An industry representative has submitted a proposal to AAFCO hoping to change the definition to Human Grade pet food. If this passes, Human Grade pet food would change dramatically.
Dr. David Dzanis of Regulatory Discretion, Inc. submitted a proposal to AAFCO Pet Food Committee requesting changes in the definition of Human Grade pet food. The upcoming (January 22 – 24, 2018) AAFCO meeting agenda states the changes proposed are “minor edits” – but they are far from minor. The proposed changes would dramatically change the quality of human grade pet food. Further, the proposed changes would make human grade pet food in violation of human food law.
To read the proposed changes, Click Here.
The challenge to the current definition of Human Grade pet food boils down to jurisdiction – or at least that is the pretense of argument presented (it is suspected there is far more than jurisdiction behind this issue). To understand just how serious this change could be…a brief understanding of food regulation and agency jurisdiction is required.
With human food…
The FDA is the governing regulatory body over Tomato Soup because it contains no meat. A human food that contains no meat is regulated on a ‘trust’ system where the manufacturer is trusted to abide by food laws. The manufacturing of the food is not inspected by regulatory; the plant itself might be inspected by FDA once in ten years.
The USDA is the governing regulatory body over Chicken Noodle Soup because it contains meat. Law requires the Chicken Noodle Soup to be manufactured with a USDA inspector on site, USDA is responsible for assuring the public all ingredients in the food are human edible and all safety standards are followed during manufacturing.
The concerning change submitted to AAFCO…
Currently, the legal definition (the legal requirements) of a Human Grade pet food requires the pet food to be manufactured by the same laws as a human food that contains meat – manufactured under USDA inspection, assuring pet owners all ingredients are human edible and all safety standards are followed during manufacturing.
The argument for the change – submitted by Dr. Dzanis – suggests that because pet food is regulated by FDA, the requirement of Human Grade pet food being “edible” should be removed. In the legal language of food regulations, the term “edible” is not utilized by FDA; FDA uses the legal language of “human food“. But…USDA legal language does use the term “edible“. USDA requires a food that contains more than 3% meat to be “edible” and manufactured under inspection. If the term “edible” is removed from the definition of Human Grade pet food, the link to USDA is removed, the requirement to be manufactured under inspection is removed. If the term “edible” is removed, consumers lose.
The change submitted would result in this…
The proposed change would result in Human Grade pet foods being regulated as a non-meat human food product. It would be based on the ‘trust’ system, trusting that the pet food manufacturer would abide by regulation, trusting the pet food would be manufactured with 100% edible ingredients. Human Grade pet foods would no longer be required to be manufactured under constant USDA inspection – Human Grade pet foods would no longer abide by human food law (same regulation as human food products that contain more than 3% meat).
The proposed “minor edits” to the definition of Human Grade pet food is a bad, bad proposal. Simply put, it lessens the quality of Human Grade pet food. If approved, the result for Human Grade pet food would be…
- Instead of constant government inspection, the facility would be inspected by authorities once every ten years. No direct regulatory oversight of production.
- Instead of government oversight, consumers would have to trust Human Grade manufacturers ARE using 100% edible ingredients.
Certainly, pet foods manufactured to human food non-meat requirements are far better than feed requirements (little to no quality assurances), but this is NOT feed grade pet food. This is food. Should this pass, we can anticipate many more Human Grade pet foods on the market that have not been manufactured under inspection providing consumers with no regulatory oversight to quality – further confusing pet food consumers. Remember, all of pet food legal definitions are private – corporately owned by AAFCO. Consumers will have no access to the definition of Human Grade pet food, most won’t understand that these products would be held to vastly different regulations than human food (with meat).
What can you do?
Tell the members of the AAFCO Pet Food Committee (those that will vote on this proposal) that you do not agree with the proposed changes. Tell them the term “edible” must remain in the definition, Human Grade pet food should be held to the same legal standards as human food with meat.
