why don’t we start an online petition on this issue? They are very effective when the public be comes aware and a government agency is brought to task?

  11. Dianne

    March 11, 2016 at 3:35 pm

    If the FDA person is who I think it is, that person used to work for Monsanto and we know how concerned they are with our health and the state of the environment. They have more money than they know what to do with and it still isn’t enough. They wont be happy until every farm in the world is growing only their gmo seed. As soon as marijuana became legal, they started working on gmo marijuana. Just disgusting.

    Anyway, he probably honed his skill at deflection and turning a blind eye during his tenure working with/ or for Monsanto. It is also shocking how many people in government positions started out with Monsanto. The Clintons have strong ties to Monsanto. I wish someone at one of the rallies asks them about the FDA and pet food.

    I also wonder what Michael Moore is doing these days.

  12. Lori S.

    March 11, 2016 at 4:33 pm

    This is so bizarre. Can the FDA just decide which laws to enforce and which to ignore based on their own assessment of the risks? Or are they supposed to enforce **all the laws**?

    I do understand and believe that funding is critically short (thanks to conservatives in Congress), and they have to prioritize what to do with severely limited funds. But it sounds like they are making choices (and excuses) based on opinion, and, probably, lobbying. The galling thing is saying that their lack of enforcement is, at worst, irrelevant, and, at best, a good thing. They never just say: we are failing to enforce the law. It is a failure.

  13. Flick, Dot and Buzz

    March 11, 2016 at 4:47 pm

    Thank you for all your hard work Susan, for your fortitude in listening to this shocking s*&( from the FDA. Is there any process by which the public can petition the USDA to control the FDA?

  14. Debi Cohen

    March 11, 2016 at 5:46 pm

    How the heck do you keep sane Susan???? your are a much stronger person then I, I know walking out is not an option, but it would be hard to speak to people that will not listen.

  15. Epony Mousime

    March 11, 2016 at 10:05 pm

    Thank you for your advocacy and persistence. I wouldn’t have been able to perform as well as you did in the midst of such frustrating inanity. I fear that nothing will be done in the near future to resolve this unless/until hundreds of thousands of people speak up. And most don’t know about it. I’ve had 4 animal companions dies of liver and kidney failure. The vet speculated it may have been due to chemicals in the carpeting. It’s probably due to a combination of toxins in the environment; but we should certainly expect to have safe and healthful food for our animal companions. Without influential big bucks and lobbying muscle, I feel we will continue to be ignored.

  16. Virginia Chapson

    March 12, 2016 at 3:23 am

    “Enraged” is not a strong enough word to express how I feel about the FDA’s complete lack of responsibility
    and concern for what their illegal actions, which go unpunished, have done to our pets. I feel like opening
    my window and screaming my outrage to the world,
    Thank you, ad infinitum, Susan for fighting for our rights.
    Gini

  17. Ron W

    March 12, 2016 at 10:08 am

    It’s a real travesty the way FDA is responding to the inquiries on pet food. Remember this is also the same agency that approves all the Medications that you may take. If you observe the ads that are aired or published in various periodicals you will find limited drug trials and so called fast track approval all through the payoff of the governing agency. Stands to reason it’s in their best interest to accept the payola and ignore the safety of the public and pets. Until that changes we’re banging our heads against a very hard brick wall. There was far more oversite of drugs prior to any advertisement of drugs and the agency was staffed with people that were interested in enforcing regulations it is entrusted with. As concerned pet owners and lovers we have a very long and hard road to travel. (20+ years in clinical research)

    • Jude

      March 13, 2016 at 12:50 am

      You are spot on, Ron. The FDA doesn’t protect our pets or us as citizens. FDA fails us both. Pet food, pet drugs, human food and human drugs are supposed to be monitored for validity and safety. The FDA “drops the ball” on all of this.

  18. barbara m.

    March 12, 2016 at 2:45 pm

    The FDA’s reply regarding the testing for endotoxins, that it:
    “would be a multi-million dollar testing project that is not within the FDA budget”… rather than complying with the law.

