An FDA Aflatoxin related Compliance Policy seems to provide a gaping hole for pet food manufacturers and regulators to dump aflatoxin laden grain into pet food. How can pet food consumers protect their pets without clearly defined regulations? And who is guarding the hen house?
Aflatoxin is a type of mold prone to grain ingredients. First hand experience has shown us high levels of aflatoxin in pet food is deadly (2005 recall), but even low levels of aflatoxins (mycotoxins) over time has shown to be deadly as well. Which makes this FDA Compliance Policy so concerning.
FDA’s CPG Sec. 683.100 Action Levels for Aflatoxins in Animal Feeds explains “Aflatoxins are toxic by-products of mold growth on certain agricultural commodities.” The compliance policy goes on to explain FDA has determined that higher levels of moldy grains could be fed to livestock animals “without presenting a danger to the health of these animals or posing a risk to consumers of food derived from the exposed animals.” So, based on FDA’s findings, the agency raised the limits of aflatoxins (action levels) allowed in various products (corn, peanut products, cottonseed meal…). And then they added this statement…
“There may be situations where circumstances warrant enforcement action at levels below an action level or where enforcement action is not warranted even though an action level is exceeded.”
The above basically states there is no clear limit to aflatoxin levels in animal feed or animal feed ingredients. As well, there is no clarification if these ‘situations’ pertain ONLY to livestock feed or if they could apply to pet food ingredients as well. The Compliance Policy is very grey – which could lead to deadly results in pet foods.
Without a full understanding of what goes on behind the scenes of pet food, it is challenging for pet food consumers to make safe and healthy pet food choices for our pets.
For the record, (and for starters) with this particular FDA Compliance Policy, the questions I would like FDA to provide answers to are…
FDA’s CPG Sec. 683.100 Action Levels for Aflatoxins in Animal Feeds states “There may be situations where circumstances warrant enforcement action at levels below an action level or where enforcement action is not warranted even though an action level is exceeded.”
This statement within the Compliance Policy appears to be a huge regulatory grey area. Does this enforcement/no enforcement policy apply to pet food ingredients? Can FDA give examples of how non-enforcement action is determined, and who makes that decision? What would a circumstance be that would allow no enforcement when a pet food ingredient would be above the action level (20 ppb)? Are these special circumstances public record? If so, where can they be found on the FDA website?
As example, would FDA allow aflatoxin levels of a corn ingredient in a pet food at 50 ppb or 100 ppb? If FDA would not approve an aflatoxin level of a grain ingredient in a pet food over 20 ppb, would FDA require a pet food manufacturer to recall if grain tested over 20 ppb was used as a pet food ingredient? Is the FDA relying on pet food manufacturers to report high levels of aflatoxin to them? Does the FDA/CVM test pet foods for aflatoxin levels? If so, what percentage of pet food testing performed by or performed for FDA is spent on aflatoxin testing?
Aflatoxins are nothing to mess with; they are deadly. Pet food consumers deserve to know the FDA is testing for aflatoxin levels and enforcing the low level limits in pet foods and treats.
Wishing you and your pet(s) the best,
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