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Pet Food Regulations

So many issues from AAFCO meeting

From the worrisome African Swine Fever to DCM to excess vitamin D to controversy…a lot happened at this AAFCO meeting.

From the worrisome African Swine Fever to DCM to excess vitamin D to controversy…a lot happened at this AAFCO meeting.

At the opening session of every AAFCO meeting, everyone is introduced including all regulatory authorities. When the FDA officials were to be introduced (45 FDA representatives in attendance), this slide was put up on the large screens in the room:

Though our group enjoyed the pun at FDA’s expense, it seemed inappropriate for AAFCO to poke fun at FDA.

From the Sunday event on the Food Safety Modernization Act laws, the event provided this slide on “Rising animal food safety issues“:

The only details provided on African Swine Fever was the following:

The information they provided states that dogs and cats are not at risk, however we can safely assume that a great deal of pork meal ingredients used in US pet foods are imported from China where this disease is currently prevalent. If your pet food contains the ingredient “pork meal”, and you are concerned, call your manufacturer and ask them for the “Country of Origin” of the pork meal (or for that matter any pork ingredient).

Regarding DCM, the slide included some Big Pet Feed promotion:

There is NO evidence that proves a pet food “made by a well-established manufacturer that contains standard ingredients” is a DCM prevention. In fact, although this slide includes the label “FDA.gov” – the FDA has determined the most common ingredient in pet foods linked to DCM is chicken. Further, “well-established manufacturers” are included in the FDA list of manufacturers (Mars, Purina, Diamond, Hills). It was VERY puzzling why false/misleading information was presented by a AAFCO representative.

And the slide from Rising Animal Food Safety Issues on excess vitamin D:

In a later discussion of future inspections, the discussion included the potential for inspections of pet food retailers (not only manufacturers – pet food stores). AAFCO representatives surveyed Department of Agriculture (state) members and provided this slide of the current inspections of retail pet food stores:

And as you can see from the slide below, their major concern was pet food stores that sell minimally processed pet foods:

This was blatantly bias – as the same “research” was not performed for retail stores of highly processed pet foods which statistically have caused significantly more human and pet illnesses.

There was a discussion of prescription pet foods that was (strangely enough) presented by AFIA – Animal Feed Industry Association, a trade association.

AFIA asked AAFCO to develop rules/laws governing prescription pet foods – as currently there are NO laws regulating them any differently than typical pet foods. I fully agree with this stance and went to the microphone to share with AAFCO that the current “FDA policy” that regulatory authorities regulate Rx pet foods under is NOT law. An FDA “policy” allows Rx pet food to be treated as a drug, even though no clinical trials or manufacturing safety requirements of drugs are required – and this FDA “policy” is not legally binding. Legally speaking, the FDA policy that allows Rx pet foods to charge exorbitant prices and require a prescription from a veterinarian to purchase is not worth the paper the policy is written on; it’s not legal.

Dr. Judy Morgan went to the microphone and expressed concern as well. She told AAFCO that as a practicing veterinarian she could not have confidence in a product that was treated like a drug but not held to any requirements of a drug. (Representatives of Rx pet food manufacturers were sitting behind us and were heard making jokes about Dr. Judy Morgan’s sentiment.)

It is unknown if AAFCO will take any action.

During the Pet Food Committee meeting AAFCO provided more details of consumer surveys performed by AAFCO regarding potential pet food labeling updates. The following slide was presented on potential warning statements for pet food. On the left side of this slide is the possible warning statement for a raw pet food and a kibble pet food:

Though not included on the slide, but stated at the meeting – the pet owners surveyed took little issue with the warning on raw pet food because they already understood safe handling is necessary when dealing with raw meat. But the pet owners surveyed were shocked that the same safe handling is necessary with kibble pet foods, something they had no understanding of at all.

And again in the consumer survey results, AAFCO learned that consumers has no understanding of meat meal ingredients:

This emphasizes our concerns brought to FDA of consumers having no public access to the definitions of pet food ingredients (including the definition of chicken meal discussed here). AAFCO owns the legal definitions and charges any and everyone $120 a year for access ONLY due to a agreement between FDA and AAFCO.

