AAFCO Meeting January 2020

The good, the bad, and the ugly from the recent AAFCO meeting.

After being allowed to attend the AAFCO meeting just 4 days before it began, it was a scramble to get to Albuquerque on Monday January 20, 2020. Coming into the meeting the first day, few regulatory authorities made eye contact. The atmosphere was chilly to say the least. But on day two, several went out of their way to tell me personally they were glad I am here. It was clear to me, that not all at AAFCO believed it was the right thing to do to ban consumers and advocates. I want to thank those that at AAFCO who shared their feelings with me – it is greatly appreciated.

AAFCO Executive Director Sue Hays on the other hand, treated me like I was a thug. I approached her after a session on Wednesday – very politely asking if I could have a minute of her time. She intentionally took a full step backwards – away from me – standing facing me, stiff as a board as if she feared for her safety (or perhaps she feared she would attack me). The expression on her face was cold, her eyes glaring at me. I stated to her: “Sue, you know as well as I do that I and the consumers that AAFCO banned were not affiliated with that lawsuit. We tried to talk to you about this, and were ignored. It was insulting to us to be accused of something that we have no affiliation with, and then be ignored.” Still with that look on her face, she told me “Thank you for your statement” and walked away…very quickly. It is a concern that the executive director of AAFCO have such a poor relationship with the largest pet food stakeholder – consumers. But it is great to know that not all at AAFCO feels like this. Perhaps there is hope for the future with some at AAFCO.

A new concern was highlighted at this meeting. AAFCO – “a voluntary membership association of local, state and federal agencies” – is slowing becoming an organization of non-local, state and federal agencies. As example, the Chair of AAFCO’s Model Bills and Regulations Committee is retired from his state government job; he’s a private citizen not held to transparency or accountability of government duties. AAFCO is beginning to implement multiple private citizens into significant positions within their organization – which is a serious concern for conflict of interest issues in the future.

The opening session of AAFCO is always an introduction of all in attendance. What was most surprising was the number of FDA representatives in attendance; an estimated 30 representatives from FDA attended this AAFCO meeting (at tax payer expense).

During the morning session on Wednesday (1/22/20) – the Pet Food Committee meeting, the discussion was regarding “therapeutic diets” – better known as prescription pet foods. AAFCO has been working on what was believed to be regulations regarding these diets, however the regulations they appeared to be developing were based on an FDA Compliance Policy – not based on law. Knowing this is a trick of the regulatory trade (enforcement of a policy as law), I asked the committee to provide clarification to what AAFCO was developing. (Background: FDA policy is FDA opinion, it is not law. As example, it is FDA policy to allow diseased animals and non-slaughtered animal material in pet food with no disclosure or warning to consumers. Law states this material is illegal, FDA policy allows it.) I asked them to clarify if they were planning on introducing regulations based on an FDA policy. After what felt like an eternity of silence, with everyone on the committee looking at each other wondering who was going to answer my question – FDA finally stated that the work AAFCO is doing will “not” be a regulation, it will only be guidance. We will be closely watching this in the future to hold them to their statement law will not be based on a policy.

Also in the Pet Food Committee was another lengthy discussion on what pet food labels will look like and say in the future. This discussion has been ongoing for years – and it remains a topic at every meeting. During this segment, I stepped to the microphone again and made the following statement on behalf of consumers: “I don’t have a question, I’d like to make a statement. And this is not to place blame on AAFCO, the Pet Food Committee, or the working groups that have worked on pet food labeling updates…however…in 2007 Congress promised pet owners labeling updates after the deadliest recall in history. Pets died for those legally required label updates – but in late 2018 Senator Rand Paul submitted an addendum to an unrelated bill and completely wiped the laws off the record. Label updates are significantly important for pet owners to make informed decisions.” My goal was to remind the room – everyone at AAFCO – that consumers have waited long enough for label updates. Hopefully some heard me.

During the same discussion on labeling updates, a Mars Petcare representative told the committee that testing for total fiber in a pet food (instead of “crude fiber” as is currently listed on labels) would be a significant expense to manufacturers; he gave the comparison of $25.00 per test to an estimated $500.00 per test should AAFCO implement certain labeling updates. Interestingly, a laboratory regulatory authority went to the microphone and stated this price increase presented by Mars Petcare was not correct information. She stated the new label claims AAFCO is considering would cost VERY similar to the old style of crude fiber. Further, as a regulator representing the laboratory side of enforcement – she asked that the laboratory regulators be included on decisions like this (to prevent misinformation being given by industry).

The afternoon session on Wednesday also included a keynote speaker from one of the largest rendering companies in the US – Darling Ingredients. Needless to say, his perspective is rendering saves the world from dangerous material that the rendering industry repurposes into sellable products. Mr. Stuewe of Darling proudly stated during his speech “if I can find it – I grind it“. While I understand that dead animal carcasses need to be properly disposed of, my opinion remains that this material is NOT quality nutrition. And it should NOT be used in pet foods – especially with no warning or disclosure to consumers.

Also in the afternoon session on Wednesday was the Ingredient Definitions Committee session. The discussion was regarding FDA’s GRAS (Generally Recognized as Safe) approval of “Krill Meal” in pet foods and treats. The GRAS approval of this ingredient allows no more than 3% (of total ingredients) to be allowed in pet foods/treats – and it comes with some concerns. Krill Meal in pet food will be allowed to contain up to 800 mg/kg of fluoride and up to 67 mg/kg of copper. Science has proven that fluoride can attach to bones which has been associated with bone cancer. I cannot say with certainty this level of fluoride is a risk (would need to research it more), but it appears to be very high. And copper (unfortunately) has no maximum level established in pet food – minimum requirements for an adult dog is 1.83 mg/1,000 calories, 1.25 mg/1,000 calories for an adult cat. But if you consider this ingredient’s level of copper, added to other ingredients level of copper, and then a copper supplement added to the pet food – again this appears to be a concern.

A big thank you to all pet owners out there that pushed to demand we be let in the door! Without all of us pushing, I doubt we would have been allowed in. So thank you to all, I am honored to represent you at AAFCO.

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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