Report of the August 2024 AAFCO Meeting

Another AAFCO meeting is complete.

AAFCO’s future is in deep trouble. The FDA has recently withdrawn from their agreement to work with AAFCO on approving new ingredients (more on this soon), and the pet food manufacturer members of the Pet Food Institute are trying to push a bill through Congress that would ultimately put pet food solely under the jurisdiction of FDA, removing all state regulation of pet food. Should the PURR Act be passed, many State Feed Officials (who make up the membership of AAFCO) will be out of a job – and AAFCO will have no one at meetings (since the majority of the crowd is pet food related). It was clear at this meeting the members of AAFCO are concerned about the future. 

It is ironic that the very people AAFCO has catered to the most over the years – the pet food manufacturer members of the Pet Food Institute – are the ones that could be responsible for the destruction of AAFCO. 

It is concerning that we clearly saw the FDA moving forward with elements of the PURR Act even before a vote on the Act occurs in Congress. It was concerningly clear the FDA’s Center for Veterinary Medicine allegiance with the Pet Food Institute is even stronger than we have witnessed in the past. 

During a brief explanation by FDA regarding their new decision to approve pet food/animal feed ingredients (separating from AAFCO), Dr. Timothy Schell (of FDA) stated the former system with AAFCO is ending in part due to the “instability it causes industry”. He mentioned nothing about the concerns we (consumers) have addressed with FDA for years regarding the flawed AAFCO nutrient profiles, the state regulations written by AAFCO being behind a paywall, or the long experienced lack of concern for pet owners from (most but not all) AAFCO members. Dr. Schell only mentioned the issues suffered by industry.

An example of what AAFCO has done, that FDA is already taking over is the salmon fish feed ingredient “Antarctic Krill Meal” discussed (voted to approve) at this recent meeting. The ingredient had already been approved by the FDA, AAFCO was simply adding it to their library of approved ingredients. 

While Antarctic Krill Meal sounds safe enough for a salmon feed ingredient, the truth is very different. “Antarctic Krill Meal – Intended use is in salmonid feed to enhance the pink to orange-red color of the flesh of salmonid fish.” This ingredient is used to make farmed salmon appear to be wild salmon in color. The ingredient is allowed to be dyed, so that the farmed salmon fed the dyed ingredient has the same beautiful orange-red flesh color of wild salmon. 

And…the ingredient Antarctic Krill Meal is legally allowed (by definition) to contain:

• “250 mg/kg of ethoxyquin;
• 2 mg/kg of lead;

• 5 mg/kg of arsenic;

• 1 mg/kg of mercury;

• 2 mg/kg of cadmium;

• 2,500 mg/kg of fluoride;

• And 170 mg/kg of astaxanthin.”

Remember…the farmed salmon that consumes this ingredient is NOT just for pet food, the salmon that eats this ingredient full of dye, a dangerous chemical preservative, and a multitude of heavy metals is served to you too. It is allowed by federal regulations (FDA) and now state regulations to dye the fish you and your pet consumes.

During the Ingredient Definitions Committee session, Dr. Mary-Grace Danao from the University of Nebraska provided an explanation of High Pressure Pasteurization (HPP). Pet owners can read more about HPP from Dr. Danao here: https://fpc.unl.edu/petfoodworkshop

During the Pet Food Committee session, we learned that pet food label updates – which took AAFCO more than 10 years to complete – will not be implemented for another six years (required to be implemented by 2030). BUT, there is a possibility that these label updates might not ever happen due to the PURR Act (from Pet Food Institute). We were told that some states are NOT adopting these AAFCO label updates because of the uncertain future of state regulation of pet food. 

The most telling and worrisome event of the entire meeting was when the Pet Food Committee briefly discussed the much needed voluntary copper maximum of pet foods. 

Background: for the last several years, science has proven there is an increase of copper storage disease (liver disease) in dogs, and many scientists (independent of Big Pet Feed influence) directly link the increase in liver disease to pet food having no maximum of copper established. Cat and dog food manufacturers can add any amount of copper supplement currently (over the required minimum). There have been years of arguments against a copper maximum – mainly from scientists representing the Pet Food Institute (though employed directly by Hill’s Pet Food). A working group was formed, FDA’s Dr. William Burkholder was chair of this working group, and Dr. Burkholder personally refused to allow Dr. Sharon Center to participate (veterinarian expert liver disease in dogs at Cornell University who pushed for this discussion to occur). The only consensus the working group could come up with was an opportunity for pet food manufacturers to voluntarily limit the level of copper in their pet foods, allowing them to make a ‘limited copper’ claim on their label. 

