AAFCO Meeting August 2017

Here is information for consumers of what was discussed during the August 2017 AAFCO meeting.

The AAFCO Annual Meeting took place in Bellevue, Washington August 10 – 12, 2017 (there are actually two public AAFCO meetings per year – one in August termed the ‘annual’ meeting, one in January termed the ‘mid-year’ meeting). In our group (we called ourselves ‘the Rebels’) was Dr. Judy Morgan (holistic veterinarian), Dr. Cathy Alinovi (holistic veterinarian representing quality small manufacturers – Next Gen), Chelsea Kent (of Hero’s Pets – independent pet store Colorado), Ashok Ramji (pet owner), Roxanne Stone and Billy Hoekman (Answers Pet Food), and Paul Raybould (KetoPets Sanctuary). We were joined after meeting hours by Kimberly Gauthier (Keep the Tail Wagging), D’Arcy Dent and Nikki and Guy Mael.

As typical of our experience with AAFCO – we are watched and listened to constantly (industry) so we tend to leave the hotel for safer (spy free) locations to relax after meeting hours. We were lucky to enjoy the fish market area of Seattle (including the gum wall pictured below – yes, that is thousands of pieces of gum).

Down to business…

Opening session of every AAFCO meeting is a roll call of attendees. Forty four different states (State Department of Agriculture members) were present, there were 404 total attendees representing 9 different countries. After roll call there was a talk from the director of Washington State Department of Agriculture and then a talk from Dr. Steve Solomon the new director of FDA’s Center for Veterinary Medicine (CVM). Dr. Solomon explained that the FDA has begun required ‘Current Good Manufacturing Practices’ inspections (per the Food Safety Modernization Act) in the animal feed industry. He also told the audience that “anything we do at CVM” has a “scientific foundation”. I did not state it publicly (didn’t want the new director of CVM to hate me right off the bat) – but I know with certainty that CVM does NOT have  scientific foundation for everything they do. The ingredients that FDA allows into pet food – illegally – ingredients sourced from diseased and non-slaughtered animals have NO scientific foundation. A year or so ago I submitted a Freedom of Information Act request for that science proving those ingredients are safe; FDA told me they have no safety information.

During the Current Issues and Outreach Committee Jamie Wiggins of the Northwest Food Processing Association gave a talk regarding “By-Products from Human Food Processing Plants” into animal feed. She shared that 73% of human food processing waste goes to animal food. And her organization was concerned that 36% (of the 73%) of human food processing waste will no longer be able to utilized (dumped) into animal feed due to Food Safety Modernization Act regulation. Us ‘Rebels’ wondered why the ‘human food processing waste’ industry doesn’t reach out to various forward thinking individuals to find a better home for waste than animal feed.

During the Ingredient Definitions Committee Meeting AAFCO made ‘official’ the various poultry ingredients that were changed in years past. The protocol is – ingredient definitions are approved as tentative. Then at a later date are approved as official. The previously tentative poultry ingredients Poultry, Poultry By-Product Meal, Poultry By-Products, and Poultry Meal are now approved.

Another topic of discussion for was the use of hemp in animal feed. To date – hemp is not defined for use in any animal food (or any cannabis product). AAFCO and FDA has asked the hemp (and cannabis) industry to provide safety data – that information has not been provided to date. Regulatory authorities are more than willing – at least it appears so – to approve the ingredient (write a definition and then it is approved), but they need safety data first specific to any species it would be used for.

Complaints were made that hemp (and cannabis) products are currently being sold to the animal industry. The state of Colorado is very active in working with regulatory and industry – and will now a consumer advocate will join that group. Chelsea of Hero’s Pets (from Colorado) will be consumer and retailer advocate joining the Colorado group.

I was asked if consumers want these products. I responded – yes, consumers do want the option for hemp products. Then I was asked why – why do consumers want pet products that include hemp. With much hesitation from me (I knew what would be coming at me after I made this statement) I responded consumers want these products as natural alternatives – as example – for seizures, arthritis. The crowd moaned. The FDA immediately jumped and said those are drug claims and hemp (cannabis) would be required to go through the drug approval process before those claims can be made. I explained that consumers don’t look at hemp or cannabis products as a drug, that consumers want natural alternatives. Richard Sellers of AFIA (American Feed Industry Association) gave me a brief lecture that natural products are not always a good thing.

