We have an opportunity to make pet food regulations and legal definitions of ingredients public information, but we need strong support from pet owners to make this happen. All you need to do is send an email.
The Problem.
One of the worse crimes in pet food is that the legal requirements of pet food are hidden from pet owners. As example, every single pet food ingredient has its own legal definition that is very different than the same food ingredient in human food. ‘Chicken’ in a human food has a VERY different legal definition and requirement than ‘Chicken’ in a pet food.
Pet owners have no access to the definition of chicken meal, or animal fat, or pea protein – or any ingredient that is listed on your pet’s food bag. The terms ‘with’ or ‘formula’ or ‘recipe’ all have a specific meaning in a pet food name. Pet food is required to contain a certain percentage of protein, fat, calcium, copper, and numerous other nutrients. But – none of this information is available to the public.
All of these definitions and regulations are owned by AAFCO – the Association of American Feed Control Officials. In order to understand what is in our pet’s food, what terms in a pet food name mean, what nutrients are required to be in our pets food – pet owners are forced to purchase the definitions and rules from AAFCO for a fee of $150.00 per year for the online version or $110.00 per year for the paper version.
The Opportunity for Change.
The state of Colorado is holding a public meeting regarding adopting AAFCO’s pet food/animal feed legal definitions of ingredients and regulations. Colorado is adopting the AAFCO definitions and rules “by reference” which means they ‘refer’ to the definitions and rules for enforcement in the state, but they don’t publish them for public view.
Colorado is NOT making the pet food ingredient definitions and regulations available to pet owners and we are contesting that based on Colorado state law.
Because Colorado is allowing public comment on this new rule, we (TruthaboutPetFood.com and AssociationforTruthinPetFood.com) sent the following comment to Colorado today (9/18/20):
Hearing Officer Jenifer Gurr
Colorado Department of Agriculture
Written comment regarding the proposed changes to “Rules for Commercial Feed Under the Colorado Feed Law, Sections 35-60-101 through 115, C.R.S.” 8 CCR 1202-6, Parts 2, 13, and 17.9 (the “Proposed Rule”).
This comment is sent for consideration at the public hearing to be held October 1, 2020, 10:30 am.
The Proposed Rule states Colorado Department of Agriculture will incorporate by reference the AAFCO standards and guidelines but then provides that a copy of these incorporated standards via the Official Publication of the Association of American Feed Control Officials will be open to public inspection, and available for copying during normal business hours. As written, the Proposed Rule violates Colorado law that requires any standard or guideline is readily available in written or electronic form. Colorado Statute Title 24, 24-4-103 ( Rule-making – procedure – definitions – statutory citation correction” (12.5) (a) (III) states: “The code, standard, guideline, or rule is readily available to the public in written or electronic form…”.)
In order to meet Colorado statutory requirements for incorporating rules by reference, the Proposed Rule must include the required information “The code, standard, guideline, or rule is readily available to the public in written or electronic form” along with an email address for the public to request the incorporated by reference rules.
Colorado is proposing to adopt by reference the 2017 Official Publication which is not available in electronic form from Colorado Department of Agriculture or AAFCO. Moreover the more recent 2020 Official Publication can only be purchased from AAFCO – for a significant fee of $150.00 per year for the online version or $110.00 per year for the written version.
The Proposed Rule only offers availability to inspect and copy the written 2017 Official Publication at its offices in Broomfield, CO. This accessibility to the referenced pet food standards and guidelines is severely limited. As example, a pet owner in Cortez, CO would be forced to travel 14 hours round trip to Department of Agriculture offices in Broomfield, CO. in order to inspect and copy Colorado incorporated by reference pet food regulations.
Further, with considerations of COVID19, State Department of Agriculture offices are not necessarily open for public inspection and copying.
The Proposed Rule as it is currently written enables one of the worst crimes committed against pet food consumers – withholding pertinent information from the pet owning public regarding the products they provide their pets. Colorado is currently denying pet owners public access to pet food regulations and legal definitions of pet food ingredients.
Colorado must make available a free electronic version of the incorporated by reference commercial feed rules to pet food consumers. Anything less would be a violation of Colorado state law and a serious injustice to Colorado pet owners.
Your Help
The state of Colorado needs to hear from pet owners. Please send Colorado your message or feel free to copy the above letter sent by us. If you reside in Colorado, please include in your message that you are a resident. But ANY pet owner can provide comment.
Send your message before September 30, 2020 to:
Hearing Officer Jenifer Gurr
Colorado Department of Agriculture
Jenifer.Gurr@state.co.us
Subject line of your email: Comment re “Rules for Commercial Feed Under the Colorado Feed Law, Sections 35-60- 101 through 115, C.R.S.”
To read the Colorado public hearing notice, Click Here.
Thank you in advance to all pet owners that send their comment.
Wishing you and your pet(s) the best,
Susan Thixton
Pet Food Safety Advocate
TruthaboutPetFood.com
Association for Truth in Pet Food
Become a member of our pet food consumer Association. Association for Truth in Pet Food is a a stakeholder organization representing the voice of pet food consumers at AAFCO and with FDA. Your membership helps representatives attend meetings and voice consumer concerns with regulatory authorities. Click Here to learn more.
What’s in Your Pet’s Food?
Is your dog or cat eating risk ingredients? Chinese imports? Petsumer Report tells the ‘rest of the story’ on over 5,000 cat foods, dog foods, and pet treats. 30 Day Satisfaction Guarantee. www.PetsumerReport.com
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The 2020 List
Susan’s List of trusted pet foods. Click Here to learn more.
Dorothy
September 18, 2020 at 3:17 pm
Done! Thanks for making it so easy, Susan!
Cory Niday
September 18, 2020 at 6:22 pm
Cory and Sylvy Jo email their barks and grrrs at Rules for Commercial Feed Under the Colorado Feed Law, Sections 35-60- 101 through 115, C.R.S. today!
Stephanie Nortell
September 18, 2020 at 5:03 pm
Thank you for providing the information for us to send emails. I’ve sent an email and forwarded the same information to friends for their help in sending emails, too.
Ensuring my pets are safe from the food and treats they eat is my highest priority. Your tremendous effort advocating for animals is very much appreciated.
Lise Petroski
September 18, 2020 at 7:20 pm
Done as well! Thank you, Susan.
Jackie
September 19, 2020 at 1:10 am
Thank you for the heads up. Letter sent with note that passing this Proposed Rule would also set a precedent for keeping pet owners in other states in the dark too.