Your tax dollars are paying for it, but you have no access to what you’ve paid for. Another huge absurdity for pet food consumers.
One of you great pet food consumers in Florida wrote their State Department of Agriculture asking for public access to pet food ingredient definitions. The response from Florida proves that consumers are the absolute last consideration of regulatory authorities. But perhaps even a bigger disclosure learned from Florida’s response to this consumer is that we (consumers) pay double for something we are never provided access to.
At the upcoming Association of American Feed Control Officials (AAFCO) meeting (July 30, 2018), discussion will include “confusing pet food names”. What this topic means is that industry has requested regulatory authorities to change the name of some pet food ingredients. Industry believes consumers are confused about ingredients such as by-products. (To learn more about this discussion click here.) A Florida pet food consumer wrote his Department of Agriculture requesting the agency take action on behalf of consumers. He asked for these ingredient definition names to NOT be changed – so not to further confuse consumers. And he also asked Florida to publish the legal definitions of all pet food ingredients on the Florida website (currently all consumers across the U.S. are provided no access to pet food ingredient legal definitions).
This is the response he received from the office of Florida Commissioner of Agriculture Adam Putnam (bold added for emphasis):
We have received your request and we are taking your concerns and suggestions into consideration regarding topics to be discussed at the AAFCO meeting. Regulators from FDACS will be present and we will do our best to make decisions and provide suggestions at the meeting based on facts regarding what we deem most appropriate for the industry.
Florida told this consumer they would act on what is “most appropriate for the industry” – not on what is most appropriate for consumers.
As absurd as it is, most educated pet food consumers know very well that regulatory authorities take little action to protect consumers. The above attitude from Florida was no real surprise.
But what did come as a surprise was this…
This consumer also asked Florida Department of Agriculture to provide free public access to pet food ingredient definitions. (Background information: every single pet food ingredient has it’s own legal definition that is very different from the definition of the same item in human food. Example chicken: chicken in human food means USDA inspected and passed meat; chicken in pet food can be anything from USDA inspected and passed meat, to chicken skin and bones (little to no meat), to USDA inspected and condemned chicken not suitable for consumption.)
Florida responded with:
In regards to your request for the Department to publish all pet food ingredient definitions on the Department website, this is a request we are unable to fulfill as the material is protected by copyright and does not belong to FDACS. One option that we can present to you is that we can provide the information to one of our FDACS inspectors that is located close to you and we can allow you to view (but not copy) the information. If you would like to pursue this option, please let me know and I will make arrangements.
To explain just how absurd this response was, the Association of American Feed Control Officials (AAFCO) Official Publication (the book that contains pet food/animal feed regulations and ingredient definitions) contains 686 pages. Based on size of the book alone, it certainly cannot be read in a few hours. And much of the information in the book is written in a legalese language that often takes several reads to understand. To suggest a consumer can come to a state regulatory office and sit down and just read the book is ridiculous.
This consumer wrote back to Florida Department of Agriculture asking:
Can you explain to me why I, as a consumer, am not allowed to access, read, and copy the information regarding products currently marketed to me? This appears to me to be a way to keep the information under a virtual lock and key since I would have to make arrangements to meet your representative and possess an eidetic memory in order to recall said information when I needed it. The public needs to know in order to make informed choices about these products. As long as this information isn’t freely distributed, I will not trust ANY pet food label, nor the representatives who do not help the general public access this information freely.
(Such a great response!)
Florida responded back to him with (bold added):
FDACS has paid to purchase a few limited copies of these materials for our roles as regulators but we do not have the right to reproduce/copy/distribute them. This is the only reason I indicated that we cannot allow you to copy this information.
Yes, you read that correctly. Florida Department of Agriculture disclosed to this consumer that they themselves – a state government agency – have to purchase the book of regulations and ingredient definitions from AAFCO in order to perform their job as a regulator.
Looking at this significant issue closely…
#1 Florida Department of Agriculture (and every other state Department of Agriculture) is a regulatory agency charged with enforcing the information contained inside that AAFCO book. And they HAVE TO PAY FOR access to it. Have to pay for access to “these materials for our roles as regulators”.
#2 Each State Department of Agriculture that participates in the AAFCO process (which is most states) – actually write the regulations and definitions that AAFCO holds copyright privilege to. Consider this…your state government pays the admission fees to AAFCO meetings for multiple representatives of your state for two meetings a year ($375.00 per person for regulatory attendees, per meeting). Your state pays the salary of these individuals while they are performing work at AAFCO, and pays for all travel expenses. The state authorities write, discuss and vote on regulations and definitions. The government authorities do all the work that is published in the AAFCO book. BUT…your state still has to purchase the work their employees participated in from AAFCO.
#3 AAFCO earns a significant income from sales of this book. Per Guidestar.org, AAFCO earned $413,978.00 in 2017 from sales of the publication.
#4 AAFCO is a private corporation. It is NOT a government agency. In other words, a private corporation is making significant income on a publication that tax dollar supported government employees actually write.
#5 Because each State Department of Agriculture are tax dollar supported agencies, in essence consumers are paying for regulators to write the regulations and ingredient definitions and then paying again for each state agency to purchase the book their own work is contained in.
#6 But you as the consumer/tax payer – have no public access to what your tax dollars have paid for.
This does not only happen in Florida. For every state that participates in the AAFCO process (which is most states) – State Government pays the salary, admission and travel expenses of multiple representatives to attend AAFCO meetings (two a year). Each state’s AAFCO representatives (State Government Representatives) help write the regulations, help write the legal definitions of pet food ingredients. Yet – not one state provides consumers public access to the tax dollar paid work they performed.
