Pet Food Regulations

Economically Motivated Adulteration

The FDA defines Economically Motivated Adulteration as the fraudulent, intentional substitution or addition of a substance in a product for the purpose of increasing the apparent value of the product or reducing the cost of its production, i.e., for economic gain. When will it end with our pet’s food?

Susan Thixton

Published

February 11, 2010

The 2007 pet food recall – ChemNutra – is the perfect example of economically motivated adulteration; vegetable proteins with added melamine to increase the protein percentage and increase the profit. From the Miller/ChemNutra indictment, ChemNutra knowingly imported wheat gluten from China with the wrong import codes on the shipments. Had the correct, legal, and honest import codes been placed on the shipment(s) of melamine tainted vegetable proteins, the proteins would have required testing and thousands of pets would not have died.
“Based on Sally Qing Miller’s training and experience, she knew that products exported from China and imported into the United States with HS code 3504.0090 would not be subjected to mandatory inspection by AQSIQ prior to leaving China whereas products exported from China and imported into the United States with HS code 1109.000 would be subjected to mandatory inspection by AQSIQ prior to leaving China.”

“Defendants ChemNutra, Sally Qing Miller, and Stephen S. Miller did not disclose to said customers the material fact that XAC wheat gluten had been exported out of China and imported into the United States with the use of a code that avoided subjecting the product to mandatory inspection by AQSIQ prior to leaving China.”

http://www2.lasvegasnow.com/docs/miller_indictment.pdf

Economically Motivated Adulteration

The FDA held a meeting addressing the concerns of Economically Motivated Adulteration back in May 2009. “The purpose of the meeting is to stimulate and focus a discussion about ways in which the food, (including dietary supplements and animal food), drug, medical device and cosmetic industries, regulatory agencies and other parties can better predict and prevent economically motivated adulteration.” http://www.fda.gov/NewsEvents/MeetingsConferencesWorkshops/ucm163619.htm

Slapping the hand of ChemNutra Sally and Stephen Miller with probation and a mere $25,000 fine sure isn’t an effective method to ‘prevent economically motivated adulteration’.

The FDA itself provides some pet foods with a free license to economically motivated adulteration. Every pet food that contains the ingredients by-product meal, meat meal, meat and bone meal, animal digest, and or animal fat could be considered adulterated according to Federal Law. FDA policy (which by the way does not override Federal Law but no one of authority seems to care) tells Field Inspectors to NOT enforce Federal food safety law; it is acceptable to FDA that diseased, dying, dead, and disabled (4D) animals can be rendered into the above common pet food and pet treat ingredients. Animal protein ingredients from 4D animals are neatly packaged into a shocking number of high priced pet foods and treats. The key to the vault; economically motivated adulteration.

When will it end?

Recent history has taught us no one of authority is going to stick up for pets; no one of authority seems to believe our pets are of any value except for profit to industry.

The good news is that there are a growing number of pet food manufacturers that are putting quality in front of profit. There are a growing number of independent pet food stores that refuse to sell the economically motivated pet foods. Our mission is to support these people. Find the pet food that answers your questions promptly and honestly, the pet food with the highest of quality of ingredients, from the independent pet food store (or directly from the manufacturer if available) that wouldn’t dare allow the tiniest box of treats that contain animal fat or by-products on their shelves. Shout their names from your rooftops! Pester your family and friends to ONLY purchase from the conscientious manufacturers and retailers.

If the FDA and some lame judge won’t put an end to economically motivated adulteration – we can.

Wishing you and your pet(s) the best,

Susan Thixton
Pet Food Safety Advocate
Author, Buyer Beware
Co-Author Dinner PAWsible
TruthaboutPetFood.com
PetsumerReport.com

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