AAFCO Meeting Notes

The August 2022 AAFCO meeting is complete.

The FDA was in attendance at this meeting, however they were very hidden with the exception of during meetings. Many state regulators were here, some are friendly and accessible, others not so much.

On Thursday 8/4, Dr. Cassandra Jones of Kansas State University gave a keynote speech. Without doubt, this was the best speaker I’ve ever seen at an AAFCO meeting. Her talk was about how risks in feed/pet food can easily spread and how manufacturers can prevent them.

One interesting study performed by Dr. Jones at KSU was building a mini-feed manufacturing facility inside a laboratory (inside a BSL3 rated lab). This particular study was to monitor how African Swine Fever (ASF) could spread in feed – but it examples how easily any pathogen could spread within a manufacturing facility.

Inside the lab, they produced a batch of livestock feed with clean ingredients. Following typical procedures, after manufacturing they tested the product for ASF – this batch did not test positive (as expected). The second batch they added the ASF virus to one ingredient, manufactured the feed just as it would be manufactured in a typical facility, and then tested the product. As expected, this batch tested positive.

But then they made four more batches of feed. Each batch contained clean/pathogen free ingredients – however, each subsequent batch tested positive for the virus. Four more batches of feed tested positive even though 100% pathogen free ingredients were used. Their study learned that dust from ingredients travel all over manufacturing facilities. If that dust contains a pathogen, the entire plant would be contaminated.

She shared that rarely do companies she consults with want to take preventative measures such as sourcing quality ingredients, stating most just want a “silver bullet” – an additive to include in a feed as a quick fix to control pathogens.

During the Model Bills session there was discussion on editing what “labeling” is defined as. AAFCO suggested that the definition of labeling include website information, which would hold pet food company websites to labeling laws. AAFCO asked for comments, we provided a statement that we’d approve of this – as many pet owners are misled by website claims that are not allowed on labels. Industry was not as happy about it. No decision was made at this session, we’ll have to wait until the January 2023 meeting to see where this goes.

During the Ingredient Definitions session there was discussion from the “Swine Heath work group” – strictly related to swine feed. The interesting thing about this discussion was that due to the “Federal Swine Health Protection Act” many previously used waste ingredients allowed in swine feed would be required to “be treated” prior to inclusion in the feed. In other words, because of federal laws – AAFCO now has to change ingredient definitions to match that of federal law. The waste ingredients that AAFCO has allowed into swine feed for years, will now not be allowed. (We need a Pet Health Protection Act!)

During the Feed and Feed Ingredient Manufacturing session, the discussion was about training for regulatory investigators (state regulators). The trade association AFIA (American Feed Industry Association) suggested AAFCO attend their sessions – to learn from industry, even offering AAFCO “free meeting space“. (Industry training regulators how to inspect…not a good thing.)

And in the Pet Food Committee session, the agenda appeared to state that attendees would be given an “update” to FDA’s work on copper levels in pet food. But that was not the case. There was an update, but attendees were NOT provided with any of that information. The Committee stated information from that update wouldn’t be shared publicly until the January 2023 meeting. However the Committee IS sharing the information with industry members of the Pet Food Committee. (They get to know, but we don’t.)

And there was discussion about Pet Food Label Modernization – something that AAFCO has been working on for years. Unfortunately, there was NO time frame for when these much needed label updates will be implemented. As I’ve done in previous meetings, I again made a plea with the Committee to promptly implement these changes. Industry complained that these are massive changes and will take time for them to implement. And even regulators pointed out that – because these will be introduced as state laws – each state will implement these laws (once finally released by AAFCO) on a different time frame. They complained that this could result in a pet food manufacturer being required to have the new labels in one state, while required to have the old labels in another state.

Unfortunately, my best guess is that pet owners won’t see these label updates for many more years.

The hotel where the AAFCO meeting was held was in downtown St. Louis…directly across the street from the Cardinals baseball stadium. It also happened to be right around the corner from Purina Pet Food’s headquarters. Taken from my hotel room:

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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