The fourth meeting of AAFCO’s working group to define human grade and feed grade happened this morning. No verbal abuse at this one, but things did take an interesting turn.
This meeting started with the announcement that AAFCO wanted all attendees to note that while these discussion are allowed to be shared with interested parties (such as consumers), it needed to be shared that these discussions are NOT the current policy of AAFCO. Such as, the suggested feed grade definition – “Material shall be safe (or shall be made safe), nutritious and appropriately handled and labeled for the intended use in making specific species(s) animal food.” – is not current AAFCO policy. It is only being considered as policy.
How the system works…Often when a challenging issue needs to be addressed by AAFCO, the discussion is moved to a ‘working group’ – who meet via webinars or conference calls and communicate through emails. The working groups typically include several members of AAFCO, FDA and various representatives of stakeholder groups. In the case of feed grade and human grade working group – the stakeholders that have participated are consumer representatives (myself and Dr. Hofve), the rendering association, the animal feed industry association, and the Pet Food Institute (trade association for large pet food manufacturers). Coming from different view points – regulatory through AAFCO and FDA representatives, industry from their trade association representatives, and consumer representatives – it is the goal of the working group to come to some sort of an agreement to define (in this case) human grade and feed grade – put it in writing – and once the group completes this those definitions are then moved to the public AAFCO meetings (which happen twice a year) for more discussion and voting by members (only State Department of Agriculture members of AAFCO and FDA are allowed to vote – no stakeholder representative is allowed to vote).
So…during the meeting this morning the point was made to be certain when sharing the discussion that every party understands this discussion is only that – discussion. It is not current AAFCO policy. Thus, the proposed definition of feed grade is not final yet – there will be a lot of discussion yet to come.
Dr. Hofve and I knew we would need to come to the middle a bit, so we developed another proposed definition of feed grade. That is: Feed Grade – Materials that can be safe and nutritious for animals but may contain materials that do not meet legal requirements of edible food, including but not limited to inedible and/or condemned foods, diseased animal material and/or material from animals that have died other than by slaughter, and adulterated human food contaminated by filth, pesticides, industrial chemicals, natural toxicants, microbes, or excessive or unpermitted drug residues* (*with CVM pre-approval).
We defended our proposed definition in the discussion stating our definition is quoting from FDA – specifically FDA Compliance Policies which determines what is allowed into feed grade ingredients.
As it turned out – going back and forth – their only valid argument was our definition was too lengthy; too many words. It was decided that FDA will have the task to ‘word smith’ the definition (rewrite the proposed definition) and that will be completed by our next online meeting in two weeks.
It will be interesting to see what FDA does to the definition. Will they endorse transparency to consumers or will they protect the secrets of industry? Time will tell. Information will be posted about our discussion after the meeting in two weeks.
Wishing you and your pet(s) the best,
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