Perhaps assuming no pet owner would ever see it, FDA gave a speech to industry that is beyond concerning.
Dr. Steven Solomon – FDA’s director of Center for Veterinary Medicine – gave a speech at a pet food industry trade event in October 2018. We filed a Freedom of Information Act request for that speech, it was just provided by FDA (9/11/2019). What FDA told industry is shocking, confirms illegal FDA activity, and is completely unethical.
In October of 2018 – in the same month that FDA gave this speech to industry – we (Association for Truth in Pet Food) asked FDA to meet with pet owners (asking for equal time as industry). 11 months later, FDA has not given us a date to hold this event. But the agency certainly told the industry they need to “engage with” consumers. Quoting Dr. Solomon’s speech (bold added):
“The only way to fully achieve our mission of protecting human and animal health is by leveraging and collaborating with our fellow public health and regulatory partners. We also need to actively engage with our industry and consumer stakeholders so we understand their issues and concerns as we address a number of ongoing and emerging challenges.”
In multiple locations of Dr. Solomon’s speech, he discusses FDA “transparency“. However what he told industry about pentobarbital is NOTHING we have heard from FDA before (no transparency with pet owners) (bold added):
“Most of us probably think that pentobarbital comes from a couple of bad actors that use a euthanized animal when they know they aren’t really supposed to. New evidence is showing that it may be a much more pervasive problem throughout the animal food supply than originally thought, and we have reason to believe rendered products can be a source for pentobarbital, if not controlled.”
“Rendered ingredients are a valuable animal food ingredient and we don’t want you to think we do not recognize that and the valuable services the rendering industry provides to both the animal food industry and the environment. We have had some pretty frank conversations around this topic with NRA and PFI staff – we appreciate the willingness to continue the dialogue, as it’s important for all of us.”
“NRA” above stands for National Renderers Association, “PFI” stands for Pet Food Institute – both industry trade associations. FDA has had “frank conversations” about pentobarbital in rendered pet food ingredients with industry…but has said nothing to pet owners. By Dr. Solomon openly admitting FDA has alerted industry and NOT alerted pet owners to the same risk – the agency has openly acted to protect the profits of NRA and PFI members, putting perhaps millions of pets at risk from pentobarbital contaminated ingredients.
Also notice that Dr. Solomon stated rendered ingredients are a “valuable service” for “the environment” (second paragraph quoted above). We can certainly agree that the rendered waste FDA allows into pet food (diseased animals and animals that have died otherwise than by slaughter) is a valuable service for the environment…but few pet owners would agree this would be considered quality nutrition, should be allowed in pet food with no warning or disclosure on the label.
And then Dr. Solomon spills the beans about why laws promised pet owners after the deadly 2007 pet food recall were deleted. (Click Here to learn more.)
“Finally, the ingredient standards and definitions provision of the 2007 FDA Amendments Act (FDAAA) was deleted. Enactment of this provision has long challenged the Agency, and its deletion provides an opportunity for us to reaffirm our relationship with AAFCO as a means of developing definitions for ingredients used in animal food. Continuing to work with AAFCO on defining ingredients ensures consistency for the regulated industry and serves our public health mission by having our scientists conduct the review of new ingredients.”
The 2007 laws – written to prevent another deadly pet food disaster – were deleted because FDA wanted to work with AAFCO (instead of doing the work themselves as these laws required). With AAFCO having control over pet food ingredient definitions, pet owners are denied public access to definitions (definitions cost $120 per year to read). The result of FDA’s “work with AAFCO” – is NO transparency for pet owners; no opportunity for pet owners to understand what they are feeding their pet.
The following quote of Dr. Solomon’s speech actually admits a violation of federal law by FDA (bold added):
“We truly appreciate the collaboration we have had with both NGFA and PFI in recent years. These collaborations have helped give us a greater sense of appreciation for the work that each other does, and I hope I can say that they have been beneficial to both sides. While we may not always agree, we have a relationship that is based in mutual respect and we are willing to listen to each other’s concerns.”
Federal law is very specific to who FDA can collaborate with; “The Secretary shall implement programs and policies that will foster collaboration between the Administration, the National Institutes of Health, and other science-based Federal agencies.” In other words, FDA is ONLY allowed (by law) to collaborate with other federal agencies. The agency is NOT allowed to collaborate with industry trade associations.
And then, Dr. Solomon’s speech crosses over into an ethics violation – soliciting industry to lobby legislators for money on behalf of FDA (red arrows and exclamation added to image for emphasis).
“In the spirit of collaboration, we can use your help with a few things. One area that you are in a unique position to assist us with is talking to legislators and appropriators at all levels.”
This is the perfect example why federal law ONLY allows FDA to collaborate with other federal agencies – not industry. When industry lobby’s Congress on FDA’s behalf – when industry performs special favors for FDA – pet owners lose, pets die.
To read the full speech of Dr. Solomon, Click Here.
