A new guideline document regarding Human Grade pet food will be voted on Wednesday August 4, 2021 at the AAFCO meeting. This guideline is brand new, something we have never been provided opportunity to review before – and it appears it could destroy the quality of human grade pet foods.
Pet owners can read the full Guidance Document Here (found in the middle of page 2).
Our concern: AAFCO appears to be setting the stage to dilute (destroy) the current high standard of human grade pet food. We (pet owners and pet owner advocates) were given NO advance notice of this guidance document, and NO opportunity to provide comment. The AAFCO session this Guidance Document will be voted on (on Wednesday August 4, 2021) is the final stage of the AAFCO process. In other words, everything in this document was previously decided on without consumer knowledge.
Quoting the AAFCO document: “Pet and specialty pet foods using the labeling claim ‘human grade’ are first and foremost animal food products and subject to inspection under 21 CFR part 507.”
To explain, “21 CFR part 507” is federal law – CFR stands for Code of Federal Regulations. This exact section of law is “Current Good Manufacturing Practice, Hazard Analysis, and Risk-Based Preventive Controls for Food for Animals.” To be clear, this exact section of law is for feed – not for food.
As readers here are aware, feed is VERY different than food. AAFCO is certainly aware that feed is VERY different than food (human grade pet food). So why is AAFCO trying to lump the two together?
The AAFCO Guideline also states (bold added): “(2) All facilities that process or package a final “human grade” pet food product that is considered ready-to-eat must be registered as both an FDA food facility and an FDA feed facility.”
A facility that manufactures food (including human grade pet food) is a completely different facility than one that manufactures feed, held to a completely different legal and safety standard. So…why is AAFCO requiring a food facility to register as a feed facility? Again, trying to lump food and feed together.
We are very concerned at this new AAFCO action, attempting to lump human grade pet food (food) into the feed category. We are very concerned AAFCO intentionally excluded consumers from this decision – the customers of human grade pet food.
Although it might be ignored (based on our history with AAFCO), we sent the following message to AAFCO today – in advance of the meeting (8/2/21):
Please provide confirmation this comment is delivered to the chair of the Model Bills Committee in advance of the session Wednesday, August 4, 2021.
On behalf of pet food consumer members of Association for Truth in Pet Food, we are objecting to “Guidelines for ‘Human Grade’ Pet and Specialty Pet Food Claims” being finalized in this session of the Model Bills Committee. We are submitting our comment in advance of the live meeting due to the potential of not being provided the opportunity to comment in the virtual meeting setting.
Consumers or their representatives were provided no opportunity for input in this new Guideline document. The ONLY AAFCO sessions we are invited to is the Annual and Mid-Year meetings. This particular document was not discussed during the last meeting (January 2021) thus we have had no opportunity for input.
Before this Guideline document is finalized, we request explanation to the following AND opportunity to provide input to the Committee based on your responses.
1. We question why the document references two different Current Good Manufacturing Standards. A human grade pet food, manufactured in a licensed human food facility would not be subject to 21 CRF part 507. These facilities would only be subject to 21 CFR part 117. We would like an explanation to why the animal food CGMS is referenced.
2. We question why Item (2) of the guideline conflicts with human food standards. Item (2) states: “All facilities that process or package a final “human grade” pet food product that is considered ready-to-eat must be registered as both an FDA food facility and an FDA feed facility.”
We remind AAFCO of their definition to feed grade: “Feed Grade: Material that has been determined to be safe, functional and suitable for its intended use in animal food, is handled and labeled appropriately, and conforms to the Federal Food, Drug and Cosmetic Act unless otherwise expressly permitted by the appropriate state or federal agency (Suitable for use in animal feed).” Feed grade products and in turn registered feed facilities are allowed by AAFCO definition to violate the Federal Food, Drug and Cosmetic Act with no warning or disclosure to pet owners.
We alert the Model Bill Committee to FDA Center for Veterinary Medicine’s response to our Citizen Petition. FDA stated in April 2019: “we do not believe that the use of diseased animals or animals that died otherwise than by slaughter to make animal food poses a safety concern and we intend to continue to exercise enforcement discretion.” Via FDA enforcement discretion registered feed facilities are permitted to violate the Federal Food Drug and Cosmetic Act with no warning or disclosure to pet owners.
