Documentary film producer Kohl Harrington challenges the Center for Veterinary Medicine’s lack of transparency based on federal law.
When an individual or organization disagrees with the FDA on a particular issue, the official procedure to request the agency change is termed a Citizen Petition. This Citizen Petition is a legal request for change that FDA is required to respond to – either agreeing with the Petitioner and adjusting the way they regulate or denying the petition request. Documentary film producer Kohl Harrington (Pet Fooled) has recently filed a legal request with FDA asking the agency to be transparent with pet owners – he formally asked the FDA Center for Veterinary Medicine (CVM) to write a public rule regarding their allowance of illegal ingredients in pet food.
Government agencies such as the FDA CVM are required to abide by the Administrative Procedure Act – a set of laws written to assure US citizens that government agencies are transparent and provide citizens the opportunity to give opinion on laws.
The federal Administrative Procedure Act states: “The rule of law requires transparency. Regulated parties must know in advance the rules by which the Federal Government will judge their actions. The Administrative Procedure Act (APA) was enacted to provide that ‘administrative policies affecting individual rights and obligations be promulgated pursuant to certain stated procedures so as to avoid the inherently arbitrary nature of unpublished ad hoc determinations.'”
In other words, law requires federal agencies such as the FDA Center for Veterinary Medicine (CVM) to act transparently to avoid random enforcement actions of the agency.
This is exactly what Kohl Harrington is challenging FDA on. He is asking FDA for a very simple thing based on the Administrative Procedure Act; for the FDA CVM to write an official rule regarding their allowed use of illegal ingredients in pet food instead of their current system of “arbitrary nature of unpublished ad hoc determinations” (random enforcement actions).
Kohl Harrington is asking FDA CVM – per federal law – to be transparent. If the CVM is going to continue to allow pet food ingredients to be sourced from diseased animals and animals that have died other than by slaughter, the agency – per federal law – should write a rule expressing this allowance in order to provide the public with transparency.
To read the Citizen Petition submitted to FDA, Click Here.
Pet owners can provide FDA their opinion on Kohl Harrington’s Citizen Petition by visiting: https://www.regulations.gov/docket?D=FDA-2020-P-2360. Click on the blue “Comment Now” box directly across from “Citizen Petition From Pet Schooled The Educated Community”.
To read the response we provided FDA, Click Here.
To learn more about the regulation of pet food from experiences of Kohl Harrington, read his blog; https://www.petschooledpress.com/
Wishing you and your pet(s) the best,
Susan Thixton
Pet Food Safety Advocate
Author Buyer Beware, Co-Author Dinner PAWsible
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