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FDA’s Unacceptable Proposed Definition of Feed Grade

Below you will find FDA’s unacceptable and misleading proposed definition of “feed grade” and my response.

Below you will find FDA’s unacceptable and misleading proposed definition of “feed grade” and my response.

Please note: this is not a final decision, this is all in ‘discussion’.

In preparation for another online meeting next week, FDA submitted the following definition of feed grade to our small working group…

Feed grade: material that is safe, functional, handled, and labeled appropriately for its intended use in animal food.

The FDA also stated that they didn’t feel it was “especially useful” to include any mention of Compliance Policies in the feed grade definition, sharing that “Those substances are atypical feed ingredients, and are handled on a case by case basis.”

(FDA Compliance Policies allow feed ingredients/pet food/animal feed to violate federal law. Federal law requires a food – defined as what humans and animals consume – to be sourced from a non-diseased animal and a slaughtered animal. FDA Compliance Policies allow pet food and animal food to source meat from diseased animals and animals that have been euthanized or died in the field. Some Compliance Policy allowed materials are “handled on a case by case basis”, but most are not.)

My response to this definition from FDA…(posted on the AAFCO website within our group)…

From the consumer perspective, this definition is completely unacceptable and misleading. Why would FDA want to hide from the pet consumer public the inferior quality of some feed ingredients with this definition? Why can’t the definition of feed grade be honest and transparent? Your/FDA’s definition is protecting feed grade ingredient providers, instead of protecting the consumer (and the consumer is who has to deal with the consequences of inferior feed grade ingredients).

Feed grade ingredients are not labeled to the consumer. They might be labeled to each manufacturer (by the supplier), but they are not labeled/disclosed to the consumer. Yes, you are correct – they should be “labeled appropriately”. “Labeled appropriately” to the consumer. Will consumers be provided this information on pet food labels?

Justifiably so, human grade is required to jump through multiple hoops to make the claim. On the other hand, feed grade accepts almost any waste material, in almost any condition, and FDA wants to define it with a far less than transparent definition. This definition is not serving the consumer, it is serving industry.

We have provided sufficient evidence that not all feed grade material is “safe”. Was that information just dismissed?

What does “handled appropriately” mean? Extremely vague.

We are asking for transparency. If regulatory authorities wish to believe that diseased animal tissues and tissues from 4D animals are safe for animals to consume – fine. If regulatory authorities wish to believe that pesticide and chemical laden ingredients are safe for animals to consume – fine. But at least be honest about it through legal definitions. Transparency will allow the consumer to make up their own minds to what quality of ingredient pet food they wish to purchase.

Again – this definition lacks transparency, is misleading to the consumer, and unacceptable.

Click Here to view the detailed information that Dr. Jean Hofve provided to this working group in reference to terming ‘feed grade’ as “safe”. What Dr. Hofve provided to this group (included FDA) has 2 1/2 pages of citations from scientific studies and published literature. All of her evidence to the questionable “safe” claim of some feed grade ingredients – to this point in the discussion – has been ignored.

(Please know that the information provided by Dr. Hofve above is included in her new e-book and so much more. The e-book “What Cats Should Eat” is available on Amazon.com and from Dr. Hofve’s website. This information is published here with her permission as she too believes that consumers should be informed of what they are purchasing. Please support Dr. Hofve’s work and her efforts advocating for consumers!)

The next meeting on this subject will be Tuesday November 24, 2015. I will post another update after that discussion.

 

Updated information: Thanks to an idea from one of you wonderful consumers, the following additional comment was provided to our ‘discussion’ group on feed grade this morning (11/21/15)…

Several quotes from Merriam-Webster seemed appropriate in response to FDA’s proposed definition of feed grade…

Full Definition of DEFINITION
1 :  an act of determining; specifically
2 a :  a statement expressing the essential nature of something
b :  a statement of the meaning of a word or word group or a sign or symbol
c :  a product of defining
3 :  the action or process of stating the meaning of a word or word group
4 a :  the action or the power of describing, explaining, or making definite and clear
b (1) :  clarity of visual presentation :  distinctness of outline or detail
(2) :  clarity especially of musical sound in reproduction
c :  sharp demarcation of outlines or limits
http://www.merriam-webster.com/dictionary/definition