And by the way, for the human food industry – consumers have free public access to all rules and all legal definitions. ONLY in pet food do consumers and regulatory authorities have to pay to access regulations.
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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Cannoliamo
July 1, 2018 at 4:57 pm
As a pet owner who has to spend many hours learning about the different ingredients that are marketed for and sold as cat food, there appears to be a huge difference between human and pet food dietary understanding. Human food is based on specific identifiable ingredients that are IN the food, where as pet food is a hodgepodge of food processing waste (much of it rendered and unidentifiable) and any food-related ingredient that isn’t specifically forbidden as harmful to pets. The AAFCO standards are more oriented to exclusion of certain food processing waste materials as opposed to the inclusion of known healthy dietary ingredients.
Even the labels say things like .. “Contains NO wheat gluten or soy, no poultry by-product meal, and no artificial flavors or colors” as if that makes it a good food. I’ve spoken to many AAFCO and pet food representatives, some of whom are nutritionists, but I’ve yet to find a CDR Certified Registered Pet Food DIETICIAN for cats and dogs who can explain the dietetics of specific pet foods and their ingredients. It’s as if the pet foods have never been studied for what IS know to be healthy and nutritious in a diet, but only for what is NOT acceptable in a food. Many of the proteins, fats and carbohydrates are not even specified on the label. I’ve found that the pet food industry in general is FAR more afraid of consumers learning the actual food sources and actual ingredients than human food manufacturers are and are FAR more secretive and nebulous in their labels and ingredients, including many unidentified food sources. It is close to impossible to develop a known healthy diet for my cats.
Frustrating to say the least.
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Cheryl Bond
July 1, 2018 at 6:15 pm
This is so OUTRAGEOUS‼️ It’s a complete misuse of our taxpayer dollars. I just can’t believe what they can get away with! AAFCO being a privately owned company, should not be bleeding a government agency that we taxpayers pay for, & then make us pay yet again! This is nonsense & they should not be allowed to get away with this! All information should be able to be accessed by the consumers & taxpayers funding the report.
What, if anything can be done to oppose this Susan? Can you start a petition, or FOIA request? It’s so maddening that they can get away with, seemingly anything they damn well want to!
Susan Thixton
July 1, 2018 at 6:27 pm
I think everyone contacting their State Attorney General on this – that their State Department of Agriculture participates in this government work (without providing the public access) is a good start. I’m also going to consult with one of the big legal aid consumer organizations to see if they would be interested in filing a lawsuit for consumers.
Jackie Earnshaw, CPDT-KA
July 2, 2018 at 3:53 pm
Thank you. i was going to ask about action steps we can take. Will do. And thanks to you Susan for moving forward with a potential lawsuit.
blowyourfunnyfuse
February 26, 2019 at 7:46 pm
i’ll join it too
Susan Hayes
July 1, 2018 at 6:56 pm
Susan – FYI, below is the response I received after emailing the Arizona Department of Agriculture (using
your suggested letter — and thank you for providing it). I have not responded.
——————————————————————————————————————
Director Killian has asked that I respond to your email. Feed is a complicated issue that has terms that have been developed for over 100 years. The purpose in this ever growing industry was to ensure that feed provided the needed animal nutrients and to define what it was so people couldn’t cheat and consumers would have uniformity and knowledge on what things were. Recently there has been the trend for premium meals made for pets from food people eat. These items would normally be recognized as safe. However, they still need to meet the nutrient requirements of the animals.
We have the AAFCO publication available here in the office for anyone who cares to come and look at it. This is a copyrighted document so therefore, we cannot put it up on the web. I am certain you are aware if you do an internet search you will find many of the definitions. I know this is not what you are requesting but it is the best we can do at this time.
I understand your request and we will keep it in mind as we attend the AAFCO meetings and discussions about terms, of any sort arise. Will a consumer understand it, if it is human edible ingredients – do people recognize this. Currently this is how poultry products are defined. Poultry is non-rendered chicken – basically the muscle meat. Poultry by products are non-rendered other stuff. Meat meal would be rendered products. Terms have been developed over years through lots of discussion and compromise. This involves input from states across the country, stakeholders – industry and non-government groups. It is a compromise, but one we as a regulatory agency try to keep all of our constituency in mind.
https://www.aafco.org/Consumers/What-is-in-Pet-Food
Jack Peterson
Associate Director, ESD
Arizona Department of Agriculture
1688 W Adams Street
Phoenix, AZ 85007
602-542-3575
Susan Thixton
July 1, 2018 at 7:00 pm
Thank you for sharing and thank you for writing them. But it wasn’t quite honest with his definitions. He needs to re-read the definitions.
landsharkinnc
July 2, 2018 at 6:44 am
Uninformed, incorrect, yes, but I hate to think that the answers were deliberately, intentionally dishonest . He probably 1. hasn’t read ALL the definitions and 2. would not understand what those definitions actually meant anyway!
tag
July 2, 2018 at 1:22 am
When my dog had bladder stone surgery it was recommended by the vet to feed a very expensive diet so this wouldn’t happen again. I actually bought a couple of cans and he wouldn’t touch it. I took every ingredient in it and did my own research and trust me soon found there was NO WAY I would ever feed this garbage to my pet. What I did do was study just what caused stones to form and followed a diet plan away from those foods. My baby died 6 months ago but he never had stones again. Bottom line. Do your own research because the vets and the food manufactures are not going to do it for you.