During the Pet Food Committee meeting the Global Alliance of Pet Food Associations (GAPFA) – which is basically industry trade associations around the world AND Mars Petcare, Hill’s Science Diet, and Purina – approached AAFCO asking for the Vitamin A levels in dog food to be increased.

Existing maximum level for Vitamin A in dog food is 62,500 IU per 1000 kcal (calories); the Global pet feed manufacturers want to increase that level to 100,000 IU per 1000 kcal. No decision was made however it was agreed that FDA and several scientist/veterinarian volunteers would look further into this topic. Dr. Jean Hofve and Dr. Cathy Alinovi asked to be a part of the discussion – it was NOT confirmed they would be allowed.

Another discussion topic was a verification process for pet food companies that don’t quite meet the full definition of a human grade pet food – most specifically raw pet foods manufactured under USDA inspection. The suggestion was a program offered by the USDA Agriculture Marketing Service (AMS). The USDA AMS provides a fee based verification service that could verify the human grade claim for raw pet foods that wish to make the human grade claim (verifying all ingredients are human edible, all supplements are human edible, and manufacturing abides by human food law). Again, no decision was made on this – there was only discussion.

It was also determined that two AAFCO website pages – The Business of Pet Food (content directed towards industry) and AAFCO Talks Pet Food (content directed towards consumers) will need to be updated more frequently. Decision was made to update these pages on a yearly basis (as they are currently out of date).

Next was reports from the Pet Food Label Modernization working group. This is the working group I am on but am not allowed to share information discussed with consumers. Because these reports were provided in the public meeting – I can now share. A little background information…after the 2007 pet food recall Congress wrote law requiring FDA to update pet food labels (and update ingredient definitions including standards of quality) – to provide consumers with more information. FDA was required to complete this task by September 2009. FDA has never completed that task (label updates or updated ingredient definitions and standards of quality). It is unknown if FDA made the request to AAFCO to complete this work – all we know is that the AAFCO Board of Directors requested a working group be formed (August 2016) to update pet food labels.

The Label Modernization working group consists of multiple members of State Department of Agriculture, multiple members representing Big Pet Feed and Big Pet Feed ingredient providers, Dr. Cathy Alinovi representing small pet food manufacturers and two consumer advocates (myself and Mollie Morrissette). Our full working group was split up into four groups (named below). The two groups I was in met almost weekly over the past year (one group on Tuesdays, another group on Wednesdays). Almost everything that I suggested to the group (directly from consumer input) has been rejected. The one exception is carbohydrate information (explained below under Nutritional Facts Box group).

Please know that none of the following reports are final – this is all very preliminary, a work in progress.

Nutritional Adequacy/Feeding Directions sub-group (I am a member of this sub-group)

The Nutritional Adequacy statement on pet food labels is the sentence that says something like this: (name of product) provides complete and balanced nutrition for adult cats. Formulated to meet the nutritional levels established by the AAFCO Cat Food Nutrient Profiles for adult cats. Current regulations allow the long statement to be anywhere on the pet food label – which makes it difficult for consumers to find. This group designed an easy to see oval that is suggested to be on the bottom right front of each label. The oval will be white with black text only providing the Complete and Balanced statement specific to what ever life stage (example: adult dogs). For pet treats or foods that are not complete and balanced, the group suggested the symbol should be a different shape for easy recognition – this symbol will be rectangle again providing brief information such as ‘Snack’ ‘Supplemental Feeding’.

For feeding directions, the group addressed the inconsistency of feeding directions provided on pet food labels. As all pets are different, this group felt a better way for consumers to know the proper amount to feed would be based on ‘body condition scores’. The group suggested AAFCO host a webpage with visual aids for consumers to determine body condition scores of their pet – enabling them to adjust the feeding amount accordingly. This group also felt that feeding directions should be required for snacks and treats (currently it is not required).

Safety Statement sub-group (I was not a member of this sub-group)

This group discussed if it should or should not be required for all pet food label styles (kibble, can, raw) and treats provide a safety statement (currently only raw pet food is required to include a safe handling statement). The group has requested recall history data from FDA, FDA has yet to provide that data to the group. No decision will be made until FDA provides information. A request was made by Chelsea Kent of Hero Pets (one of our Rebels) to also request data from the Centers for Disease Control (CDC). To date, kibble is the only style of pet food that is documented to have caused human illness (Diamond Pet Food – 2012). This group is also still in discussion if safe storage statements should be required on the pet food label.

