News from the August 2020 AAFCO Meeting

Another AAFCO meeting is done, the first virtual AAFCO meeting.

The AAFCO meeting was held virtually – via webinar. Giving credit where credit is due, the AAFCO officials did a good job at transitioning the meeting to virtual.

Day 1 AAFCO included keynote speaker Dr. Bernadette Dunham, former director of FDA’s Center for Veterinary Medicine (CVM). Dr. Dunham spoke on the One Health Initiative, which FDA appears to be taking an active role in. One Health is a movement for all types of professionals to work together to improve human and animal health.

While Dr. Dunham’s presentation on the One Health Initiative was wonderful, it seems she forgot what she herself allowed to be processed into pet food/animal feed during her tenure at CVM and the current director Dr. Steven Solomon continues to allow. From Dr. Steven Solomon 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 where appropriate.”

What I found absurd is: at the same time FDA puts on this public show of their participation in the One Health Initiative to improve human and animal health, urges laws to be changed under the One Health Initiative (see below) – FDA themselves intentionally contributes to the deterioration of human and animal health through their ‘enforcement discretion’. How can illegal waste allowed by FDA into pet food/animal feed be considered in line with the One Health Initiative? These waste ingredients have been – and continue to be – the perfect storm for human and animal illness. It is beyond understanding how or why the FDA refuses to acknowledge the documented risk. (As reminder, years back we asked FDA for their science to prove these illegal, waste ingredients are safe for pets to consume. FDA could not provide us with any scientific evidence.)

The FDA also – under the One Health Initiative – pushed through AAFCO a new (though only slightly) and controversial definition of adulteration. The new definition is (in bold are the only changes):

“(a) (1) If it bears or contains any poisonous or deleterious substance which may render it injurious to human or animal health; but in case the substance is not an added substance, such commercial feed shall not be considered adulterated under this subsection if the quantity of such substance in such commercial feed does not ordinarily render it injurious to human or animal health;”

It was interesting that almost all of the industry trade associations disagreed with this change. Their argument – which is valid – is that this AAFCO definition varies from federal law. The federal law definition does not include the words “human or animal”. The above definition passed, but only barely. Voting members of AAFCO (FDA and State Department of Agriculture representatives) were well divided on this issue – with only slightly more than 50% voting to approve the definition.

The Pet Food Committee meeting was the shortest in history – lasting only 45 minutes. No new information or discussions were provided.

The Ingredient Definitions Committee meeting was held in two – 1 hour, 45 minute sessions. Day 1 was not too significant to pet food. Day 2 included some good news for pet food. Almost 2 years ago we submitted to AAFCO some animal ingredient definition changes. The discussion was finally introduced into discussion at this meeting. Overall, what we asked AAFCO for was animal ingredients (such as chicken) to be specific to what is included in that ingredient. As example – the current definition of chicken can be chicken meat, or chicken bones, or chicken skin, or chicken internal organs or a combination of one or more, and condemned or USDA inspected and passed varieties of each type of chicken part. We submitted ingredient definitions that would not only tell the consumer what parts of the chicken is included in your pet’s food – but also the quality of the chicken (inspected and passed or condemned). So from today, AAFCO has agreed to look into this issue. It will probably take years for any changes to be implemented, but thanks to AAFCO we now have a beginning to the discussion. This is a great start.

FDA was asked their opinion on new animal ingredient definitions, they were hesitant. And one regulatory authority from Indiana stated he disagreed with definitions providing quality information.

This is one of those circumstances that regulatory authorities need to hear from pet owners. I encourage every pet owner to send a quick email to FDA and to your State Department of Agriculture representatives – thanking them for AAFCO’s discussion on these ingredient definition updates and confirming to them you want to know what you are buying in your pet’s food. Confirming to them you want ingredient definitions that clearly explain what animal parts are included in your pet’s food and the quality of those parts. You can find your state’s officials here: https://www.aafco.org/Regulatory. You can email FDA at: AskCVM@fda.hhs.gov

Regulatory officials need to hear this from all of you – not just from me and other advocates. So please send your emails and encourage other pet owners to do the same. Thank you in advance.

The next AAFCO meeting will be in January 2021.

Wishing you and your pet(s) the best,

Susan Thixton
Pet Food Safety Advocate
TruthaboutPetFood.com
Association for Truth in Pet Food

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The 2020 List
Susan’s List of trusted pet foods. Click Here to learn more.