We had Significant Success in Washington DC
With a great deal of work to go, I am thrilled to report to consumers that our trip to Washington DC was not in vain. We achieved a significant agreement from FDA to work with consumer advocates for transparency in pet food. Is it feed or is it food? Hopefully soon the pet food label will tell you.
Our team was…Dr. Karen Becker, a pet owning lawyer, and myself. None of us had gone to Senator’s offices before, the three of us had never before worked together. We had a monumental task in front of us. The three of us were ‘all in’. We were focused, we each brought different things to the table. Though it is sort of bragging…I have to say – we were an awesome team.
Day 1 – June 21, 2017 – was meetings with Senator Richard Durbin’s (Illinois) office at 11 AM, meetings with Senator Pat Roberts (Kansas) and Senator Debbie Stabenow (Michigan) office – both members of the Senate Agriculture Committee – at 2 PM.
We weren’t nervous, but we felt the pressure of what was at stake. Walking down the hallways of the Hart Senate Office Building to Senator Durbin’s office was exciting. We arrive in Senator Durbin’s office and wait for our meeting. Soon we were escorted to a conference room where we met with Kevin Lefeber, Senator Durbin’s legislative advisor. We shared consumers concerns of pet food – starting with laws written (in part) by Senator Durbin back in 2007 (after the 2007 recall) requiring FDA to update pet food ingredients and labels. We told him FDA is almost 8 years past deadline. We explained that most pet foods are ‘feed’ and contain feed quality ingredients but marketed to consumers as food. We explained that laws within the Federal Food, Drug and Cosmetic Act are openly ignored by FDA and each State Department of Agriculture. And we explained how consumers are left in the dark – not knowing exactly what they are buying because pet food ingredient definitions are corporately owned, not public information as in human food.
We all added to the conversation and we were flawless (sorry to brag again, but I’m just that proud of us). But…there was no solution offered. Sincere concern, but no solution.
Next meeting went about the same. We met with Dr. Chelsey Shivley DVM – an AVMA fellow for Senator Debbie Stabenow and Chelsie Keys on Senator Pat Roberts staff. Again we were escorted into a conference room and again your team did an awesome job addressing the serious issues pet food consumers face. Awesome minus one moment when my frustration for a resolve caused me to go off focus for a bit…but…the rest of the team got me back on track quickly. Dr. Chelsey Shivley and Chelsie Keys took pages and pages of notes – they listened attentively. During this meeting we specifically asked for a resolve – we asked for pet foods that do not meet the requirements of food law to be labeled as feed. Their suggestion was to start this discussion with FDA and to have more consumers write their Representatives in Congress about these same issues.
We left feeling a bit deflated but we quickly realized this is how the ‘system’ works. One step at a time. Our first step was to make these three significant members of Congress aware of the problems pet food consumers face – that was a success. We made them very aware of the problems.
The next day – June 22 – was our meeting with FDA. We arrived at the offices of FDA, but it was not the FDA headquarters as you see in pictures. It was in an office park, 3rd floor. Again we were taken to a conference room and were promptly joined by Dr. Dan McChesney, Charlotte Conway, LeeAnne Palmer, and a couple more FDA representatives. Arrangements had been made in advance for Nikki – the owner of the pug Talula that died from eating pentobarbital contaminated Evanger’s Pet Food – to be on a conference call for the meeting. Nikki was the foundation for our request that things must change – no more pets should die.
Nikki spoke to FDA from the heart, a recently broken heart due to her loss of Talula. FDA was a bit uncomfortable. FDA asked us ‘What are you here for?’ We told them we are tired, consumers are tired. We told them we are tired and completely worn out worrying about the safety of pet food. We told them we cannot fathom how FDA can enable industry to profit from selling adulterated, illegal pet foods – misleading consumers. We told them we want transparency in pet food, we want law enforced.
And then FDA said…Ok, what do you suggest? Our suggestion was label all pet foods that do not meet food law as “feed” – “dog feed” and “cat feed”. Lots of details have to be worked out, but…FDA found this suggestion acceptable. Dr. Karen Becker spoke up and asked if it would be possible for a grading system for pet food – similar to the grading system USDA uses for meat. (Meat suppliers have the option to pay an additional fee to USDA to ‘grade’ meat as Prime, or Choice, or Grade A. The higher grade meats are in turn sold as a more expensive, higher quality product.) Again, lots of details have to be worked out but…FDA was very open to this suggestion as well.
We then asked about a time frame – when could the feed/food system be implemented, when could a pet food grading system be implemented? At this we received some push back. FDA would not commit to a time frame, and this we could not accept. We pushed again asking FDA how these changes in pet food could be moved along quickly. They suggested it go through the AAFCO process and agreed to introduce the idea to AAFCO at the next meeting in August (less than 2 months from now).
This is significant – we have law to back us up – we have law to push through these changes. We have the Federal Food Drug and Cosmetic Act behind us to facilitate this change in pet food. Current law states “In prescribing a definition and standard of identity for any food or class of food in which optional ingredients are permitted, the Secretary shall, for the purpose of promoting honesty and fair dealing in the interest of consumers, designate the optional ingredients which shall be named on the label.”
Feed grade pet food ingredients ARE “optional ingredients” permitted by each State and FDA. Most certainly, “for the purpose of promoting honesty and fair dealing in the interest of consumers” these optional ‘feed’ ingredients should be named on the pet food label. Law is on our side.
FDA asked us to put our requests in writing and submit them to the agency as an addendum to the Citizen Petition that we filed with FDA in October 2016. Needless to say, we have much work to do in a short time frame. Your team will complete the write ups and submit to FDA within the next couple of weeks.
There is much work ahead of us, including assistance from consumers in the near future to get this pushed through. I suspect some in pet food will be in support of these transparency changes, but I suspect the most powerful, most influential pet food manufacturers will be adamantly opposed. If we receive any push back from industry – consumers will know exactly which pet food companies are not willing to be transparent with consumers, which pet food companies have secrets to hide.
Again – law is on our side, we are ready for whatever opposition they put in front of us. And also remember, FDA felt these were good changes – we will continue to work with FDA to keep this on track.
We – all pet food consumers and all pet food advocates – succeeded in Washington DC. Your voices were heard. More news on the progress of this will be shared soon. Get ready to write emails, sign a petition, and/or make a few phone calls. Together we will achieve improved transparency in pet food – we’ve finally seen the light at the end of the tunnel!
A big thank you to Senator’s Durbin, Roberts and Stabenow for your time and your attention to the plight of pet food consumers. A big thank you to FDA for your willingness to meet with us and your willingness to work on true transparency for pet food consumers.
And a big, big, big thank you to Dr. Karen Becker and our ‘lawyer friend’. You were both awesome! I’m so proud of us all.
Go ahead…imagine it. Imagine walking into a pet food store and seeing clearly on the label pet feed or pet food. It IS going to happen. Consumers deserve to know what they are buying. Using Federal law we are going to make that happen. Soon.
Wishing you and your pet(s) the best,
What’s in Your Pet’s Food?
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