Nutritional Facts Box sub-group (I am a member of this sub-group)

This group developed a Nutrition Facts Box to (hopefully) be added to pet food labels – similar to the nutrition facts box on human food labels. It has not been determined what nutrients will be provided within the pet food nutrition box. For certain, similar information to the current Guaranteed Analysis (protein, fat, fiber, moisture) will be included. A significant change (and requested by consumers) is carbohydrate information. (Hopefully) This will be stated through the calorie statement. This group proposed a calorie breakdown per container (for canned foods) or per cup to read something like this (example numbers): Calories obtained from protein: 45 kcal, Calories obtained from fat: 35 kcal, Calories obtained from carbohydrates: 65 kcal. The ‘crude’ protein/fat/fiber which is currently stated on pet food labels will be changed – ‘crude’ will be removed from the label (however the analysis method to verify protein/fat/fiber will still be ‘crude’ methods).

Ingredient Statement sub-group (I was not a member of this sub-group)

This group is still in discussions. One of their possible suggestions was to make it optional for manufacturers to list Vitamins and Minerals like this: Chicken, Chicken Fat, Potato, Minerals (Copper Sulfate, Calcium Pantothenate, Sodium Selenite), Vitamins (Vitamin B-12 Supplement, Thiamine Mononitrate, Vitamin D-3 Supplement, Riboflavin Supplement).

Of huge significance to consumers (this is what I so wanted to share with consumers but was not allowed to), this group determined there are “villain ingredients” in pet food. Villain in that consumers have a bad perception of these ingredients. This group decided it was in the best interest of consumers to change the names of these ‘villain ingredients’ (although it was later shared that the group was not in consensus). When I first learned of this (horrible) decision, I objected adamantly. During this meeting – I objected again, telling the committee “I am certain it is not in the best interest of consumers to put the villain ingredients into the witness protection program by changing their names. It is hard enough for consumers to know what they are buying because all ingredients are in the OP (Official Publication – away from consumer awareness).”

I cannot disclose what those villain ingredients are, as they were not mentioned in the public meeting (I am only allowed to tell consumers what was discussed in the public meeting). Consumers can probably correctly guess which ones are the villain ingredients. I was told any possible changes to ingredient names would move the discussion to the Ingredient Definitions Committee (and that committee chair asked if he could use my ‘witness protection program’ line – I gladly gave him permission).

With 5 minutes to go before the meeting was over, the last thing to happen at this AAFCO meeting was FDA’s betrayal of pet food consumers. This is a story too long to continue here. And because what FDA did is so, so bad – it deserves it’s own special post. Click Here to read what FDA did to pet food consumers.

After FDA’s debacle (I’m being kind phrasing it that way), one last ‘thing’ happened. Eight members of AAFCO agreed to meet face to face with Nikki and her husband Guy – the owners of the pug Talula that died from Evanger’s Pet Food. We all met in a quiet section of the lobby – back in a corner with no ears around us. Nikki brought pictures of Talula – baby pictures up to pictures of her in the veterinary hospital after eating the Evanger’s Hunk of Beef pet food. Nikki told them the full story – she was crying through much of it – the AAFCO folks were crying too (honestly). They were very patient with her, listened to her every word, asked questions. They were wonderful. They admitted there are holes in the regulatory system that need to be fixed, they promised to look into this further. I think both Nikki and Guy felt good at how this discussion went (they did not feel the same with their discussion with FDA).

Though only time will tell, personally I think it was good for the regulatory folks to hear the detailed story of what happened to Talula. It is not an easy story to hear (I was crying too), but it is one the people whose job it is to protect our pets needed to hear. Special thank you goes out to Meagan Davis of Louisiana Department of Agriculture for making this meeting happen.

My sincere thanks to all of our group of Rebels. I remember the days when I was alone at AAFCO meetings – I hid a lot in my room. It is wonderful to have great people there to share the ‘fun’ of AAFCO with. Thank you all for going!

And my sincere thanks to pet food consumers for supporting this website so that I can go to AAFCO meetings. I couldn’t do it without all of your support.

The next AAFCO meeting will be in Anaheim, CA in January. Information will be posted closer to time about that meeting should any pet owner wish to attend.

Again, to read the story about what FDA did to consumers at AAFCO – Click Here.

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

What’s in Your Pet’s Food?
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The 2017 List
Susan’s List of trusted pet foods.  Click Here

Have you read Buyer Beware?  Click Here

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