The schedule for the upcoming (August 2013) Association of American Feed Control Officials (AAFCO) showed something very unusual; the AAFCO agenda showed meetings for industry groups Pet Food Institute and American Feed Industry Association. This confusing meeting schedule led to a phone call to AAFCO. You are not going to believe what they told us.
The Association of American Feed Control Officials (AAFCO) is a an independent organization (listed as a not for profit corporation). Members of AAFCO are employees of State Department of Agriculture (though not all states participate). FDA representatives participate at all AAFCO meetings, and three FDA employees sit on the Board of Directors of AAFCO. AAFCO is responsible for pet food (and all animal food) ingredient definitions, pet food (and all animal food) label requirements, pet food (and all animal food) nutrient requirements. The AAFCO Mission statement (quoted from the 2013 Official Publication) states “To provide an open forum for the discussion of regulatory sciences in which regulators, the industry and consumers alike can enhance the assurances of feed safety, quality and effectiveness.”
Again, AAFCO members are state and federal employees. While wearing their ‘AAFCO hat’, these state and federal employees have no regulatory authority (they make the rules, they don’t enforce them). However, in their day job as a state or federal employee they do have regulatory powers; both FDA and State Department of Agriculture can force a recall or pull products from store shelves.
On June 13, 2013 the AAFCO website provided the 2013 Annual AAFCO Meeting Draft Agenda showing the following meetings listed on the schedule…
“Sunday August 11th 8:30 am – 4:30 pm PFI RAC Meeting”
“Sunday August 11th 1:30 pm – 7:30 pm AFIA Feed Regulatory Committee”
“Tuesday August 13th 8:00 am – 12:00 pm AFIA Ingredient Approval and Definitions Committee”
“Wednesday August 14th 1:00 pm – 5 pm PFI Working Group”
AAFCO – state and federal employees. PFI stands for Pet Food Institute – the lobby organization that represents Big Pet Food – industry. AFIA stands for American Feed Industry Association – the lobby organization representing all animal feed businesses and it’s ingredient suppliers – industry. In other words, the agenda for pet food regulatory meetings – meetings where state and federal employees decide the future of pet food regulations – also listed meetings of industry; separate meetings that were for industry members only.
Why? Why did the AAFCO meeting schedule list these industry group meetings – as part of the 2013 AAFCO Annual Meeting agenda? Mollie Morrissette and I called AAFCO and asked. Jennifer (of Federation of Animal Science Societies – the group AAFCO hired to manage the organization) spoke with us. After introductions I asked her about the Wednesday afternoon meeting – specifically I asked “what does PFI stand for?” (I thought I knew what PFI stood for – Pet Food Institute, but surely AAFCO wouldn’t host an industry meeting – so I thought there certainly must be some other explanation. Nope, there wasn’t.) Jennifer responded “Pet Food Institute”. To which I replied “why would a PFI meeting be listed on the agenda for the AAFCO meeting?”
And then Jennifer told us…“The (AAFCO) Board of Directors instructed me to contact three of the groups and offer them our extra meeting space.”
Jennifer told Mollie (in a follow up conversation) that the hotel provided AAFCO with various meeting rooms. AAFCO did not need all this meeting space, so in turn they – at no charge – provided the meeting space to industry groups (and only industry groups).
The meeting space provided to industry groups listed on the AAFCO Draft Agenda were removed from their website within 2 hours of our conversation with Jennifer at AAFCO offices (afternoon of June 13, 2013). However I took screen shot images of the document (providing a date and time stamp) and Mollie and I both saved the original Draft Agenda document.
Again, here is the meeting space AAFCO gave to industry that was listed on the original agenda…
Sunday August 11th 8:30 am – 4:30 pm PFI RAC Meeting (8 hours free meeting space)
Sunday August 11th 1:30 pm – 7:30 pm AFIA Feed Regulatory Committee (6 hours free meeting space)
Tuesday August 13th 8:00 am – 12:00 pm AFIA Ingredient Approval and Definitions Committee (4 hours free meeting space)
Wednesday August 14th 1:00 pm – 5 pm PFI Working Group (4 hours free meeting space)
The AAFCO Board of Directors voted to gift the Pet Food Institute 12 hours worth of free meeting space and voted to gift the American Feed Industry Association 10 hours worth of free meeting space.