Voting Pet Food Committee members are:
Kristen Green, Chair, Kentucky Department of Agriculture – email: email@example.com, phone: (859) 257-4496
Stan Cook, Vice Chair, Missouri Department of Agriculture – email: firstname.lastname@example.org, phone: (573) 751-5501
Lizette Beckman, Washington State Deptartment of Agriculture – email: email@example.com, phone: (360) 902-1942
Dr. William Burkholder, FDA/Office of Foods (OF)/Center for Veterinary Medicine (CVM) – email: firstname.lastname@example.org, phone: (240) 402-5900
Kathleen Close, FDA-ORA – email: email@example.com, phone: (515) 244-0480 ext 1003
Charlotte Conway, FDA – email: firstname.lastname@example.org, phone: (240) 402-6768
Laura Earhart, Virginia Department of Agriculture & Consumer Services – email: email@example.com, phone: (804) 371-2667
James Embry, Office of the Texas State Chemist – email: firstname.lastname@example.org, phone: (936) 245-9949
George Ferguson, North Carolina Department of Agriculture & Consumer Services – email: email@example.com, phone: (919) 733-7366
Liz Higgins, New Mexico Department of Agriculture – email: firstname.lastname@example.org, phone: (575) 646-3108
Jan Jarman, Minnesota Department of Agriculture – email: email@example.com, phone: (651)201-6221
Tiffany Leschishin, Minnesota Department of Agriculture – email: Tiffany.Leschishin@state.mn.us, phone: (651) 338-9951
Eric Nelson, FDA, Center for Veterinary Medicine – email: firstname.lastname@example.org, phone: (240) 276-9201
Jo Lynn Otero, New Mexico Department of Agriculture – email: email@example.com, phone: (575) 646-2676
Suzanne Riddle, Missouri Department of Agriculture – email: firstname.lastname@example.org, phone: (573) 522-6786
Jason Schmidt, Louisiana Department of Agriculture – email: email@example.com
Austin Therrell, South Carolina Department of Agriculture – email: firstname.lastname@example.org, phone: 803-415-5220
Below is TruthaboutPetFood.com’s and AssociationforTruthinPetFood.com’s response submitted to the AAFCO Pet Food Committee…
AAFCO Pet Food Committee
Re: Proposed agenda item for “minor edits” to the definition and guidance document for Human Grade pet food.
Representing pet food consumers, TruthaboutPetFood.com and AssociationforTruthinPetFood.com is in disagreement with the proposed changes to the definition and guidance document for Human Grade pet food. The proposed changes would result in Human Grade pet food being non-compliant to human food law.
Human food that contains more than 3% meat is USDA jurisdiction, required to be manufactured under constant USDA inspection. The proposed definition changes ignore proper jurisdiction of a meat based ‘food’ and federal requirement of inspection.
Human food that contains little to no meat (less than 3%) falls under FDA jurisdiction and is not required to be manufactured under inspection. The proposed definition changes attempt to move Human Grade pet food into a non-meat containing ‘food’ product jurisdiction.
As Human Grade pet foods contain more than 3% meat, the proposed changes would – per human food law – produce adulterated Human Grade pet food due to lack of inspection. The term “edible” must remain as it ties Human Grade pet food to the proper jurisdiction for food that contains meat.
This proposal is far more than “minor edits”. This proposal suggests a dramatic change to the definition and guidance document for Human Grade pet food. Consumers should be provided with the same quality and safety standards of ‘food’ with a Human Grade pet food.
There are numerous consumer advocates that are working together to try to stop this proposal. Consumers can help us by telling any or all of the above voting members of the AAFCO Pet Food Committee you disagree with the proposed change. Consumers deserve at least one pet food option that abides by law! The current definition of Human Grade pet food abides by law, the proposed definition would not (and most feed grade pet foods do not abide by law).
For all Human Grade pet food manufacturers, please make arrangements to attend the January AAFCO meeting and voice your opposition to these proposed changes. And/or contact Dr. Cathy Alinovi of Next Generation Pet Food Manufacturers Association for representation on this issue at the meeting.
Wishing you and your pet(s) the best,
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