Although it’s absurd we had to, we once AGAIN asked FDA to enforce law in pet food.
In July of 2010, pet owners asked FDA to enforce law in pet food. Simple enough request, we aren’t asking for the moon. We just wanted FDA to enforce law in pet food, we asked them to stop allowing pet food to violate law.
FDA thought about our request for 4 years. In July of 2014 the long awaited FDA response to our request was “denied” stating in part “because your petition does not provide sufficient data and information to support this request“. In other words, the FDA didn’t feel we provided the agency with sufficient evidence their allowance of illegal material in pet food (ingredients sourced from diseased animals and animals that have died otherwise that by slaughter) was not safe.
Next we turned the tables a bit, and then asked FDA through Freedom of Information Act request for their evidence. We asked the FDA for their scientific evidence that proves pet food ingredients sourced from diseased animals and animals that have died otherwise than by slaughter are safe for pets to consume. FDA responded in 2016 stating they had no scientific evidence that proves these horrendous pet food ingredients are safe.
Wiser to their tricks, we tried again in October of 2016 and filed another legally appropriate document (our Citizen Petition) with FDA asking the agency to enforce law in pet food. And based on a face to face meeting with FDA, we added an Addendum to the Citizen Petition in 2017 asking for a ‘standard of identity’ of dog feed/cat feed be required of pet products that do not meet the legal standards of food.
On April 30, 2019, the FDA responded with a “no” to everything we asked for. ‘No’ – FDA will not enforce existing law in pet food. ‘No’ – FDA will not prevent the use of pet food ingredients sourced from diseased animals or animals that have died other than by slaughter. And ‘No’ – FDA will not agree to allow pet food consumers to make informed decisions.
On May 1, 2019 we contacted the mediation division of FDA asking for a discussion with FDA regarding their continued attitude allowing pet food to violate law. FDA agreed to mediation on May 20, 2019…but 20 days later on June 10, 2019 the Agency changed their minds. We were told we could file a “Petition for Reconsideration” instead.
Today – June 17, 2019 – we filed our Petition for Reconsideration with FDA asking the Agency to reconsider in full it’s decision to continue to allow pet food to violate law with no warning or disclosure to pet owners. Pet owners can read that document Here.
We argued every point we could (those allowed per requirements of Petition for Reconsideration), but one of the most telling arguments (personal opinion) we had was in response to FDA’s attitude that all pet owners are fully aware pet food is not food, and the Agency’s “belief” diseased animal material is safe – thus pet owners don’t need to be informed to what is actually in their pet’s food.
That one particular argument was:
We challenge the Agency, if these ingredients are so safe and the Agency is so certain the public understands what they are buying – why not label the ingredients on pet food labels with their true identity such as “diseased chicken” or “condemned beef”? We argue that we both (FDA and Association for Truth in Pet Food) know why these ingredients are used under the FDA facilitated cloak of secrecy; “diseased chicken” or “condemned beef” on a label would not sell pet food. By allowing these ingredients not labeled with their true identity (example ‘diseased chicken’ or ‘condemned beef’), the Agency is enabling pet food to be an illegal waste disposal system unbeknownst to the individuals purchasing these products (pet owners).
It is unknown at this point if FDA will allow pet owner comments on the Petition for Reconsideration. However in the meantime, if you agree with the position we provided – you can send your comments to FDA via email at AskCVM@fda.hhs.gov. Make sure to reference ‘Petition for Reconsideration Docket ID: FDA-2016-P-3578’.
Again, to read our original Citizen Petition Click Here.
To read the Addendum Click Here.
To read FDA’s response to Citizen Petition and Addendum Click Here.
And finally, to read our FDA Petition for Reconsideration Click Here.
Now we wait for FDA to decide if they will continue to allow the pet food industry to utilize illegal ingredients with no warning or disclosure to pet owners. It is unknown how long FDA will take to respond.
It is more than absurd that we have to ask for existing law to be enforced in pet food and have to ask that pet owners be provided the opportunity to make informed decisions when buying pet food. But we’ll continue to ask no matter how long it takes…because we won’t give up on our pets.
Wishing you and your pet(s) the best,
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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. Click Here to preview Petsumer Report. www.PetsumerReport.com
The 2019 List
Susan’s List of trusted pet foods. Click Here to learn more.