On the AAFCO website – on the Whistle Blower Policy page it defines “Fraudulent or Dishonest Conduct” as…
“Misappropriation or misuse of AAFCO resources, such as funds, supplies, or other assets.”
Did AAFCO Board of Directors misappropriate resources? Would extra meeting space provided to AAFCO via the hotel be considered an AAFCO ‘resource’ and in turn, would gifting that meeting space to industry groups be considered misappropriation?
If pet food consumers were provided a vote on the above questions, I’m confident the majority would feel the AAFCO Board of Directors did indeed misappropriate resources by gifting industry groups free meeting space.
This is bad – however what’s really bad is that apparently the AAFCO Board of Directors did not realize this was a huge mistake (that is until a couple hours after we pointed it out to them how bad it was – when they promptly removed the meetings from the website). Pet food regulators and industry groups have been such pals and buddies for so long – they don’t even recognize when a line is crossed. Regulatory authorities gifting meeting space to industry (or vice versa) is not ethical. But they don’t see it that way. They think…we’re all friends, why wouldn’t we offer our friends some free meeting space? And there’s the problem.
How can AAFCO, State Department of Agriculture, and FDA properly regulate their friends? How can a proper inspection take place at the ‘home’ of a friend?
Think about this…
There has only been one recall over the last couple of years (to my knowledge) that the contaminant in the pet food/treat was found by the Department of Agriculture in the same state as the manufacturer. One.
As example…in 2012 a Diamond pet food manufacturing plant in Gaston, South Carolina experienced a large recall. Every variety of pet food made at the plant was eventually recalled. It wasn’t the South Carolina Department of Agriculture that found Salmonella in the pet food (same state as the plant), it was Michigan and Ohio. FDA follow up (after the recall) inspection of the plant found equipment held together with duct tape and cardboard. Why didn’t the South Carolina Department of Agriculture find the plant failed to maintain equipment prior to this recall? Do states not inspect (or properly inspect) manufacturing facilities located within their borders?
I’ve been told by insiders of pet food manufacturing that when inspectors come to many of these pet food plants, management is given days if not weeks advanced notice. Inspectors are led around the plant to areas management wants them to see (not to areas they don’t want them to see). Once ‘inspection’ is complete, everyone goes to lunch together – management and regulatory.
It’s hard to properly regulate your friends.
Here’s some potential friends of AAFCO’s (which includes FDA too)…(from the AAFCO website Committee Advisors webpage)…
Pet Food Institute, American Feed Industry Association, Pet Food Industry, Hills Pet Nutrition, National Grain and Feed Association, National Oilseed Processors Association, National Renderers Association, American Feed Industry Association, The Scotts Miracle-Gro Company, Archer Daniels Midland Company, Cargill, Lilly Research, Mosaic, Pfizer Animal Health.
Each of the above industry groups or corporations have been provided one or more advisory positions to AAFCO committees. Now guess how many consumer advocate advisors there are?
One. Dr. Jean Hofve.
Mollie Morrissette and I (through our consumer association) asked for two advisory positions to the pet food related committees in February 2013 (five months ago). AAFCO President Tim Darden continues to tell us he is discussing this with AAFCO attorneys. Makes you wonder if such conversations took place (with AAFCO attorneys lasting five months) when Cargill or Pfizer or Hills Pet Nutrition representatives were welcomed on board.
They don’t see it is unethical for regulatory authorities to have friendships with those they regulate. They don’t see it as unethical to gift meeting space to those they regulate. They don’t see it as unethical to continue to refuse to give consumers a voice.
And they wonder why we don’t trust them.
Wishing you and your pet(s) the best,
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