The Tail Wagging the Dog
The AAFCO system for writing pet food ingredient definitions is backwards. AAFCO allows the tail to wag the dog.
For the AAFCO meetings coming up next week, the agenda for the Ingredient Definitions Committee includes updating various poultry ingredients (example chicken, chicken meal, chicken by-product meal) commonly used in pet food. There was a pre-meeting conference call for committee members last week, and during this call it was stated that the AAFCO investigator charged with writing the updated poultry ingredient definitions had been working with “the pet food industry and the poultry industry” to update the definitions.
In other words, AAFCO has been asking the poultry industry exactly what they put into these ingredients and asking the pet food industry how they want the definition worded. Shouldn’t it be the other way around? The definition should be written according to what is the best nutrition for the pet and then ingredient suppliers should be required to adhere to those specifications. The tail (industry) wags the dog (AAFCO).
And there was a one stakeholder missing from those that AAFCO consulted to write the proposed updated ingredient definitions – pet food consumer advocates. Dr. Jean Hofve, Mollie Morrissette, and myself are active participants on the AAFCO Ingredient Definitions Committee and the Pet Food Committee – we all hold advisory position to these committees. But AAFCO did not consult with any of us for these definitions.
We (Dr. Hofve, Mollie, and myself) sent AAFCO a letter asking that these updated pet food ingredients be ‘tabled’ until we are provided with the same information that industry was provided with. We reminded them that consumers ARE a stakeholder of pet food. We were told they will be proposed as tentative ingredient definitions so that all stakeholders would have time to review the definitions.
This upcoming AAFCO meeting will have a small army of pet food consumer advocates in attendance. And the meetings are likely to get very heated considering some of the sensitive (to consumers) topics that will be in discussion. AAFCO will be addressing enforcement concerns of “Potential Misbranding of Feed Ingredients and Finished Commercial Feeds” linked to numerous pet food studies finding pet foods to contain animal proteins not included in the ingredient list, and/or pet foods that did not contain an animal protein that was stated on the label.
The Ingredient Definitions Committee meeting will discuss these poultry ingredients as well as defining ‘What is feed grade?’. Dr. Hofve, Mollie and myself submitted the following proposed definition of feed grade: “Material that does not meet the legal requirements of food, including but not limited to inedible and/or condemned foods, diseased animal material and/or material from animals that have died other than by slaughter, and adulterated human food contaminated by spoilage, filth, industrial chemicals or drug residues* (*with CVM pre-approval).” I’m confident this definition will raise some eyebrows and conversation in Big Pet Feed.
And in the Pet Food Committee the discussion will be defining human grade ingredients in pet food claims. I will be printing out two copies of every signature and comment received on our petitions for this issue – delivering one to AAFCO Pet Food Committee and one to FDA.
For anyone that wants to listen in on these meetings, you have free access online or via conference call. Click Here for those meeting times and how to listen.
We will be there – in force – to remind AAFCO, FDA and Industry – that pet food consumers ARE an official stakeholder of pet food and we will never go away. Each time they ignore us – each time they allow industry to write their own ingredient definitions, we will share their bias with our millions of stakeholder members. We the pet people, we will never give up.
Wishing you and your pet(s) the best,
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