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Pet Food Regulations

Final AAFCO Meeting Update

For inquiring minds that want to know, the following is the rest of the story from my experience at the recent AAFCO meeting. Plus a few ideas to change the future of pet food.

For inquiring minds that want to know, the following is the rest of the story from my experience at the recent AAFCO meeting.  Plus a few ideas to change the future of pet food.

At last years AAFCO meeting, though most were friendly, I did not get a feeling that I/consumers were really welcome to the meeting.  This year, AAFCO definitely put out the Welcome Mat.  I’m not sure why there was a significant difference between last year and this year.  I believe Dr. Jean Hofve (who attended the meeting as well) played a huge role in getting us a seat at the Pet Food Committee and a seat at the Ingredient Definitions Committee.  I’m not sure my participation on these committees would have occurred without her.  Three cheers for Dr. Hofve.   We are not committee members yet – but I expect this will become official soon.  It needs to be noted that more than once they (AAFCO members) expressed to me when I could/should talk or ask questions (procedure), but for the most part I felt this advise was to benefit me/us – not hinder.  It wasn’t a ‘you can catch more flies with honey’ type of thing – it was procedure.  I welcomed (and probably needed) the instruction.

For clarity’s sake, AAFCO stands for Association of American Feed Control Officials.  Members of AAFCO are Department of Agriculture representatives from each state (I believe at this point only two states are not members).  The work of AAFCO is done via committees.  AAFCO Committees are: Collaborative Check Sample Committee (animal feed testing quality control), Current Issues and Outreach Committee (information to members, industry, and the public), Education and Training Committee (seminars to members), Enforcement Issues Committee (develop State enforcement policy), Feed and Feed Ingredient Manufacturing (evaluate needs for policy), Feed Labeling Committee (label laws), Ingredient Definitions Committee (defines ingredient definitions), Inspection and Sampling Committee (testing foods and food ingredients), Laboratory Methods and Services Committee (feed control laboratory standards), Model Legislation and Regulation Committee (regulatory principles), Pet Food Committee (all pet food related – regulations and ingredient definitions), and Strategic Affairs Committee (AAFCO By-Laws).

AAFCO does not – per se – develop pet food/animal food laws; they develop law recommendations – all of which are approved by FDA (a member of FDA sits on each Committee).  These law recommendations or ‘model bills’ cover all types of animal feeds (dogs, cats, birds, horses, cattle, and so on) and can be accepted by each U.S. state.  Key word is ‘can’.  Each U. S. state ‘can’ accept the model bills developed by AAFCO word for word, or any particular state has the option to significantly or slightly alter the AAFCO model bill to meet the needs/wants of that state.  As well, a U.S. state could have accepted as law the AAFCO model bill in (as example) 1965, but state law did not leave opportunity for updates of AAFCO model bills in following years.  Thus, this state would have out-dated animal feed/pet food laws in relation to current recommended law.  It all depends on the individual state; a nightmare for pet parents and manufacturers.

AAFCO members are not paid for their work within AAFCO.  However, it is my understanding that many State Department of Agriculture job descriptions include their involvement with AAFCO.

Nothing significant (to my knowledge) occured with pet food for this meeting (other than more complaints from Pet Food Institute regarding calorie statements and updating nutritional requirements for pet food).  Below are some additional notes; some things just for information, some of greater interest.

At the opening of the AAFCO meetings, a sort of roll call took place. Each U.S. State was announced and a representative of the State was asked to speak up – making it clear which states were represented. The states that did not attend…Alabama, Alaska, Connecticut, Georgia, Illinois, Maine, Massachusetts, Nebraska, Nevada, New Hampshire, New Jersey, North Dakota, Ohio, Rhode Island, South Carolina, South Dakota, Tennessee, Vermont, and Wyoming (plus I think there were two more states not represented – couldn’t write fast enough). There were three representatives from Canada (Canadian Food Inspection Agency). After these introductions were complete, all others in attendance were asked to stand, state their name and business affiliation. There were many representatives of big commercial pet food – from what I could hear, the most from P & G (manufactures Iams, Eukanuba, and Natura).  This also meant that all in attendance heard TruthaboutPetFood.com; all in attendance knew ‘we’ were there.

Later in the second day of the meeting I received an anonymous email via the contact form on my website….

“I am afraid that due to my position I am forced to send this email in an anonymous fashion. I can tell you that I work for an animal feed ingredient manufacturer and I am currently attending the AAFCO meeting. I do not sit on any of the Committees but I have attended every AAFCO meeting for the past several years.

I just wanted to thank you for representing consumers at the meeting. I think what you are doing is very important and please do not give up.”

No one ever introduced themselves to me, I do not have a clue who this was; but I so appreciated their words. Thank you to Anonymous.  I assure you, none of us will ever give up.