Full Definition of VAGUE
1 a :  not clearly expressed :  stated in indefinite terms
b :  not having a precise meaning
2 a :  not clearly defined, grasped, or understood :  indistinct; also :  slight
b :  not clearly felt or sensed :  somewhat subconscious
3 :  not thinking or expressing one’s thoughts clearly or precisely
4 :  lacking expression :  vacant
5 :  not sharply outlined :  hazy
http://www.merriam-webster.com/dictionary/vague

Full Definition of MISLEAD
transitive verb
:  to lead in a wrong direction or into a mistaken action or belief often by deliberate deceit
intransitive verb
:  to lead astray :  give a wrong impression
http://www.merriam-webster.com/dictionary/misleading

 

Wishing you and your pet(s) the best,

Susan Thixton
Pet Food Safety Advocate
Author Buyer Beware, Co-Author Dinner PAWsible
TruthaboutPetFood.com
Association for Truth in Pet Food

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23 Comments

23 Comments

  1. Dianne

    November 20, 2015 at 6:39 pm

    It just occurred to me, that in terms of the argument that all this garbage would go to the landfill, if it is indigestible, it will still end up in the landfill via dog and cat poo. The difference is the cost of disposal is instead passed on to municipalities.

  2. Mollie Morrissette

    November 20, 2015 at 6:56 pm

    That is absolutely unacceptable. Particularly, in light of the excellent report published yesterday by the Cornucopia Institute. It seems we are going to have to fight them tooth and nail over this topic.

  3. Linda

    November 20, 2015 at 7:42 pm

    thank you for fighting this absurd inequity

  4. Cheri Fun Fellinger

    November 20, 2015 at 7:56 pm

    FDA sucks hard. You summed it in the one sentence “This definition is not serving the consumer, it is serving industry.” At this point I have to ask myself what purpose does FDA serve? They aren’t doing anything for me. If they aren’t working to protect the public through monitoring producers and manufacturers than it’s just all a big free for all and anyone can do anything they want. If they aren’t going to be honest about what goes into feed grade why should I believe they are honest about what goes into human grade? It’s apparent that we can’t trust labels PERIOD. I am going back to feeding a home prepared diet to my animals. I pay 1/3 less per year to do so anyway. I’m just sickened by their proposed definition of feed grade. I give them a big F as their grade!

    • Jane Eagle

      November 21, 2015 at 6:06 pm

      I agree, and would like perhaps a splinter group work on de-funding the FDA. WE pay them to protect us from bad food and drugs; since they do neither, and clearly get paid by industries, there is NO reason whatsoever for our tax money to be wasted on paying them to NOT do the job we are paying for!

  5. Brenda Boutin

    November 20, 2015 at 8:32 pm

    Yeah, plastic fits that description.

  6. Valerie Noyes

    November 20, 2015 at 8:57 pm

    There is really only one question for FDA. “Do you lie for Big Pet Food because they’re your buddies, or are they paying you off?”

  7. Renee

    November 20, 2015 at 9:31 pm

    Maybe they don’t own pets!

  8. james gearhart

    November 20, 2015 at 9:59 pm

    Thanks SO MUCH for carrying on the good fight , Susan. The FDA has been bought outright by corporations. I believe they actually fund it now. I know Big Pharma doles out ALOT of money to get their new drugs to the marketplace TOO soon to be tested correctly. If big pharma does it, I’m sure big agra & big chemical do too.

  9. Laurie Matson

    November 20, 2015 at 10:05 pm

    I would strongly say that big pet feed is paying fda some really big dollars and they have them in the palm of they’re hand!!!

  10. Nora

    November 20, 2015 at 10:55 pm

    They will never, never put on the label what is actually in the garbage that we pay for and feed to our pets. They would be out of business if they did. Just don’t buy it. Make your own food. Let’s hope all the companies that produce this garbage go out of business. Ever wonder where “mad cow disease” comes from? It’s the crap that is in the so called “feed grade” food that the cattle are being fed and then our beef purchases at the grocery store are being marketed as “human grade” and we end up eating that crap when we put a steak on the barbecue.

  11. Pat P.

    November 20, 2015 at 11:13 pm

    Not only is this “feed-grade” definition deceptively vague and inaccurate, but it is an insult to the intelligence of pet owners and consumers (ok,maybe, not all of them). Safe”?! For who?!

