What will veterinarians say about FDA’s Compliance Policies?
Most veterinarians are unaware of FDA Compliance Policies that openly allow illegal wastes into pet food. So…how about we provide our veterinarians with the evidence this waste is allowed and commonly used in pet food and ask our vets to stand with us? Perhaps it is our job to begin to provide regulatory education to our veterinarians, and ask them to send the FDA an opinion this material is NOT safe in pet food.
The Let’s Ask Our Veterinarians Mission:
(cue dramatic music)
Step 1. Pet owners provide veterinarians with copies of FDA Compliance Policies.
Step 2. We ask our veterinarians to give us their opinion on this FDA allowed waste in pet food.
Step 3. We ask our veterinarian to email FDA their opinion. AskCVM@fda.hhs.gov
The Outcome:
The FDA ignores consumer concerns about pet food, but will the agency ignore veterinarians? Even if FDA chooses to ignore concerns of veterinarians, pet owners win because we’ve shared valuable pet food education with our vets.
Background for you and your veterinarian:
Federal law defines food as: “(f) The term “food” means (1) articles used for food or drink for man or other animals, (2) chewing gum, and (3) articles used for components of any such article.”
Federal law defines an adulterated food as (in part): “(5) if it is, in whole or in part, the product of a diseased animal or of an animal which has died otherwise than by slaughter.”
The laws quoted above are from the Federal Food, Drug and Cosmetic Act, which FDA is charged with enforcing (see Laws Enforced by FDA).
Three questions for your veterinarian…
#1 Ask your veterinarian: Do you believe pet food should abide by federal law?
Of course your veterinarian will agree that pet food should abide by federal laws. But, probably what your vet doesn’t know is that FDA allows pet food to violate federal law through their use of Compliance Policies. The next part of your mission is to explain to your veterinarian what Compliance Policies are…
The FDA website explains Compliance Policies as: “Compliance Policy Guides (CPGs) explain Food and Drug Administration (FDA) policy on regulatory issues related to FDA laws or regulations.”
In “Chapter 6 – Veterinary Medicine” of FDA Compliance Policy Guides, “Sub Chapter 660 – 699 Animal Food” we find the following two examples of FDA ignoring law in pet food which can be printed or emailed to your vet:
Example #1: CPG Sec. 690.300 Canned Pet Food. This FDA policy states: “POLICY: Pet food consisting of material from diseased animals or animals which have died otherwise than by slaughter, which is in violation of 402(a)(5) will not ordinarily be actionable, if it is not otherwise in violation of the law. It will be considered fit for animal consumption.”
In the above FDA pet food policy, FDA admits this material is “in violation” of the Federal Food Drug and Cosmetic Act (402 (a)(5) quoted above). But, completely ignoring federal law (actually, this FDA policy is word for word OPPOSITE of law) the agency states – “material from diseased animals or animals which have died otherwise than by slaughter“…”will be considered fit for animal consumption.” Pet owners can print the above Compliance Policy to deliver to your vet, or email the link.
Ask your veterinarian: Is material from diseased animals or animals which have died otherwise than by slaughter fit for my pet’s consumption?
If your vet agrees with FDA’s position (this material is fit for animal consumption), ask them to explain why they believe it is safe. If they say no, ask your vet why they believe this material is not safe for pets to consume. And then ask your veterinarian to take a stance with you; ask your vet to share their opinion with FDA by sending a brief (or lengthy) email to FDA at
AskCVM@fda.hhs.gov.
Example #2: CPG Sec. 675.400 Rendered Animal Feed Ingredients. This FDA policy states: “POLICY: No regulatory action will be considered for animal feed ingredients resulting from the ordinary rendering process of industry, including those using animals which have died otherwise than by slaughter, provided they are not otherwise in violation of the law.”
Ask your veterinarian: Is rendered pet food ingredients sourced from animals which have died otherwise than by slaughter a safe, quality ingredient?
If your veterinarian disagrees with FDA’s position of ignoring federal law allowing waste in pet food, thank them for their opinion and (again) ask them to share that opinion with FDA.
Just maybe…we can get our veterinarians to stand with us against FDA’s allowance of illegal pet foods! Maybe when our vets learn what really goes into pet food, everything can change.
Fingers crossed.
Wishing you and your pet(s) the best,
Susan Thixton
Pet Food Safety Advocate
Author Buyer Beware, Co-Author Dinner PAWsible
TruthaboutPetFood.com
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Cannoliamo
April 25, 2019 at 1:10 pm
Good article, Susan. Thank you.
Grass-roots consumer initiatives are always popular, but can be limited in effectiveness (especially with their ability to impact Federal laws and/or regulations). I recently read an article written by Dr. Amy Farcas,
https://drandyroark.com/the-biggest-myths-about-vets-and-nutrition/
who is a diplomate of the American College of Veterinary Nutrition
http://www.acvn.org/directory/?_page=1&num=50&sort=post_title
that provides advice regarding communications, assessments and recommendations between vets and pet owners, and was disappointed to note that not once was either FDA or AAFCO mentioned in the guidance.
I’m wondering if perhaps getting a policy position from the ACVN that supports the necessary revisions for both FDA pet food safety AND AAFCO quality standards could be helpful in getting the rules updated and in compliance with FSMA and increasing the advocacy of veterinarians for providing pet owners with competent and current dietary guidance.
…… just a thought.
