The perpetual mess, FDA’s Animal Feed Safety System
After the 2007 pet food recall, Congress mandated FDA clean up its act regarding pet food safety. Although deadlines have long past, the FDA’s latest version of AFSS (Animal Feed Safety System) includes some serious concerns for pet food safety.
After the deadly 2007 pet food recall, Congress appeared to care about our pets and the safety of pet food in the U.S. Congress told the FDA, through the Food and Drug Administration Amendments Act (FDAAA) to quickly develop improved pet food (animal food) ingredient definitions and to quickly design an improved pet food (animal food) safety system. Deadlines to accomplish these goals were set for 2008 and 2009. The plan was to prevent what happened in 2007 from every happening again.
However, here we are in 2010 and the FDA is STILL trying to figure out what to do.
In response to Congress’s FDAAA (FDA Amendment Act), the FDA has worked on their version titled the Animal Feed Safety System (AFSS) which has accomplished little to actually prevent another deadly recall and has accomplished nothing regarding clear pet food ingredient definitions. Furthermore, the latest edition of AFSS has some new additions which could make things worse.
The Fourth Edition of AFSS states…
“CVM (Center for Veterinary Management, sub-category of the FDA) plans to begin a pilot program and accept Generally Recognized as Safe (GRAS) Notifications for feed ingredients under an interim policy that will be announced in a Federal Register document. An Ingredient Safety Team has been established in the Division of Animal Feeds to review GRAS Notifications. CVM is also preparing the Federal Register announcement that will provide firms with information on the interim policy. This interim policy is being initiated due to the delay in finalizing the Generally Recognized as Safe Notification rule, which was proposed in 1997. It is anticipated that the interim policy will be in place until this final rule publishes in the Federal Register.”
How can this be a concern? Well…as example, the FDA has determined that rendered euthanized animals rendered into pet food ingredients are GRAS (Generally Recognized as Safe). The FDA has determined that pentobarbital, the drug used to end the life of an animal, is GRAS in those rendered pet food ingredients too.
The above quote from the latest update of AFSS slips in the statement ‘the CVM is preparing to announce the new GRAS rule to firms. I interpret this to mean the CVM is about to tell rendering companies and other waste processors to get ready to submit their applications to the ‘Ingredient Safety Team’ for new garbage to be considered GRAS pet food ingredients.
GRAS means no extensive independent testing for safety is required. GRAS means the ingredient supplier only has to provide enough data to the Ingredient Safety Team (perhaps only biased ingredient supplier prepared data) to persuade GRAS acceptance. GRAS could be a new health promoting ingredient; however, GRAS could as well be an ingredient that causes long term health damage to our pets. GRAS leaves me feeling very uncomfortable.
If you’d like to read (and be discouraged) the updated AFSS, go to http://www.fda.gov/AnimalVeterinary/SafetyHealth/AnimalFeedSafetySystemAFSS/ucm196795.htm
My suggestion…for the Ingredient Safety Team…
50% of the team should be FDA scientists, 50% of the team should be pet owners that lost a pet during the 2007 recall or due to any other pet food contamination.
Sure, I know this won’t happen…but wouldn’t it be great?
Oh…and by the way, the FDA has requested “$4.03 Billion to Transform Food Safety System, Invest in Medical Product Safety, Regulatory Science”. http://www.fda.gov/NewsEvents/Newsroom/PressAnnouncements/ucm199516.htm
(If they would use that money to actually make food safer – including pet food – I’d be all for it.)
Wishing you and your pet(s) the best,
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