But, when this proposed limited copper label claim was discussed at AAFCO, the scientists from Pet Food Institute (in this instance Hill’s Pet Food) continued to argue against it. A few months before AAFCO was to vote on the issue, the Hill’s Pet Food scientists published a paper claiming that their research indicates pet “liver copper concentrations” were not problematic. Dr. Leslie Hancock – co-author and Hill’s pet food chief medical officer stated “although there is an increase in copper concentrations, it is not clinically significant.”

(Dr. Leslie Hancock who claimed documented increases in copper concentrations in pet livers was also part of the AAFCO working group. To read the full report from AAFCO’s working group, Click Here.)

However, Dr. Hancock’s published paper was retracted because significant flaws were found by unbiased (not employed by Hill’s Pet Food) scientists. 

When the paper was retracted, AAFCO was in a position to discuss the issue again because the author(s) of the flawed paper were part of the AAFCO working group. This new discussion occurred in the Pet Food Committee session of this recent meeting. BUT, the discussion lasted only a few minutes, even with comments from several asking AAFCO to vote again, asking AAFCO to consider the science Dr. Hancock provided was flawed. 

Dr. Karen Donnelly of FDA shut down the discussion almost immediately. Dr. Donnelly refused to allow the voluntary limited copper label claim to be voted on again. And it was clear Dr. Donnelly had already informed the scientists from Hill’s a new vote was not going to happen. During every other AAFCO discussion on copper, the Hill’s veterinarians were at the meetings ready to argue against limiting copper (based on their flawed science). But this time, they were nowhere in sight. It was clear, they already knew. It was clear, Dr. Karen Donnelly had informed them she would stop any further vote on the issue. 

AAFCO – led by Dr. Karen Donnelly of FDA – refused to allow pet foods to voluntarily limit the level of copper in their pet foods (with a label claim of limited copper that would alert pet owners to potentially safer levels of copper). By this extremely biased action, AAFCO and FDA proved to industry that flawed science works. Submit a bad paper with flawed science, get what you want. 

Should any pet owner wish to provide Dr. Karen Donnelly of FDA their opinion on a voluntary limited copper level (with label claim) on pet food, her email address is: karen.donnelly2@fda.hhs.gov.

And then at the close of this last session – the Pet Food Committee session – Stan Cook of Missouri Department of Agriculture, co-chair of the Pet Food Committee informed the attendees he was retiring from the Pet Food Committee in a tearful (for him) few minutes. While some in the audience might have been moved by his words, my thoughts went to employees that worked at a pet food plant in Missouri that Mr. Cook and others at Missouri Department of Agriculture inspected and failed to take any action on (Mars Petcare, Joplin MO). While Mr. Cook was tearfully discussing how much he will miss his industry and regulatory friends at AAFCO, my thoughts went to the many employees of that pet food plant who have died over the past 11 years linked to exposure to phosphine gas (from fumigated ingredients), mycotoxins, diacetyl, and other contaminants ignored by regulatory (18 employee deaths in the past 11 years, most were in their 40s and 50s when they died). My thoughts went to employees that remain sick today because not one regulatory authority protected them or the pets that consumed pet food made there. 

Please know, not all state feed officials/AAFCO members are heartless. Many…perhaps better phrased as some…actually care about regulating pet foods as law requires them to do. They often try to perform as their job requires, but are limited with the amount of influence (control) the industry has over regulatory. 

Was this our last AAFCO meeting? I honestly don’t know what the future is going to bring. But I can say I have serious concerns that FDA has already closed ranks with the Pet Food Institute, and fear FDA’s tight allegiance with industry could make things much worse if FDA alone regulates pet food. From actions and words at the meeting, it certainly appeared that the FDA and the Pet Food Institute have already decided what the future is going to bring, and we can safely assume it will NOT be good for our pets. (More information soon on this issue.)

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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