Please report these legal/ethics violations and lack of transparency concerns of FDA/CVM to your representatives in Congress. We pet owners need to do some lobbying of our own. Example email/letter:
FDA’s Center for Veterinary Medicine director – Dr. Steven Solomon – gave a speech to industry in October 2018 (recently obtained via Freedom of Information Act request). FDA admitted to industry that pentobarbital (a drug used to euthanize animals) in pet food is “more pervasive problem throughout the animal food supply than originally thought”. FDA had discussions with industry about this dangerous problem of pet food, but the agency has never alerted pet owners to the situation. I am appalled to learn from these FOIA documents FDA has kept this dangerous secret with the pet food industry.
The FOIA documents also evidence FDA’s open collaboration with the pet food industry. The Federal Food Drug and Cosmetic Act only allows FDA to collaborate with another federal agency. Please explain how FDA is allowed to violate federal law and collaborate with industry.
I also learned through the FOIA documents of Dr. Steven Solomon’s speech that FDA solicited industry to lobby Congress on the Agency’s behalf. “In the spirit of collaboration, we can use your help with a few things. One area that you are in a unique position to assist us with is talking to legislators and appropriators at all levels.” I find this completely unacceptable and unethical for the director of CVM to solicit industry in this manner.
I am asking for a full investigation into the operations of FDA’s Center for Veterinary Medicine. This division of the FDA openly allows industry to violate federal law, one example being FDA CVM allows “diseased animals and animals that have died other than by slaughter” into pet food with no warning or disclosure to pet owners. Another violation is through FDA CVM Memorandum of Understanding agreement pet owners across the U.S. are denied public access to the legal definitions of pet food ingredients – having no means to understand the products they provide their pet. Please see this Citizen Petition, FDA response, Petition for Reconsideration and pet owner comments here: https://www.regulations.gov/docket?D=FDA-2016-P-3578. FDA CVM openly and frequently ignores federal laws governing pet food, putting millions of pet’s lives at risk. Please investigate and provide me a detailed response to your findings.
Wishing you and your pet(s) the best,
Susan Thixton
Pet Food Safety Advocate
Author Buyer Beware, Co-Author Dinner PAWsible
TruthaboutPetFood.com
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Kathrynne Holden
September 12, 2019 at 11:55 am
Susan, thanks so much for your diligence in alerting us to the perfidy of the pet food industry and FDA. It is very much appreciated.
MC
September 12, 2019 at 12:03 pm
So, who is this agency protecting? Does not appear to be the consumer.
Cannoliamo
September 12, 2019 at 12:51 pm
Susan, …. when you say
“This division of the FDA openly allows industry to violate federal law, one example being FDA CVM allows “diseased animals and animals that have died other than by slaughter” into pet food with no warning or disclosure to pet owners.”
I thought CVM withdrew the Compliance Policy Guides (CPG) that allowed the use of 4D (dead, dying, diseased, disabled) animals in rendered pet food products on April 30
https://www.fda.gov/animal-veterinary/cvm-updates/fda-withdraws-outdated-compliance-policy-guides-use-certain-animal-derived-materials-animal-food?utm_campaign=4-30-2019-CPGs&utm_medium=email&utm_source=Eloqua
following the same rules FDA used to prohibit the use of 4D ingredients in human food and soon after they published the analytical testing method for pentobarbital in tallow
https://www.fda.gov/media/120102/download
Is the FDA / CVM simply using their “regulatory discretion” to look the other way and ????? ??? ?? ?? ??????????? in pet food without requiring any pentobarbital testing and analysis as this article describes?
http://www.poisonedpets.com/fda-pulls-the-plug-on-policy-guides-which-allowed-4d-meat-in-pet-food-but-admits-it-might-still-get-a-pass/
What’s the purpose of CVM withdrawing the CPG allowing use of 4D ingredients if they’re going to then allow the use of 4D ingredients in pet food without requiring any testing? Is FDA simply covering up their responsibility to protect our pets from eating 4D-contaminated food?
btw, …. how much was Smucker fined for their horse meat pentobarbital contamination incident in Gravy Train?
Susan Thixton
September 12, 2019 at 12:58 pm
The FDA withdrew the Compliance policies, but they did not withdraw their allowance of diseased animals and animals that have died other than by slaughter in pet food. You can read FDA’s response to our Citizen Petition to verify that. https://truthaboutpetfood.com/wp-content/uploads/2019/06/Final_Response_-_Letter_from_FDA_CVM_to_AssociationforTruthinPetFood_com.pdf FDA stated “we do not believe that the use of diseased animals or animals that have died otherwise than by slaughter to make animal food poses a safe concern and we intend to continue to exercise enforcement discretion”. Page 5.
To me, the purpose of CVM withdrawing the CPGs was to remove from any public document FDA is allowing their use.
And to my knowledge, Smucker was not fined for their pentobarbital contaminated pet foods.
Cannoliamo
September 12, 2019 at 1:05 pm
Thanks for the clarification.
