AAFCO Meeting Update

The good and the ugly news from the January 2022 AAFCO meeting.

The January 2022 AAFCO meeting took place in Mobile, AL from January 18 through 20th. We attended the meeting in person, however most of the meeting sessions were virtual – which meant we traveled to Mobile, paid a higher fee to attend in person, plus travel expenses (hotel) and sat in a conference room to watch a webinar of most AAFCO sessions. While we understood AAFCO faced many obstacles to host the meeting in person, for those that attended in person – we could not see the video information (slides) very well and couldn’t hear some of those speaking via webinar. It was very frustrating.

There were 2 consumer advocates in attendance, myself and Chelsea Kent. 

Early into the meeting, President George Ferguson (North Carolina Department of Agriculture) shared a story regarding AAFCO attendees needing to ‘agree to disagree’. He shared that before he knew Charlotte Conway of FDA, he didn’t like her and disagreed with some of the things FDA required. He also shared that after meeting her and working with her at AAFCO he changed his mind on her – that through AAFCO, attendees agree to disagree. So late that same day – after the meetings were over, I saw Mr. Ferguson in the lobby and took the opportunity to ask if that same attitude of working with others you previously disagreed with applied to me and pet owners. Through Freedom of Information Act request emails, we know that Mr. Ferguson has referenced me as a “barking snake oil salesman” and he has mocked (made fun of) some consumer emails he received. Based on our history, I wondered if Mr. Ferguson’s ‘agree to disagree’ attitude applied to pet owners and advocates. I directly asked him if we could move forward and work together. He didn’t say no, but he also didn’t say yes either. After complaining to me that I make pet owners believe he doesn’t care about them – he just stared at me, not speaking. The message was very clear – my offer of an olive branch was refused.

Opposite of President George Ferguson, AAFCO Director Sue Hayes was very welcoming and courteous. Ms. Hayes and consumers have had their disagreements in the past, but she looked beyond that and stated she was glad to see me in attendance. Her professionalism was appreciated.

Many at AAFCO are professional, unfortunately there are also many that are not. One of the things AAFCO has always done – that I’ve never felt was professional – is during an introduction of the states that are in attendance, they make in-poor-taste jokes about each state. This year for Michigan they poked fun at the serious water issues experienced in the state claiming a common internet search in Michigan is “At home water test kits”. For Missouri they claimed residents searched “Day drinking for dummies”. And for South Dakota they claimed residents searched “Why can’t I hunt tourists?” At every AAFCO meeting, after this display of juvenile behavior, I’ve always been left with the feeling that many at AAFCO feel they are better than anyone else because they are regulatory – that making fun and mocking others is acceptable because they believe they are more important than others.

There were only 139 people in attendance at this meeting – typically it is over 400. 

During the Model Bills and Regulations Committee session, we learned that this committee is working on editing the definition of “labeling”. The proposed new definition is “The term labeling means (1) all labels and other materials upon a commercial feed or any of its containers or wrappers, or (2) accompanying or supporting such commercial feed published or communicated in any manner.” 

Industry did not agree with the words “in any manner”. It was suggested that AAFCO have a “legal review” of the definition performed – but unfortunately we don’t know from what perspective the legal review would be in. Such as, will the legal review be to protect industry or will the legal review be for the best interest of consumers? Because the AAFCO attorney is the same law firm that represents industry (members of the trade association AFIA), we assume the legal review will be to protect industry.

During the Ingredient Definitions Committee meeting, AAFCO again discussed the ingredient alfalfa. This particular discussion has gone on for years but perhaps it is finally put to rest as members voted to not delete the ingredient “Dehydrated Alfalfa”. 

During the Feed and Feed Ingredient Manufacturing Committee session, the Pet Food Institute gave a “stakeholder update”.  They shared that the industry is facing challenges of sourcing fat ingredients – because they are being sold to the biodiesel industry. The rendering industry responded saying they were sorry, but… The ingredient they are speaking of is the used restaurant grease and the fat produced by rendering diseased and non-slaughtered decomposing animal carcasses. In other words, it is basically a waste ingredient that the Pet Food Institute (trade association for Big Pet Feed) stated is in short supply to pet food because the fuel industry is purchasing it from renderers. We thank the rendering industry for sending this waste ingredient to the fuel industry instead of pet food. 

