Here is what was discussed at the recent AAFCO meeting.
AAFCO disclosed that 42 states were virtually attending this meeting (regulatory authorities from 42 states), 147 representatives from FDA were attending, and a total attendance was 501 individuals. AAFCO charged regulatory authorities $200.00 each to attend, industry and consumer representatives were charged $350.00 each to attend.
The Pet Food Committee agenda stated attendees would be provided with an update regarding the definition of Human Grade pet foods. However, the AAFCO member that was to provide the update – George Ferguson of North Carolina Department of Agriculture was unavailable at the last minute, no update was provided.
Within the update provided for the long standing AAFCO project of updating pet food labels (in discussion for over 5 years), Dr. William Burkholder of FDA objected to the committee’s carbohydrate disclosure for future pet food labels. Dr. Burkholder told the committee that the proposed carbohydrate disclosure was “misleading” to pet owners and told the committee unless this was corrected he would be voting “No” on its approval. Dr. Burkholder also stated “consumer advocates and nutritionists should be against this“. Because AAFCO has removed (kicked out) every consumer advocate from this committee – consumer advocates didn’t know about the carbohydrate disclosure issue until this meeting (all of these discussions are held privately, outside of AAFCO’s public meetings). After Dr. Burkholder’s strong opposition to the proposed labeling requirement, the Pet Food Committee agreed to work further on proposed labeling requirements.
In the Ingredient Definitions meeting the Committee introduced a slightly altered definition of Human Grade:
“Every ingredient and resulting product must be stored, handled, processed and transported in a manner that is consistent and compliant with 21 CRF part 117 and those applicable federal human food laws as required by ingredient, process and/or facility type.”
The committee decided to hold the definition until other documents regarding human grade pet foods (specific requirements of manufacturers) are passed by other committees and the vote will be on all documents collectively. In other words, we wait to see if AAFCO will change the definition to the detriment of existing human grade pet foods.
This same committee approved updates to two pet food ingredient definitions. The ingredient definitions below are the updated and passed definitions – in bold was the update.
Poultry is the clean combination of flesh and skin with or without accompanying bone, derived from the parts or whole carcasses of slaughtered poultry, or a combination thereof, exclusive of feathers (except as unavoidable in good processing practices), heads, feet, and viscera. If it bears a name descriptive of its kind, it must correspond thereto. If the bone has been removed, the process may be so designated by use of the appropriate feed term. It shall be suitable for use in animal food.
Poultry Meal is the wet rendered or dry rendered product from a combination of clean flesh and skin with or without accompanying bone, derived from the parts of whole carcasses of slaughtered poultry, or a combination thereof, exclusive of feathers (except as unavoidable in good processing practices), heads, feet, and viscera. The label shall include guarantees for minimum crude protein, minimum crude fat, maximum calcium (Ca), and minimum phosphorus (P). The calcium (Ca) level shall not exceed the actual level of phosphorus (P) by more than 2.2 times. If it bears a name de4scriptive of its kind, it must correspond thereto. It shall be suitable for use in animal food.
These definitions were submitted for these minor changes by Stan Cook, Missouri Department of Agriculture. Mr. Cook spoke at the August 2020 meeting promising to update multiple pet food ingredient definitions to provide better clarity to pet owners. We were not told if this was the ‘clarity’ he was speaking of last meeting, we certainly hope it is not.
Dr. Cathy Alinovi of Next Generation Pet Food Manufacturers Association asked the committee if they would clarify in the update “How many feathers are unavoidable?” AAFCO refused to add a percentage requirement of feathers allowed. Thus, no supplier is held to any requirement with the definition; “unavoidable” will be left to many interpretations.
Though it has nothing to do with pet food, “Black Soldier Fly Larvae Oil” – the oil of maggots – was approved by AAFCO for pig feed and fish feed.
Unfortunately, AAFCO’s poor attitude toward consumer representatives continues. During the Ingredient Definitions Committee I posted a question. As a paid attendee of the meeting I am provided with the opportunity to pose questions – BUT, my question was ignored. Sue Hayes, AAFCO Executive Director who was moderating the questions specifically told the Committee Chair there was no questions when mine was already posted waiting to be responded to. I posted again, “Why was my comment ignored?” to which AAFCO responded to in an email (not as part of the meeting) something unrelated to what I originally asked. I followed up with AAFCO asking “I would like to know why my comment was ignored, since I paid my $350.00 to AAFCO just like others. Is AAFCO denying me the ability to comment (while accepting my money)?” AAFCO ignored this question too. Because AAFCO did not respond, we don’t have confirmation that the organization is accepting our money while ignoring our questions.
The next AAFCO meeting will be held in August, 2021. Only time will tell if AAFCO plans on continuing their bad attitude towards consumer representatives or if they will truly be an organization that welcomes all attendees and all opinions.
Wishing you and your pet(s) the best,
Susan Thixton
Pet Food Safety Advocate
Author Buyer Beware, Co-Author Dinner PAWsible
TruthaboutPetFood.com
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Vickie Paterakis
January 21, 2021 at 6:50 pm
What a lack of respect you were given after you paid to have your question answered and to be only ignored. This goes to show you just how little if any consideration they have, beyond themselves.
Dick McWay
January 21, 2021 at 6:58 pm
Susan, I share your level of frustration with this group. The appropriate question back at Burkholder should be to please explain how listing carbohydrate values would be “misleading”. It is listed on practically every human food item we buy. Could it be that dogs have zero dietary requirement for carbohydrates? I’ve said it before and I’ll say it here: the FDA, CDC, big food/ag, and big pharma are a criminal, corrupt, cartel whose only interest is not the health of our pets or us humans, but the financial health of their buddies in big pharma and big food/ag. And they have the entire congress in their pocket. A truly pathetic situation.
Susan Thixton
January 21, 2021 at 7:38 pm
I perhaps didn’t explain it properly – Dr. Burkholder was telling the pet food committee their developed system to disclose carbohydrates on pet food labels was misleading – not that carbs shouldn’t be disclosed. I felt he was taking up for pet owners with his comments. It is absurd that AAFCO has taken so long to provide this information to pet owners.