In another discussion was the following concern of some pet food manufacturers claims in marketing or on labels their product contains 50% or 60% or whatever percentage of meat when actually those numbers are inflated. Such as if the pet food includes meat meal ingredients, those are moisture removed ingredients. The claims of 50% meat (or other high meat claims) are sometimes based on miscalculations of the manufacturer by adding high levels of moisture back into their total meat calculations for the meat meal ingredients misrepresenting to the consumer an inflated ‘meat’ percentage than what is actually in the pet food. AAFCO asked manufacturers (in red below) to make these claims based on “total weight”.

The bison/water buffalo issue was finally defined at this meeting too. Pet food labels that previously stated “buffalo” will now be required to distinguish between the American Buffalo (or Bison) and Water Buffalo (commonly sourced from India). Labels will be required to state ingredients as “Bison” or “Water Buffalo”, though it is unknown how long manufacturers will be given to update labels.

Another issue of concern that happened at this meeting doesn’t directly effect pet owners, but it does indirectly. During the Ingredient Definitions committee meeting was discussion of the legal definition of the feed ingredient “Oat Fiber“. Several industry suppliers/manufacturers of this ingredient spoke out against the AAFCO definition claiming it was a definition specific to ONLY one manufacturer. They shared if AAFCO approved the ingredient, their businesses would be severely damaged. And then an attorney representing one of the other manufacturers (whose ingredients would not meet the new AAFCO definition) spoke. He quoted AAFCO policy that states the organization will not define ingredients that are specific only to one manufacturer – written in AAFCO official procedures. This attorney once again reminded AAFCO if they approve this ingredient definition, it would be proprietary to only one manufacturer and that is a violation of AAFCO written policy. AAFCO ignored their own policies, AAFCO ignored the multiple other ingredient suppliers who paid their $500 to attend and voice their opinion – and AAFCO approved the ingredient definition that was specific to ONLY one supplier excluding all the others.

It would not surprise me if we soon hear of several new lawsuits against AAFCO over this. Their actions were very biased.

Another AAFCO meeting done. Next one is scheduled for January 2020.


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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8 Comments

8 Comments

  1. Laura Beveridge

    August 8, 2019 at 1:34 pm

    And I, as a consumer whose family has suffered great loss, will repeat the consumer motto….. DON’T PEE ON MY LEG AND TELL ME THAT IT IS RAINING. I am so tired of the lies, deceit, apathy, and carelessness of these organizations. I grow so tired of watching the bravado at these meetings and we must ALL pull together and fight this battle. I hope that every pet parent will reach out to at least 10 of their pet parent friends and offer as much education around these issues as you possibly can. Don’t wait until you go through what we have experienced in our loss. Educate yourself and those around you. Do all that you can because no one else will regulate and protect your furbabies for you!

  2. Cannoliamo

    August 8, 2019 at 3:08 pm

    […. overcome with words like “sad” and “disappointing” ….]

    Three comments come to mind ….

    1) The relationship between AAFCO, the FDA and the pet food manufacturing companies is FAR TOO CASUAL to be an effective program of pet food quality and safety. I think it’s time to follow the database lead taken for labeling that is mandated for use of pesticides regulated by the EPA under their MSDS requirements. EPA currently funds the National Pesticide Information Center – NPIC at Oregon State University

    http://npic.orst.edu/ingred/proddata.html

    that maintains pesticide safety information in a format available to the public. The format and definitions and safety standards have been uniformly consolidated and a consumer can evaluate the chemical ingredients, testing and toxicity data prior to purchasing a specific pesticide. I recognize that pet food is not as potentially toxic as pesticides, but, in many cases, it can be just as deadly.

    2) There needs to be a program of accountability for specific ingredients, manufacturing standards, packaging, transport, storage and recall that is effective at PREVENTING outbreaks of pet food poisoning, …. not simply RESPONDING to them.