During this session too, the Poultry industry gave an update stating they are working with AAFCO to update animal protein ingredient definitions. For those that follow updates from AAFCO meetings, you will remember we submitted to AAFCO years ago updated animal protein ingredient definitions (definitions that would clearly tell consumers what the ingredient was). The poultry industry representative stated they are working on new definitions that “match what the industry is producing”. This was a significant disclosure. Pet food ingredients are not necessarily defined or added to a pet food because they are the right thing for a pet to consume – not necessarily an ingredient that has a nutritional purpose. Pet food ingredients are often defined and added to a pet food because they are ‘what industry is producing’. Many ingredients ‘produced’ are waste, left over from the processing of human food. 

And last but not least, the Pet Food Committee session included an approval of the Human Grade pet food guidelines. Pet owners can read the guidelines Here. Committee co-chair Stan Cook (Missouri Department of Agriculture) stated that the group has worked a long time on this guidance document, and that meeting the standard of human grade “is not easy for a reason”. He stated that reason “is safety for my grandkid”. While I agree that meeting the human grade claim should not be easy (it should be exactly to the same standard as human food), I find it puzzling that no one sees the concern of feed grade pet food safety for children. Spending so much time on human grade pet food guidelines for the safety of ‘my grandkid’ while ignoring the allowance of diseased animal material and non-slaughtered decomposing animal carcasses in feed grade pet food seems…like a double standard (at best). Regardless, at this point in time, the high quality standards of human grade pet food remains in place (and that is a good thing).

At the last AAFCO meeting (August 2021), the FDA stated during the Pet Food Committee meeting that copper levels in pet food would remain as is (with no maximum level established) even though multiple scientists were finding a link to copper storage disease in dogs with copper levels in pet food. However, at this meeting the FDA has (somewhat) changed their minds. Dr. Burkholder of FDA stated that after Dr. Sharon Center of Cornell University’s presentation to the agency during the September 2021 Listening Session (https://www.youtube.com/watch?v=PY_yEAWe01I – her presentation starts at 1:10 in the video), the FDA met again with Dr. Center (at her request, not FDA’s) and her persistence has somewhat paid off. Dr. Burkholder stated that the Pet Food Committee will need to address the copper issues. Another big change suggested by FDA (Dr. Burkholder) was that AAFCO workgroups formed to determine a maximum copper level in pet food should be “expanded to include veterinarians”. This is great news for pet owners, IF we can get more veterinarians like Dr. Center (unbiased/not employed by Big Pet Feed) to be included in AAFCO decisions. 

Dr. Burkholder also stated that he told AAFCO in 2015 the organization should “get out of the nutrient profile business” and he shared he still believes that today. I couldn’t agree more. AAFCO – which is an organization of state feed control officials – most are not veterinarians, nutritionists, or scientists – should not be the decision maker to the copper minimum or maximum in cat and dog food, or calcium or any other nutrient in pet food. In my opinion – those decisions should be made by an independent panel of scientists that are not employed by the industry.  

And during the Pet Food Committee session we heard an update of AAFCO’s years long Pet Food Labeling Modernization work. Pet owners can go to this AAFCO webpage – https://www.aafco.org/Regulatory/Committees/Pet-Food – and click on “Working Groups” tab for a drop down menu. Under that option, look under “PFLM” (Pet Food Label Modernization) to read various AAFCO documents. Although it could take several more years for the updates to be implemented on pet food labels, it appears that AAFCO is getting closer.

The next AAFCO meeting will be in August 2023, in St. Louis, MO. 

My thanks to pet owners for your continued support of our consumer association so that we can continue to attend these meetings on behalf of all pet food consumers.

Wishing you and your pet the best –

Susan Thixton
Pet Food Safety Advocate
TruthaboutPetFood.com
Association for Truth in Pet Food

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