“It’s AAFCO’s party…”

“…we can invite who we want to the party.” This is a quote from email communication between myself and Mr. Stan Cook, Missouri Department of Agriculture, AAFCO President-elect.

AAFCO booted me (Susan Thixton) out as a representative of consumers under the false pretense statements posted on this website “were in the nature of a personal attack against Mr. Stan Cook, AAFCO’s President-Elect and Chair of the AAFCO Pet Food Committee.” A detailed response was sent to AAFCO regarding the dismissal, however the organization has not bothered to respond.

As it turns out, Mr. Cook informed me of the rules AAFCO operates by in an email dated June 24, 2016.

Photo of an email from me to Mr. Stan Cook and Ms. Kristen Green, co-chairs of the AAFCO Pet Food Committee dated June 24, 2016…

The above email was sent regarding my participation (representing consumers) in the AAFCO Pet Food Label Modernization working group. AAFCO was allowing the working group to vote on what pet food label updates would be implemented. I was providing feedback to the working group chair to those voting rights and feedback to a pet food manufacturer’s consumer solicited opinion.

Mr. Stan Cook provided the following response to my feedback. His response was typed into my email – Mr. Cook’s response is in blue colored font below…

Significantly Mr. Cook stated:

Any of the people providing input to the group and thus to AAFCO as a whole, serve at AAFCO’s discretion. It’s AAFCO’s party, we can invite who we want to the party.

Representation in work groups are rarely built on precise equality.

Fair enough AAFCO. It is your “party”. Maybe you do have the right to “invite who we want to the party.”

But do they? Is it really AAFCO’s “party” to contol?

AAFCO writes “model bills” which are accepted as law into most states. Which means AAFCO’s work is – in essence – an extension of state government; AAFCO writes state laws.

AAFCO also writes the legal definitions of pet food ingredients in a cooperative agreement with the FDA. (Click Here to read that agreement.) This agreement with FDA means – in essence – AAFCO’s work is an extension of the federal government/FDA.

All state and federal government laws and definitions are required to be free to the public. But somehow…some way…AAFCO controls their own private party.

AAFCO owns and copyright protects the “model bills” and animal feed ingredient definitions – charging all who wish to read these laws and definitions a hefty yearly fee. Per AAFCO’s 2015 tax returns (required to be public information per their non-profit status), AAFCO earned $344,836.00 in sales of the Official Publication – the book that holds pet food/animal feed laws and ingredient definitions.

Law making proceedings in state and federal government are free for the public to attend.

But not with AAFCO’s private party. Again, AAFCO charges hefty fees for the public to attend their meetings which are by agreement (with State government and FDA) an extension of our government’s work. Per AAFCO’s 2015 tax returns, AAFCO earned $355,755.00 for hosting law making meetings.

The AAFCO organization earned more than $700,000.00 in 2015 acting as an extension of government. Almost three fourths of a million dollars that should NOT have been earned by an organization performing duties by agreement are State and Federal government work.

Click Here to view AAFCO’s 2015 tax return.

It’s their party – but AAFCO…’you can’t have your cake and eat it too.’ You can’t act as an extension of government on one hand, and a private corporation on the other.

For any consumer that believes it is unjust that AAFCO owns the legal definitions of pet food ingredients, that AAFCO owns the regulations that govern pet food, that AAFCO can earn almost three quarters of a million dollars from the sale of information that should be free to the public – please write your state Attorney General. (Google search your State Attorney General. Instructions to contact the Attorney General are provided on each State’s website.) Example letter below.

Dear ________,

I am writing to request an investigation into the relationship our state has with the organization Association of American Feed Control Officials (AAFCO).

AAFCO is a private corporation with non-profit status that is provided the responsibility of writing model bills – accepted as state law – governing the animal feed/pet food industries. Under a ‘Memorandum of Understanding’ agreement with FDA, AAFCO writes, owns, and copyright protects the legal definitions of animal feed/pet food ingredients. Through this FDA agreement, AAFCO’s work is an extension of State and Federal government.

Pet food/animal feed ingredients – written, owned and copyright protected by AAFCO – are not public information. Pet food/animal feed regulations (as example labeling laws that govern what is required to be disclosed to a consumer on a pet food label) – written, owned and copyright protected by AAFCO – are not public information. I as a pet food consumer have no access to read and understand what information pet food labels are required to disclose to me, and more significantly I have no idea what is actually in my pet’s food as I am not provided with access to the legal definitions of pet food/animal feed ingredients. Pet food ingredient definitions are very different than their human food counterparts – each ingredient has its own legal definition, again which I am denied public access to as a pet food consumer. I am denied my Freedom of Information rights as a (pet food) consumer because AAFCO owns and copyright protects these legal definitions of ingredients and pet food regulations.

I request your investigation into the relationship our state has with the AAFCO organization. I request you assure all pet food consumers within our state are provided with free access to all regulations/laws that govern pet food including public access to all ingredient definitions.

Please provide a response to this request with information on your investigation of this concerning denial of consumer rights.

Sincerely,

[Your Name]

If consumers receive a response from their Attorney General, responses can be sent to this website and will be shared with all consumers.

Opinion: AAFCO should not be provided with the opportunity to act as an extension of State and Federal government (writing law and legal definitions) while not being held to the same legal requirements of government. Pet food consumers deserve free public access to all laws governing pet food and all legal definitions of ingredients. AAFCO meetings should be free to the public, AAFCO model bills and legal definitions of ingredients should be free to the public. Only consumers can force this change. Consumers can demand our Freedom of Information rights be provided. Every pet food consumer deserves to know what exactly is in their pet’s food.

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

What’s in Your Pet’s Food?
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The 2017 List
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