  12. Helen Thompson

    November 21, 2015 at 1:28 am

    The FDA……They are traitors, sellouts and I am ashamed to admit they are fellow Americans……and that, is wording it nicely.
    Brave men and women gave their lives to build this great nation and the FDA does nothing but spit in the faces of all.

  13. Anne

    November 21, 2015 at 9:38 am

    Can someone provide an email address for the highest person in the FDA to contact regarding the FDA’s total sellout? Maybe if everyone on this site sent a daily email to the FDA, eventually, they might take notice. Maybe.

    • Susan Thixton

      November 21, 2015 at 9:45 am

      Dr. Bernadette Dunham is head of FDA’s Center for Veterinary Medicine. To find anyone’s email or contact information at FDA you can search the employee directory here: http://directory.psc.gov/employee.htm

    • T Allen

      November 21, 2015 at 3:21 pm

    • Jane Eagle

      November 21, 2015 at 6:14 pm

      FDA will not change because several hundred people complain. More effective for all of us to contact our congresspeople and senators and demand that they either de-fund this fraudulent agency, or look into their problems.
      http://act.commoncause.org/site/PageServer?pagename=sunlight_advocacy_list_page
      This page will give you contacts for all your reps, from POTUS to state assemblies. You do NOT end up on any lists.

  14. gail .s.

    November 21, 2015 at 10:09 am

    so if the members of the FDA went out to dinner and the menu just said “meat and vegetable dinner” would they order that? Or, would the dialogue go like this.
    What kind of meat is that?
    Cooked.
    But, what kind?
    Edible.
    I should hope so…but, what kind of meat is it?
    Some big pieces, some small.
    …..you get the picture. That is what they are providing us. Gibberish, that doesn’t say anything useful.

    • Dianne

      November 21, 2015 at 2:58 pm

      Great comment.

  15. Anthony Hepton

    November 21, 2015 at 11:43 am

    Susan, Once again, thank you for a great challenge to the regulators who appear to be regulating for the pet food manufacturers and the food waste disposal industry. Their definition fails in it’s first requirement, SAFE. Just what is their definition of safe, is it the FDA version of “considered safe” which they use for meat, poultry and grain, or is it “generally regarded as safe” or GRAS for which there are specific legal requirements, or do they just think it’s safe because it is subjected to high temperatures which may kill most bacteria but will have no effect on many of the contaminants professionally listed by Dr Jean Hofve in her referenced summary.
    In any of the above definitions of SAFE, there is a requirement to have data that backs up the claim and while that may exist for such contaminants as mycotoxins for which there are established tolerances, these alone are no assurance of safety when products pass or fail based on inadequate sampling methods.
    We know the Pet Food Industry’s position when management personal claim that the number of complaints they receive pales in comparison with the number of dogs they feed. That is the same as saying the payments we make for the illness and death of pets pales in comparison with our profits.

  16. Gitta

    November 21, 2015 at 3:54 pm

    It seems we have brought religion into the labeling of pet food. The believe that something is safe. Or perhaps the wishful thinking that it is. Then we have brought magic thinking into the labeling of pet food.

    Well, I can play too. I believe crap is not safe. If the FDA and their lobbyists don’t need to PROVE that is is safe, then I don’t need to prove it is not. In order for me to exercise my right to believe (in whatever) I demand to know what exactly is in the food.

    The FDA was the one to come up with exceptions. Now they need to own that decision and make it public knowledge. By stating that feed grade is made according to FDA compliance policies and not federal law and then there needs to be a link to these compliance policies.

    Or, they can rescind their compliance policy and then only federal law applies.

    FDA started the game with these policies. Now it is time to reap the results.

  17. Bob Milnover

    November 22, 2015 at 5:41 pm

    You are fighting a good fight. Keep it up.

    Be realistic about Realpolitik: why should those people in the FDA care about you and your vets and pet owners who complain to them? Because your cause is just and true and they should do what’s right?

