Imagine an hour long conversation with a federal agency defending its action of ignoring law. That was what happened yesterday with our FDA meeting.
For the first 15 minutes or so of our hour long meeting (3/10/16), the FDA listened to our evidence proving the serious risk to FDA’s practice of allowing 4D animal material into pet food – which by the way, is a direct violation of law (that FDA is charged with enforcing). For the following 45 minutes, the FDA defended their ‘aiding and abetting’ practice of allowing pet food to violate federal law.
We provided the FDA with evidence that their sister federal organization – the USDA – was concerned about the risk to pets when dead livestock is rendered into pet food. The USDA feels decaying animal carcasses are a risk to pets due to the cooking process producing endotoxins; “these toxins can cause disease and pet food manufacturers do not test their products for endotoxins”. FDA was unconcerned. The FDA stated “some of this material is safe”. (Notice they did not say ‘all’.)
We shared that Donald R. Strombeck, DVM, PhD, Professor Emeritus, University of California, Davis, School of Veterinary Medicine has stated endotoxins in pet food can cause “damage to the liver”. FDA was unconcerned sharing “We are aware of his research and his feelings about dry dog food.”
FDA told us we have a “theory” that perhaps can be investigated, but shared it would be a multi-million dollar testing project that is not within the FDA budget; it was suggested we ask Congress to give FDA more money. A little guilt was thrown in to deflect us, FDA sharing to test the risk of 4D animal material to pets a “terminal study” would need to be performed. A “terminal study” means dogs and cats would be killed to determine how the illegal pet food material actually effects the pets consuming the foods.
We shared with FDA ‘no millions of dollars needs to be spent; no pets need to give their lives. The ‘fix’ to this is FDA enforcing the law. Stop allowing bacteria filled, putrid (and illegal) dead livestock into pet food.’
(brace yourself) FDA stated (a direct quote): “So 3 billion plus animals should go to landfills?”
To which I responded (a direct quote): “So you want pets become living landfills? Is that what you are saying?”
Another FDA representative quickly stepped in and deflected the conversation. At this point, FDA stated that all meats even for human consumption contain endotoxins.
Again, we steered the conversation back on track stating the true risk to pets is not low levels of endotoxins (our bodies and pets bodies have natural methods to safely handle low levels of endotoxins) – we again told FDA high levels of endotoxins in rendered 4D animals, as warned by the USDA, is the risk we are bringing to their attention.
And FDA again steered the conversation away from the fact that illegal bacteria contaminated material is being dumped into pet food stating ‘Endotoxins are not just from just one potential source – I don’t think you can blame that one source.’ (Meaning FDA doesn’t feel dead livestock that has laid in the field for days prior to rendering, contaminated with bacteria – resulting in dangerous levels of endotoxins – resulting in pet death – are more of a risk that rendered bits and pieces from a slaughtered animal. The law does, but not FDA.)
FDA adamantly stated they will not do a testing project that will kill pets to determine if dead livestock are a risk.
FDA was reminded that their sister federal agency – the USDA – has stated endotoxins cause disease in pets. FDA was unmoved except suggesting that perhaps USDA should be the one to do the testing (reminder, it is FDA responsibility – not USDA’s – to assure consumers pet foods are safe).
Besides myself in this FDA meeting, there was a pet owner whose own dog died from eating a pet food he firmly believes was highly contaminated with endotoxins. This pet owner gathered more scientific evidence than anyone can image – all of that evidence was provided to FDA. He provided FDA the clinical lab results from his dying dog matching every symptom of endotoxemia, he provided studies proving that some pet food ingredients (example propylene glycol) increase the absorption of endotoxins into the blood stream, study after study was provided. My patience with FDA stopped quickly when FDA kept asking this pet owner for more (more studies, has the pet owner tested the pet food himself, necropsy results).
I interrupted FDA and told them ‘This is a pet owner, it is not his responsibility to test pet foods, it is not his responsibility to provide FDA with data proving illegal ingredients are a risk to pets. That is FDA’s responsibility. It is our responsibility to bring serious concerns to FDA’s attention and we certainly hope you listen to us.”
We asked FDA what they are going to do about the very serious risk of endotoxins. They told us “we might” add it to the testing schedule for 2017, sharing they would only test “a handful” of products. FDA stated perhaps this could be a multi-year project.
I thanked FDA for this effort, but shared I felt sorry for all the pets and their grieving families that are going to die between now and then due to illegal, endotoxin contaminated pet foods. At this point, FDA reminded me (scolded me) for a statement (which I still stand by) said at an AAFCO meeting 8 months ago. I made a statement to the chair of the Pet Food Committee that they as individuals might have pets of their own, but they are nothing like the pet owners I represent. (AAFCO members and FDA representatives that own a pet are in a position to do something about a bad pet food that might sicken or kill their pet. Pet owners that I represent don’t have that benefit.) FDA told me they are pet owners too, and they didn’t appreciate my accusations they are not. My response: ‘No accusations intended – I simply stated I feel sorry for the pets that ARE going to die between now and when FDA decides to do something about this. One of those pets that die could be one of yours – depending on what pet food you feed’ (hopefully leaving them with something to think about).
And lastly I directly asked the FDA – “Is FDA going to continue to allow non-slaughtered, dead livestock – that are a direct violation of the Federal Food, Drug and Cosmetic Act – into pet food?” The FDA told us “We’re going to allow animals that have died other than by slaughter that are further processed, we will allow those ingredients in pet food.” The FDA openly admitted they will continue to allow pet food to violate federal law.
I openly admit I wasn’t the most pleasant person on that phone call. The pet owner on the call remained composed, even under direct assault by FDA. I did not. To this pet owner – my sincere thanks for your composure, and your very skilled knowledge on the topic of endotoxins. What a pity (what a crime) FDA did not take heed to the evidence you presented.
To FDA, I thank you for your time. I adamantly disagree with your opinion that 4D material is safe for pets to consume and I will continue with my battle asking FDA to enforce federal law with pet food. I will continue to question every authority on the planet if need be. I will be knocking on your door again and again – for as long as it takes.
Furious doesn’t even explain it. The simple truth of this situation: with the aid of FDA, the pet food industry is allowed to make billions of dollars each year selling adulterated pet foods to unknowing consumers, and pets are dying because of it. Some would call that aiding and abetting a criminal.
We are not done with this battle.
Wishing you and your pet(s) the best,
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