During the Ingredient Definitions Committee meeting, an agenda issue was brought up discussing the need for definitions for the pet food ingredients Rabbit Meal, Venison Meal and Lamb Meal (currently these ingredients fall under the ‘meat meal’ definition).  A task force was initiated – AAFCO’s Neal Lanning was designated to head this task force.  Dr. Hofve and myself volunteered to work on the task force along with Pet Food Institute and the National Renders Association.

Later that same evening (Thursday), Neil Lanning (of AAFCO) sent me an email asking to speak to me and Dr. Hofve for a few minutes.  He shared, that the concern of the committee is that ‘things’ discussed within the task force would be repeated on TruthaboutPetFood.com.  Dr. Hofve quickly responded that…’PFI is going to take ‘things’ back to their people to discuss, why can’t we take ‘things’ back to our people to discuss?’  The point was made (again three cheers for Dr. Hofve!) – we remain on the task force with permission to discuss ‘things’ with our people (of course within reason).

Of the two Committee tables we were invited to sit at, the Ingredient Definitions Committee table included several AAFCO members, a representative of the National Renderers Association, a representative of American Pet Products Association, two representatives from Pet Food Institute, two representatives of American Feed Industry Association, a representative of Enzyme Chemical Association, and Dr. Hofve and myself as guest consumer representatives (all others were Committee members).

Please notice there was no representation of quality minded pet food manufacturers and no representation of any veterinary association.  Imagine, year after year – meeting after meeting, the only suggestions for new model regulations or ingredient definitions and/or complaints against new regulations or ingredient definitions coming solely from ingredient suppliers and/or Big Pet Food.  I have witnessed two years in a row, the Pet Food Institute representatives constant whining and moaning about calorie statements on labels; causing delay after delay (this organization is clearly not petsumer friendly).  Now imagine the combination of years and years of whining and moaning, and years and years of biased science provided by these industries (with no one providing alternative science)…and now you have an idea of why pet food is in the condition it is (with misleading labels, federal law illegal ingredients, and little to no consumer friendly information).  Yes, AAFCO could have stood strong against all of our concerns of pet food (and animal food) – but they are only human.  This is not to give AAFCO an easy out (actually I can’t imagine how anyone can sleep at night that had anything to do with allowing euthanized animals to be processed into pet food) – this is to emphasize the need for improved and expanded involvement in the AAFCO process.

As a pet parent myself – and as a pet parent representative at the AAFCO meetings, I whole heartedly disagree with many of the existing model regulations that have been developed over the years.  However, with the AAFCO Welcome Mat out and with the awareness of the influence big industry has had within AAFCO for years, now is the time for swift action.

That swift action…(discussed by both Dr. Hofve and myself during downtime at the AAFCO meeting)…

Another pet food lobby organization needs to be developed.  An organization developed with the goal of producing the highest quality pet foods and treats that enhance the health of the pet – not an organization with the goal of producing pet foods that utilize waste to enhance the health of stockholder wallets.  I firmly believe a consumer representative should sit on the Board of Directors of this new pet food lobby organization – showing all very clearly – that this organization respects petsumers and willingly listens to the needs and wants of petsumers.  This new organization needs to be represented at every AAFCO meeting, not whining and complaining about (as example) calorie statements or updated nutritional guides for pet food; the new pet food lobby organization will be providing much needed science to AAFCO members (evidence that quality does matter), initiating clear consumer friendly ingredient definitions, and overall helping to develop model regulations to improve the health of pets (and the quality of pet food).

Holistic veterinarians need representation.  Who sees the clinical benefits of quality food better than holistic veterinarians?  Not that all non-holistic veterinarians remain old school and continue to recommend waste ingredient pet foods; holistic vets tend to – as a whole – see the forest in spite of the trees with nutrition.  These veterinarians need to be a voice at every AAFCO meeting as well.

And of course petsumer representation at each and every AAFCO meeting needs to continue.  Dr. Jean Hofve and I are committed to this (as my Dad used to say…the good Lord willing and the creek don’t rise – I’ll be there).

Now, just image if AAFCO’s Welcome Mat stays out…at the next AAFCO meeting, sitting as advisors to the Pet Food Committee and the Ingredient Definitions Committee will be…Pet Food Institute, Rendering Association, and others – plus representatives of petsumers, a new quality minded pet food lobby representative, and a holistic veterinarian representative.  Then we’ll see how far that whining and moaning gets them!  Petsumer representation alone – I don’t believe – will produce the swift action we all need, want and deserve.

I intend to contact pet food manufacturers – those that I believe are quality minded – to get the ball rolling on this new pet food lobby organization (those of you that are quality minded – feel free to contact me as well).  Dr. Hofve is planning on contacting some of her holistic veterinarian associates to begin the process of their participation at AAFCO.

We must fight our fight for safe pet food through continued pet parent education and through organized lobby efforts.  Big Pet Food has been doing this for years (though their education is through television commercials – many which mislead); they have a tremendous head start on us.  We’ve got a great deal of catching up to do.  However I have no doubt we will catch up and sail past!

 

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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