AAFCO August 2021 Meeting Notes

Attending this meeting were representatives from 46 states, 7 countries. The FDA had 74 attendees at the meeting. A total of 407 attendees. Regulatory attendees pay AAFCO $200.00 per person to attend, all others paid AAFCO $350.00 per person to attend. The meeting was virtual.

The good news first…

We won one! AAFCO did not vote on the proposed changes to Human Grade Pet Food guidelines that we previously shared. It was decided that the guidelines would be posted on the public pages of the AAFCO website with opportunity for anyone to provide a comment on. We were very glad AAFCO made this decision. When the document is posted and comments are open, we will let pet owners know. (My thanks to everyone that sent AAFCO a message, I believe your efforts played a role in this change of heart by AAFCO.)

The next bit of good news is that AAFCO will finally make pet food/animal feed ingredient definitions public. However, what AAFCO is allowing to be viewed is not current definitions (they are 1 year old) and the organization appears to make some serious restrictions on anyone that wishes to view the definitions.

Those that wish to read the definitions must provide AAFCO your name and email address, plus acknowledge the copyright of the definitions. The statement that must be accepted is this:

“Copyright Disclaimer: The AAFCO Official Publication, including Chapter Six, is an original work authored by AAFCO, which holds copyright rights in the Official Publication. The Official Publication is available for purchase on the AAFCO website. No part of the Official Publication may be copied, photocopied, reproduced, translated, or reeducated to any electronic medium or machine-readable form, in whole or in part, without the prior written consent of AAFCO. Any other reproduction in any form without the permission of AAFCO is prohibited. All materials contained in the Official Publication, including this online version of Chapter Six, are protected by the United States copyright law and may not be reproduced, distributed, transmitted, displayed, published, or broadcast without the prior written permission of AAFCO.”

So…if anyone wishes to meet AAFCO’s demands, you can now read pet food ingredient definitions by visiting this webpage – Click Here.

Other updates by AAFCO during this session:

Dried Black Soldier Fly Larvae is now an approved ingredient for adult dog food or treats. Emphasis was given (without explanation) that the ingredient is only approved for adult dogs, not puppies. We assume the reason is that science submitted to FDA regarding the safety of this ingredient was only for adult dogs. Unfortunately, pet owners are not provided with opportunity to view the science submitted to FDA. The FDA added that if this ingredient is used in a dog treat, the product must be labeled ‘For Adult Dogs’.

Prescription Pet Foods
AAFCO approved into their regulations the FDA Compliance Policy regarding prescription pet foods. This specific FDA Compliance Policy allows pet food to make a drug claim – without the legal requirement of clinical trials to prove the effectiveness. The FDA Compliance Policy also allows these pet foods to be sold only by a veterinarian. The strange part of this action -perhaps concerning part- is that FDA Compliance Policies are not legally binding – they are ONLY FDA opinion. By AAFCO adopting an FDA opinion, this makes the opinion legal when states adopt AAFCO regulations. AAFCO provided no background information to why an FDA opinion was adopted as a regulation, which leaves us questioning the AAFCO motive.

There have been numerous lawsuits against prescription pet foods challenging the high cost and prescription aspect (only available from a veterinarian) of the pet foods. It can be assumed that because AAFCO adopted an FDA non-legally binding policy into law, this prevents lawsuits (or at least one aspect of lawsuits) against these types of pet foods. We have to wonder, did AAFCO adopt this prescription pet food policy to protect the manufacturers of prescription pet food?

Copper
The FDA provided a brief discussion about a recent paper questioning the safety of copper supplements in dog food (linking copper in dog food to disease in dogs). After this paper was published, the FDA agreed to develop a working group to look into the concern. I asked FDA if any of the scientists who authored the paper questioning the safety of copper supplements in dog food were invited to participate in the working group. Dr. William Burkholder of FDA responded stating “No“. He shared their opinions were already stated in the paper AND their opinions would be “biased“.

But…speaking of biased – the working group (including FDA) requested further research into the safety of current copper levels allowed in pet food from a pet food manufacturer; FDA requested further science from Purina Pet Foods. We assume based on the research provided by Purina, Dr. William Burkholder of FDA stated the opinion of the scientific paper was “impractical“. It appears FDA and AAFCO will be ignoring the concerns of multiple scientists regarding the safety of copper supplements in dog food.

Marine Microalgae Oil has been approved for use in can and dry dog food. Safety information was submitted to FDA and can be read here and here. Although AAFCO specifically stated dog food in their discussion, the ingredient is also considered GRAS (generally recognized as safe) by FDA for cats, safety information for cats can be read here and here.

Menadione Sodium Bisulfite Complex
Even though this ingredient has been used in pet food for decades, legally it is ONLY approved for use in poultry feed. During this AAFCO meeting, there was discussion that took place over two sessions (and at least 2 hours of discussion) about finally approving the ingredient for use in pet foods. AAFCO formed an “expert panel” to investigate the safety of Menadione Sodium Bisulfite Complex (even though it is already used). The expert panel – with input from a Purina Pet Foods white paper – determined the ingredient was safe for pet foods. BUT…the white paper that the safety of this ingredient is (in part) based on is “confidential”.

A representative from FDA – Dr. William Burkholder – posed the question to Purina ‘why make the white paper confidential when you are arguing the safety of an ingredient’? (VERY good question.) It was left that perhaps Purina will provide a redacted version of the white paper – but only to the AAFCO committee (not to the general public).

This particular ingredient is quite a mess. Menadione Sodium Bisulfite Complex is currently used in pet foods illegally – and has been for years. Safety issues aside – law is law. And law has been ignored. Now, years later, they decide they need to fix their problem. If law was enforced in the first place, they wouldn’t be in this position today. This incident proves that regulatory’s selective enforcement can turn and bite them.

AAFCO’s efforts to update animal protein ingredient definitions was briefly discussed by Stan Cook (Missouri Department of Agriculture, Pet Food Committee co-chair). No time frame was discussed to how long these updates will take, however they alluded it would take years. Mr. Cook did acknowledge these updates are necessary stating many ingredients in pet food have changed over the years without the definition changing.

FDA Center for Veterinary Medicine (CVM) Director of Surveillance and Compliance Dr. Tim Schell was a keynote speaker. He provided a twenty plus minute pre-recorded speech bragging about FDA’s work. Dr. Schell shared that thanks to additional funding provided to CVM the agency was able to hire multiple new employees. However, explained by him and repeated by another FDA representative later in the meeting (Dr. David Edwards) the additional FDA employees were hired to benefit industry – not pet owners. FDA bragged the new employees are working to approve new feed ingredients. There was no mention of new employees to perform more safety testing of pet food, no mention of new employees to investigate consumer complaints of pet food related illnesses or deaths.

Opinion: All of the discussions that occur at AAFCO, as well as all scientific information discussions are based on – should be public information easily accessible (and at no cost) to pet owners and veterinarians. The decision AAFCO made regarding the Human Grade Pet Foods Guidance Document is the proper way all regulations in pet food should be made. Publicly and allowing public comment. We succeeded in getting one tiny document public and open for comment, now we need everything else public and open for comment. Hopefully one day.

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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What’s in Your Pet’s Food?
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The 2021 List
Susan’s List of pet foods trusted to give her own pets. Click Here to learn more.