I would also like to see the 2006 “Nutritional Needs Science-Based Guides for Pet Owners” revised and updated.
http://www.acvn.org/nutrition-resources/
~Pet Owner~
April 25, 2019 at 1:38 pm
“Most veterinarians are unaware of FDA Compliance Policies that openly allow illegal wastes into pet food. So…how about we provide our veterinarians with the evidence this waste is allowed and commonly used in pet food and ask our vets to stand with us? Perhaps it is our job to begin to provide regulatory education to our veterinarians, and ask them to send the FDA an opinion this material is NOT safe in pet food.”
What about investing in a database e-mailing list of national veterinarians? Maybe donations could be requested (I think it costs about $300).
We’ve always talked about the need to educate vets. With just the above article alone, could provide an introduction for Vets to begin learning what we already know, and to help them understand why clients have unfavorable opinions (fears) about PF.
? I’ll try to make this my last “suggestion” for a while now!
Sandra Murphey
April 25, 2019 at 8:44 pm
I find that most vets aren’t open to getting information like this from pet guardians. After all, they paid for their education.
~Pet Owner~
April 26, 2019 at 8:43 pm
That’s why I suggested emailing articles from the TAPF. On a mass basis so conversations can be started/continued among Vets. These articles are backed by research and industry informers. What Vets are unwilling to discuss with personal clients, they might be willing to read about. At least to open their minds. It will take a long time.
Sherri
April 25, 2019 at 5:31 pm
I would be curious to know how many people have actually attempted to have such a discussion with their vet and how that conversation was received. At the office of my last vet, who I no longer go to, I was shut down very quickly by a tech and a vet both of whom knew next to nothing about pet food ingredients and were not remotely interested in talking about it! I was met with only stony, superior, condescending attitude. The vet fervently wanted for me to just shut up and buy my dog a bag of the Science Diet he sold in the front office with the advice to feed her nothing but that for the rest of her life! Yeah, not gonna happen!! So while education is always a good thing and vets SHOULD be open to learning and staying current on ALL info, not just medical procedure, unfortunately many of them are completely closed minded to the idea that they need to be educated about pet food. I think most people who read a site like this are far more educated about what their pets are eating then the vast majority of vets. Sad because change could happen so much faster if the veterinary establishment was on our side.
Sandra Murphey
April 25, 2019 at 8:48 pm
I posted this question to veterinarians on Quora. This is the first answer: There will be more….
Randall Haveman, DVM Veterinary Medicine, Colorado State University (1979)
“Some is, but there are strict protocols in place. There are levels of quality in per foids, not necessarily related to the price of food. All pet foods are safe for human consumption, though.”
Susan Thixton
April 26, 2019 at 7:55 am
Great idea to post the question. Thank you Sandra!
~Pet Owner~
April 26, 2019 at 8:46 pm
I do not understand this response. What does “levels of quality in per foids….” mean? Quality is binary, it either exists or doesn’t. And somebody has seriously failed in labeling if it’s assumed “pet foods are safe for human consumption, though.”
Please clarify.
Sherri
April 29, 2019 at 2:51 pm
“…all pet foods are safe for human consumption…” Wow. But that whole comment made by someone who should certainly know better is a great example of how far from truth and reality vets are when it comes to pet food and their ingredients and how much work there is to be done to attempt to educate them. I say attempt because most seem to believe themselves to already be experts on the topic. Wonder if he would be willing to eat a bowl of Science Diet from his own front office to prove his point?!
Christine
April 29, 2019 at 10:45 am
I’m not sure that vets would know enough about what “animals which have died otherwise than by slaughter” means, and what’s truly allowed in this category. In the same way, there’s a big push by vets right now to support the use of “byproducts” in pet foods, pushing them as safe and containing wonderful organ meats valuable to their nutrition, and saying that it’s a marketing problem that people think byproducts are bad. Our local traditional vet recently put out an email to all of their customers (regarding the cardiomyopathy UC Davis stuff, encouraging people to switch back to foods with grains like the Hills they sell) saying, “Marketing firms have gotten us used to interpreting some ingredient words such as “by-products” as bad and others such as “grain-free” or “all natural” as good. You probably aren’t surprised to hear that reality is a little more complicated than fancy labels and commercials. While terms like “meat by-products” may sound alarming to us, often that term refers to organ meats such as heart and kidney which are rich in protein. Eliminating those meats from the diet could be part of the problem.” (of Cardiomyopathy/taurine issue)
We however understand what could be and likely is in rendered animal waste includes euthanized dogs, cats,and horses, putrid roadkill, farm animals that died in the field and laid there for a time before being transported and rendered, cancerous tumors, spoiled grocery store meats and their packaging, restaurant grease that’s been stored in the sun for ages before it’s picked up and transported, factory farmed chickens that died in the barns from overcrowding, byproducts from slaughterhouses that certainly weren’t handled as if they were food, perhaps transported in a hot truck to a rendering facility, etc. My guess is that nice organs such as hearts and kidneys would probably be excised and handled as food as I imagine that they could be sold for a higher price to companies that purposely use organ meats in their pet food formulas, and that they wouldn’t be thrown away into a rendering vat for the much lower price they must get for the waste material used to make “animal byproduct meal” etc. For these reasons, I feel that the above material aimed at education vets, though accurate and disturbing if you understand the definitions, might fall on deaf ears. They trust the regulatory agencies completely it seems, and wouldn’t likely believe or stop to think what animals that died otherwise from slaughter even means. I like your idea of trying to educate vets, but I can just picture the “stony, superior, condescending attitude” that was mentioned above by Sherri when people attempt such a thing. Not that I think they shouldn’t try, but maybe including that picture of green rotten chicken parts that Susan has used in the past and a list of meats that qualify as “otherwise than by slaughter” would help? Does FDA itself have a list of these specific things that aren’t legal yet are not actionable?
Another idea for the future is trying to educate the vets that teach students in vet schools!