Another AAFCO Update

Here are some notes from the afternoon sessions of Day 1 at AAFCO…

On Monday afternoon, the Canadian regulatory authority gave an ‘update’ to what is going on in animal feed/food regulations in Canada. This Canadian government representative went into detail of many changes Canada is implementing to make animal feed/food safer. Her presentation was about 15 minutes (or so). At the end of her presentation – I walked to the microphone and asked “With all of these updates Canada is implementing, do these updates include pet food – cat and dog food?” The answer “No”. The Canadian food regulatory system does nothing with pet foods – nothing. I then asked “Canadian consumers pay a sales tax on each pet food purchase – which is revenue for the government – don’t these consumers deserve something in return for that revenue?” The response “It’s a big government.” I tried one more time to emphasize the significance of this with “Many Canadian consumers have shared with me that they want to support pet food manufacturers in their own country, but due to Canadian government having no oversight of pet foods manufactured in Canada, they are turning to US manufactured pet foods.” No response.

(Pet foods manufactured in Canada but sold in the US have to meet all of the US requirements. Only pet foods made in Canada and sold in Canada would not have any government oversight.)

She did say that the food safety authorities are holding ‘Town Hall’ meetings across Canada beginning in February. If any Canadian consumers can attend one of these meetings – you might be able to express your concern to government authorities there. The bad news is, I don’t have information of where or when these meetings will be. You can check your food safety government website for more information. (And if anyone goes, please let me know what happens.)

Also in the afternoon session was a meeting that I didn’t fully understand. The title of this meeting was “AAFCO Feed PC Harmonization Work Group, Food Safety Modernization Act Model Bill Language”. ‘PC’ stands for (I believe) Production Controls or Processing Controls. In a working group (these working group meetings are held via phone conference in between regular public AAFCO meetings) AAFCO and members of industry (and I assume representatives of FDA) met and developed model (proposed) rules that when approved at public meetings would be added to the AAFCO big book of regulations (known as the Official Publication). I believe that the work done was to get the AAFCO rule book up to date to match the new regulations of FDA’s Food Safety Modernization Act. (It was all very confusing.)

They proposed three different options – one being “Option A. All food and drug rules. Food and drug rules. Applicable federal regulations including recodification contained in Code of Federal Regulations, title 21, parts 1 to 1299, not otherwise adopted herein, also are adopted as feed rules of this state.” The other options (Option B and C) did not include the full federal regulations. And Option A got the most comments – few liked it. From what I understood (clearly, it wasn’t much) Option A is the full Federal Food, Drug and Cosmetic Act. So my understanding is that if a state adopted Option A into their state laws, the full Federal Food, Drug and Cosmetic Act (FD&C Act) would become state law. As reminder, the FD&C Act are the federal laws that state a diseased animal or an animal that has died other than by slaughter is NOT allowed into any food (including pet food). These materials are considered adulterated and illegal. FDA – the federal authority – has Compliance Policies that allow these materials into pet food (without consumer notification) — But…states do not have Compliance Policies. So, if Option A was implemented into state law, all of the pet foods that contain rendered diseased animals or rendered 4D animals would be illegal (per state law). An FDA representative said if Option A was adopted by states it could have “unforeseen, detrimental consequences”. I assume he was meaning that so much of animal feed/pet food would not be legal to be sold in these states.

Those “unforeseen, detrimental consequences” are in the eyes of the beholder. Waste material recycled into animal feed/pet food is right now a violation of federal law. It’s just that no regulatory authority (FDA) chooses to enforce those federal laws. I’ll all for Option A (at least if I understand this whole confusing situation correctly) – it is ridiculous that so many pet foods and animal feeds violate federal food safety law. And worse yet, no consumer is informed if they are purchasing an illegal pet food product.

Hope all of the above makes sense – like I said, the one meeting was confusing to me so I hope I didn’t confuse every with my notes about it.

Today is a very full day – meetings from 9 until 5 (or later) straight through. Today is Ingredient Definitions Committee and Pet Food Committee. You can listen into the madness – to see how, click on either of the meetings to view the agenda – information is provided there on how to hear the meeting.

Thanks to everyone for your ongoing support!

Susan