    Several things to keep in mind if you really want to succeed at the federal or state level.
    1. Media coverage to arouse hundreds of thousands at least. Think how the TV spot with Sarah McLachlan singing “Angel” in the background has been in raising money and awareness. A tear-jerker. A *professionally done* (pro bono?) video on youtube, one that’s so emotional is goes viral. Truisms that cannot be disputed — it works and brings in the dollars you need to make a cause succeed.

    2. Journalism 101, page one: “There’s nothing staler than last week’s news.” I lived and worked in DC most of my life and here’s what happens. Unless public pressure is maintained over weeks, there’s an initial response of “Yes, we’ll make things right, things are going to change!” to satisfy the complainers. But then the old lawyer trick of delays and wait it out, and more time passes but nothing really happens. The protest *fizzles out.* Then business as usual. You know that’s what happens. Incidentally, is that dentist who killed and beheaded Cecil the lion back filling people’s teeth, as usual? How could that be? There was a huge outcry over it, thousands and thousands of signatures and emails to Congress, and celebrity outrages ..continued for several weeks. But see the update on CNN site to see that he’s just fine and won’t be charged. It would hurt tourism. Don’t be discouraged by this but be aware of the realities of making changes happen against industry.

    3. Committees and organizations are groups of people. Real live people with faces. Unless those individuals are named, and named with photos, they remain anonymous as “the FDA” or “the such and such committee.” No real pressure felt. But when named with their photos, public exposure hence embarassment , people in their community, their kids at school, and others who have influence on them? With public exposure which shames, their decisions change.

    These are the realities of change today. You are competing with experienced professional spin doctors and masters of delay and counter-tactics. And whose colossal “support budget” is shown below.

    4. Look at the numbers below, the money industry you are up against. You need viral video(s) and continued pressure and names named with their faces. Do you think even the President of the United States could turn a monster money industry influence around by himself without public shaming? Learn from a most successful citizen group, the big dogs who actually learned in the past to control Congress (at least the House), even against majority public opinion: the National Rifle Association. Don’t reinvent the wheel. Ignore their content and copy their methods exactly. How they mobilize only about 5 million citizen supporters with emails and phone messages who then email or call their reps in Congress –the House and many in the Senate are afraid of them. It doesn’t take huge sums of money to set up a website and emailer and dialer and do what the NRA does. They then bring in the money to bring in the lobbyists. Fear and emotion keep them going strong.
    Total U.S. Pet Industry Expenditures
    Year * Billions * of dollars
    2015 $60.59 Estimated
    2014 $58.04 Actual|

    5. This 60 billion spent is great news and not just for the industry lobby. You have millions and millions of dog and cat owners who, if they were informed and aroused about what their government is allowing them to feed their “pet kids,” could be just like the NRA’s dedicated supporters if played right. You have more potential supporters who have a personal stake in this than the NRA or Cecil the Lion ever did. Who have a continued interest in seeing their pet kids’ food on the store shelves become safe and healthful. Imagine applying the NRA’s simple methods to the potential 43 million dog households and 36 million cat households. Read that again. The NRA controls Congress with only about 5 million members. Think you could get that many out of at least 30 million households?

    We have the best government money can buy and does. Why would we expect it to be any different?

    Hope this helps. Incidentally, this CBC eye-opening expose of the industry a few years ago is always a useful source for expose ideas and material. “Pet Food A Dog’s Breakfast CBC Doc Zone” https://www.youtube.com/watch?v=GrBOOhDCC6g

  18. B Dawson

    November 23, 2015 at 6:50 pm

    This is bit off topic, but it illustrates where the pet industry puts it’s focus, or more accurately how it questions what happens in the pet food world. As usual, a well meaning article hits the bullseye but on the wrong target.

    PetProductNews – that’s a trade publication for the industry for those not familiar with it. – ran an article today about packaging’s influence on consumers. The article is pretty neutral, but I found the kudos handed out to small independents a hollow compliment. Apparently the fact that we’re educating our customers way better than the big box should be a selling point for our stores. Something that sets us apart and endears us to our customers.

    It is a selling point, but why should we have to educate consumers to look past deceptive packaging? The industry is missing the point – why isn’t the industry questioning the packaging to begin with?

    Here’s the link to the article, hope it works since it’s a subscription: http://www.petproductnews.com/Blogs/Blog/How-Much-Should-Packaging-Influence-Pet-Food-Purchasing-Decisions/

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