Death by Dog Food: A Critical Examination of Pet Food Regulation in the United States
An honest examination of pet food regulations from a law student.
Google is a wonderful thing. You can search the Internet and find some revealing information. The New York State Bar Association offers a writing contest each year for law students. The following excerpts are from a very detailed document found on the New York State Bar Association website that won First Place in the 2013 writing submission contest…
While most Americans assume the federal government is protecting their pets from consuming diseased animals and harmful substances, the unfortunate reality is that a lack of resources and a combination of industry pressure has left pet food safety in peril. Many pet owners are unaware of the hidden dangers lurking inside the food they feed their pet every day.
At first glance, it appears that pet food is heavily regulated but closer examination reveals a complex web of industry-dominated groups promulgating self-serving rules and regulations that will continue to ensure a healthy profit.
In an effort to restore consumer confidence in pet food safety, the United States Food and Drug Administration (FDA) should re-examine mandates given to them by Congress in recent years. Instead of allowing pet food industry representatives to secure legislation allowing a non-governmental organization, dominated by industry insiders, to take over some of these responsibilities, the FDA should promulgate appropriate regulations itself.
As will be discussed below, the FDA is aware that potentially dangerous substances are entering pet foods through the rendering process.
The last sentence above is significantly true; the FDA is aware of dangerous substances in pet food – but the agency refuses to take action. In March of 2016, I was provided a meeting with FDA in which the agency was provided a wealth of documentation proving the risk to pets of certain rendered pet food material – including a statement from sister federal agency USDA (to the risk of rendered pet food ingredients). This material is a violation of federal law (The Food Drug and Cosmetic Act). The FDA openly stated in this meeting – they will continue to ignore federal law with pet food and will continue to allow rendered risk material into pet food.
More excerpts from Death by Dog Food: A Critical Examination of Pet Food Regulation in the United States…
As part of its new proactive approach to food safety in general, as mandated by the Federal Food Safety Modernization Act of 2011, the FDA should prohibit certain production practices that allow risky substances to enter pet food before there is another national crisis. Numerous pets should not have to die because the FDA could not muster the will to stand up to the pet food industry.
While the FDA may not agree with or like the mandate given to them by Congress, they had a duty to meet their entire obligation and promulgate all of the appropriate regulations called for in the FDAAA. Partial compliance is not acceptable for a federal agency charged with protecting the nation’s food supply. At the expense of animal welfare, the FDA has decided to ignore this deadline and continues to allow the industry to self-regulate.
In 2003, the Scientific Steering Committee for the European Parliament and Council concluded that animal by-products derived from animals not fit for human consumption should not enter the feed chain and their uses should be limited. To this end, the Council adopted a regulation dividing animal by-products into three categories based on their potential risk to humans, animals, and the environment. The regulation limited the use of animal by-products in pet food to Category three materials, which include by-products derived from healthy animals slaughtered for human consumption.
Prior to passage of the regulation, raw material of a lower standard was permitted in pet food. The practice of recycling cadavers and material unfit for human consumption in the feed chain was a factor in spreading BSE and other epidemics in European countries.
Animals in the U.S. are being exposed to harmful chemicals and other ingredients due to the type of animals rendered into meat meal and the practices of the rendering industry. As discussed above, condemned animals, road kill, grocery store garbage, and euthanized cats and dogs are just some of the substances permitted for use in pet food.
Feeding our pets diseased and condemned leftovers from the human food supply does not constitute the good, or even adequate, treatment these animals deserve.
This author is completely right. The FDA was charged by Congress (in 2007) to establish updated pet food ingredient definitions, to be completed by September of 2009. The FDA has not completed this Congressional requirement; FDA ignored the deadline.
Pet food in Europe (European Union) cannot include the hideous waste that FDA allows in the U.S. As this author explains, the FDA – and in turn each and every State Department of Agriculture – is protecting industry, not pets.
It bears repeating…“Feeding our pets diseased and condemned leftovers from the human food supply does not constitute the good, or even adequate, treatment these animals deserve.”
If FDA and State Department of Agriculture would enforce existing law, pet owners would not be unknowingly feeding diseased and condemned leftovers to their beloved pets. Criminal.
It is the duty of pet food regulatory authorities to enforce law.
Click Here to read the full paper.
Wishing you and your pet(s) the best,
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