We would like an explanation to why a licensed food facility would be required to register as a feed facility. And we ask if anyone has investigated if this is even possible? Such as, has anyone consulted with USDA (who would oversee production in a licensed human food facility with products containing more than 3% meat) if dual registration would be allowed?
Pet owners that purchase Human Grade pet products do so – in large part – specifically due to the regulatory requirement all food regulations are being abided by. To require food facilities – that meet every requirement of food – to register as a feed facility (allowed by AAFCO definition and FDA discretion to violate federal law) is a serious conflict. Pet owners that purchase these products do NOT want a pet feed, and we would assume the human food manufacturers would also NOT want any affiliation with a pet feed.
We request this agenda item be tabled until consumers are provided opportunity to have questions responded to and provide input. We also request our comment be added to the meeting minutes, on official record.
Thank you –
Susan Thixton
TruthaboutPetFood.com
AssociationforTruthinPetFood.com
If you provide your pet with a human grade pet food and do not wish to see the high standard diluted by behind the scenes efforts of AAFCO, please send them a message. You can email AAFCO at: aafco@aafco.org.
We will provide pet owners with information on the outcome of the meeting – which begins today (August 2, 2021).
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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B Dawson
August 2, 2021 at 11:10 am
What are they up to?
As it stands now you can’t claim ‘human grade ingredients’ if you manufacture in a non-human grade facility. As soon as those ingredients hit a feed grade facility, they can no longer be called human grade. That’s the argument they use to keep claims off the label.
Using feed grade ingredients in a human food certified facility should invalidate the human grade permits/certifications. Is that the goal? Get permits revoked at pet FOOD production facilities? That rule would also seem to prevent a pet food company from using a human facility to make their food as well. That facility would have to be a registered feed facility which would present all sorts of marketing issues for their human brands.
What a conniving bunch of creeps.
Pamela Bayless
August 2, 2021 at 11:54 am
Do not stop making human grade pet food!!!
chris
August 2, 2021 at 12:31 pm
Just like everything since covid, the groups and politicians keep trying to slip things in assuming the consumers are too busy with stuff to pay attention.
Amee R.
August 2, 2021 at 12:35 pm
Thank you, Susan, and I need to join this AAFCO consumer group again!
KJ
August 2, 2021 at 1:02 pm
This is disgusting! AAFCO is deliberately trying to blur the lines between feed and food. If they’re successful, consumers will not be able to trust the human grade label. A lot of smaller human quality pet food makers use human food facilities (on the weekend and evenings) to make their batches of pet food. If the human food facility can’t or doesn’t want to register as a feed facility (and who can blame them); this will crush those smaller companies which of course, is the intent of this new guideline. It just shows how truly corrupt the whole industry is. If this doesn’t show how in bed the pet feed conglomerate is with AAFCO, I don’t know what would.
Sarah
August 2, 2021 at 3:37 pm
The only way to ensure your dog, cat, or other small pet (or livestock as well) is fed healthy food: for household pets the only safe thing to feed is home prepared organically sourced food; for livestock, know your feed producers – for example I purchase organically grown hay from a local farmer who lives less than 50 miles away and haul it myself, yes, it can be done. On the rare occasions I feed a pelleted feed I purchase from a local feed line developed by a veterinarian and manufactured in a plant again about 50 miles from me and it is actually a HUMAN FOOD GRADE manufacturing facility that processes a variety of ingredients for local wine and craft breweries. Even that facility’s “squirrel mix” has locally farmed human-grade corn and sunflower seeds! TAKE THE TIME to find LOCALLY grown products from farms and manufacturers that ACTUALLY care more about the animals fed their products than the almighty dollar.
T Allen
August 2, 2021 at 5:40 pm
We REALLY need a good attorney on board here! You know AAFCO has attorneys so we need to find someone for our team. I think we could raise the money to hire someone with all the people who now feed only human grade or home made. We could combine forces with Rodney Habib and Karen Becker to make it a worldwide effort.
M
August 18, 2021 at 7:51 am
Even if you don’t feed human-grade, I urge everyone to email and tell them you disagree with this. Regulations are primarily red tape and nonsense that prevents competition, and this is an example. The government wants to regulate but not to the advantage of taxpayers or consumers.