    Could it be the FDA’s decision to ignore the law is due to financial concerns? When proposed changes to the status quo presented to the hierarchy within the FDA, it no doubt comes down to a decision regarding money.

    In 2015, the military spent $601 BILLION. That’s BBBillion, folks. Whereas the FDA spent only $335 million, and the USDA spent $139 million. Billion vs. million. In a perfect world, I can see some trimming done to a certain part of the government, that could benefit both the FDA and USDA.

    • Anthony Hepton

      March 27, 2016 at 6:31 pm

      Barbara m, the FDA could avoid that multi-million testing for endotoxins by requiring those who choose to use the potentially contaminated products and the renderers who choose to sell their products as pet food rather than fertilizer, to pick up the tab for this much needed research. Until the manufacturers of the potentially contaminated products have data that have been peer reviewed and are available for public review, they should be required to put a WARNING label on every container of product.

  19. barbara m.

    March 27, 2016 at 8:54 pm

    Yes, Anthony. That is a great idea, to require the manufacturers and renderers to pick up the tab for the testing. Unfortunately, this is a non-issue. There will be no testing, because at this time there are no minimum levels established for endotoxins. This will be decades down the road. In the meantime, what do you do with 4 billion pounds of rotting carcasses? Make pet food, of course. So, the public needs to become more informed as to what exactly is allowable in pet food, such as: Cancerous tumors, liver flukes, abscessed tapeworms, (too name a few of the hundreds allowed). The parts of the animals “stick marks”, where animals have been injected with antibiotics, hormones, or other drugs that are cut from the carcasses that are going to human consumption. Carbolic acid, kerosene…Flea collars.

    • Anthony Hepton

      March 29, 2016 at 8:52 pm

      Barbara M, You are correct in stating that there are no minimum levels established for endotoxins, and FDA stated that they were not about to undertake that chore any time soon. However, there is a requirement on the part of the manufacturer to produce a safe product and USDA has already stated that the ingredients of rendering contain endotoxins that can cause disease. I contend that the manufacturers are obliged to develop data that they share with the public that shows their products are safe.
      Dr McChesney of FDA/CVM has written ” The simple assertion of this safe use thus does not satisfy the burden the proponents of the use bear to establish general recognition” and further “General recognition cannot be based on an absence of studies that demonstrate a substance is unsafe, there must be studies or other information to establish that the substance is safe” My question to Purina and the other users of these products is WHERE ARE YOUR DATA SHOWING YOUR INGREDIENTS ARE SAFE? Purina will not allow this topic to be discussed, they just assert that FDA allows it.

      • barbara m.

        March 30, 2016 at 2:39 pm

        We seem to be going around in circles.
        You say that manufacturers of pet food are required to produce a “safe product”; but regarding endotoxins and the minimum levels issue, the manufacturers do not have to test their product for endotoxins until a N.O.A.E.L. test has been done – determining the No Observable Allowable Effect Level. This can be done by a university. Then Congress can enforce the law. Until then, a WARNING label would be a great idea, but who is going to enforce them to do this?

        • Anthony Hepton

          March 30, 2016 at 5:55 pm

          These are great points, but USDA has already stated that endotoxins cause disease, isn’t that an observable adverse effect? I would be delighted to see a warning label on those products containing endotoxins until a tolerance is set, unfortunately the manufacturers have FDA protecting them.

          • barbara m.

            March 31, 2016 at 11:25 pm

            Yes, USDA stated that endotoxins were unsafe, and it may or may not be “an observable adverse effect”; but, because it’s not their purview, they can’t do anything… is how I see it. USDA – human food. FDA – pet food (feed). Then there are the manufacturers.
            The whole thing stinks.

  20. Nora

    March 27, 2016 at 9:33 pm

    I still wonder what the employees and CEO’s of these huge pet food manufacturing facilities right down the line to the guy that sweeps the diseased crap off the floor of the processing rooms feed their own pets? Boggles the mind! Hey! Maybe they don’t know? Secrets abound. Horrifying!

  21. Dianne

    March 27, 2016 at 9:43 pm

    I don’t suppose there are publically available minutes for these meetings?

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