    3) Any individual or company responsible for submitting an AAFCO label to a state regulatory authority must be certified as a professional bonded animal nutritionist and legally liable for maintaining compliance with any food manufactured, packaged or sold under their label.

    This meeting, if nothing else, emphasizes the need for a formal regulatory process that defines the inherent responsibility of each agency and company participant in ensuring that the pet food sold for consumption is both appropriately tested, packaged, and labelled as a safe and nutritious FOOD (not feed) and any consumer (including myself) should be able to access the information as necessary to have this assurance. I hope that AAFCO and the FDA takes their responsibilities for protecting our pets more seriously in the future. It appears that, as of now, they take it as a joke.

  3. Leslie

    August 8, 2019 at 5:25 pm

    I Find it funny in the DCM Slide that they quoted Freeman like she was speaking fact. I thought that Particular piece was an Opinion paper and was NOT peer reviewed. Smoke and Mirrors!

  4. ~Pacificsun~

    August 8, 2019 at 9:24 pm

    Thank you for enduring a tedious, deceitful and expensive meeting amounting to smoke and mirrors. If it wasn’t for you and your associates presence at the meeting, consumers wouldn’t know anything.

    I’m pretty good at reading comprehension. But I am confused as to what points AAFCO was trying to make while accompanied by the above slides. Is it simply a status on the current state of affairs? Like surveys taken, and the analysis of the consumer market. Or are they using them defend certain positions? Why are there so many “watermarks” on those slides? Are they being used out of context? Because usually a slideshow is supposed to accompany the speaker’s narrative. As in being a hard copy record of the the address.

    I am really confused as to what this is all about. Or in short …. what was the point of meeting in August 2019?? What was proposed? And what changed?

    • Susan Thixton

      August 9, 2019 at 8:27 am

      The slides were from multiple presentations throughout the entire AAFCO meeting. The watermarks were from the organization – such as AFIA – that presented the information the slide was part of. The consumer survey slides were from a paid consumer survey – paid by AAFCO – regarding potential label updates. AAFCO hired a company to perform focus groups with pet owners regarding those potential label updates to determine if the potential updates were well received or not.

      AAFCO meetings cover many different topics. I probably made it a bit confusing with my presentation of the meeting – trying to give pet owners an overview of all the proceedings.

  5. Ettore Giarratana III

    August 9, 2019 at 4:53 am

    Thank-you, Susan for your efforts on our behalf. We appreciate you so very much.

  6. John Bartiromo

    August 13, 2019 at 12:07 pm

    Thank you Susan and the whole TAPF Team and supporters – of whom I intend to join – for your considerable work on behalf of pets and pet parents alike.
    How humans who do these things – actions that they know will harm and kill to make another buck – sleep at night is beyond my understanding. I don’t know if karma exists or if there is a penalty in the here-after for such people: I question there being anything divine or even hopeful in our existence. It’s surprising that these non-human creatures choose us out of anything but pure acquiescence for survival…certainly unaware of the scope of man’s true nature of selfish and wanton greed.
    But you few do give my soul a bit of light and I commend you for your amazing strength in the face of adversity and in the den of the jackals.
    You are truly heroic.

  7. Tina

    August 28, 2019 at 6:07 pm

    Thanks for the summary update with pictures Susan.

    I have some information regarding the excess vitamin D that was put in dog premix packages for Hill’s. The supplier is DSM. A rep named Hugh Welsh wrote this to me via email after I submitted a question via DSM’s online contact form & made a few calls to some of DSM’s US offices:

    “DSM made a Lot/Two Batches of premix for Hills Pet Nutrition on August 16, 2018 at our Fort Worth, Texas plant into which an operator mistakenly put too Vitamin D instead of Vitamin E. These two batches are the only batches that had too much Vitamin D and these batches were only shipped to Hills Pet Nutrition in Topeka, Kansas. No other DSM products or customers were in any way impacted by this one mistake. The Fort Worth plant’s Food Safety Plan has been updated and positive release controls such as daily inventory management have been put in place so that a mistake of this nature cannot happen again.”

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