Solomon and CVM want to pretend they are concerned about use of 4D ingredients (including pentobarbital) simply to cover up their regulatory enforcement negligence and not be open to public scrutiny for permitting the manufacture and sale of 4D pet food. I find this behavior simply abominable. Count me in if there’s any additional consumer action that can force administrative compliance.
readerguest9
September 12, 2019 at 12:55 pm
We have known this for years after reading Food Pets Die for: Shocking Facts about Pet Food
book by Ann N. Martin
Ann Martin was the first to expose the fact that euthanized killed cats and killed dogs from animal shelters and vet clinics are common free protein ingredients in many commercial pet foods. ..
The Rendering Companies offer this free service to pick up all the killed dogs and cats at the animal killing centers everywhere and the pet bodies are ground up and cooked up for pet food for kibble and canned.
With free ingredients, especially protein, the most expensive ingredient, and the Big Pet Food corporations, can get it free from killing centers, makes for a very profitable product of pet food kibble and pet canned food.
Why fall for this anymore. The grocery store has real food, real eggs, real veggies, chia seeds for fiber and firm poop so there is No need to buy pet food kibble or pet food canned food from big pet food corporations.
If your pet dies, don’t dare leave it at the vet clinic, take the body home to bury in your backyard or have your pet cremated.
Ms. B Dawson
September 12, 2019 at 1:16 pm
Well that’s interesting.
My concern with the pentobarbital being “a much more pervasive problem” is that rendered ingredients aren’t always what consumers think. Non-species specific animal fat is pretty much recognized, at least by readers here, to be a bad thing even without any contamination.
But meat meals are considered rendered products, including species specific ones. Rendering is a process that doesn’t concern itself with what is being rendered. Lard is a rendered, human consumable product for instance.
I would conclude from this FDA disclosure that consumers aren’t protected from pentobarbital contamination even if they purchase a top brand of holistic, natural, grass-fed, all-natural ultra-premium, highest award winning food that costs $10 per pound. If the company itself isn’t testing each batch, we don’t know because any rendered ingredient could be contaminated.
Thanks, FDA. I’m so glad you are dedicated to stopping this instead of squandering your limited resources on other issues like, say, alarming the public by prematurely publishing inconclusive research about DCM.
Thank doG I can afford to feed my Peaceable Kingdom (including the humans!) real, recognizable food.
Laurie Raymond
September 12, 2019 at 3:05 pm
Species specific meals might not be contaminated – but because the pet food industry has colluded to prevent transparency in the food chain – that is, no manufacturer will identify the specific rendering company from which it purchases its meals, and there are over 450 rendering companies in this country, we cannot check and verify the reputation and history of violations of the renderers supplying the brand we are feeding. Nature’s Logic and Open Farm are the only feed grade companies that will release this information. I argued with the Nature’s Logic owner for several years, insisting that this information is essential to substantiating claims and providing transparency to consumers. Then they did it. Open Farm made this their practice from the beginning. But now it has grown large enough that I should check it again. The thing is, the government agencies charged with protecting the wholesomeness of pet food have abdicated. We are not given the tools to verify claims and follow the standard consumer due diligence advice of “trust but verify.”
B Dawson
September 12, 2019 at 5:04 pm
You expanded my slightly cynical (sarcastic?) point very well, thank you Laurie.
When access to official definitions cost $120 annually (and AAFCO likes to fiddle with the names if something gets a bad reputation) the definition of ‘rendered’ isn’t well understood and can include a whole lot things consumers might not even think fall into the category.
Add to that companies such as Evanger’s who consistently seem to be hot water over something that’s never ‘their fault’ and the consumer has no hope of making informed decisions.
No matter what a company tells you today, tomorrow is another day. A decade in the industry taught me that. Now I’m afraid I adhere to the lead character’s catch phrase from ‘House, MD’: everyone lies.
~ Pet Owner ~
September 12, 2019 at 8:18 pm
So true. Because there’s no consequence for doing otherwise.
And yet if you lie in court under oath you can be convicted (penalized) for perjury,
Dianne & Pets
September 12, 2019 at 10:13 pm
My vet office has declared this to be pet nutrition month and is offering free consultations, They are also posting a series of myth versus fact items, This is an example “‘By-products’ are a common buzzword in pet food marketing. But what are they?
Myth: By-products are low in nutritional value and contain hair, horns, hooves, beaks, feet and feathers.
Truth: A by-product comes from the same sources as human food. It is the clean, fresh organ meats that are more nutrient dense than the meat that comes from muscle.” This is another winner ”
In the internet age, it can be difficult to sort through the vast amounts of information available. How can you be sure the website you’re reading is trustworthy?
Check out these great resources if you want to do some at-home research on pet nutrition!
https://bit.ly/2MeTm9F
https://bit.ly/2OQwlfp
#YourVetKnowsBest #PetNutrition”
The link is to this document https://www.wsava.org/WSAVA/media/Arpita-and-Emma-editorial/The-Savvy-Dog-Owner-s-Guide-to-Nutrition-on-the-Internet.pdf?fbclid=IwAR3cJJCbiByiruAdnD_3D8j3AN-y6UC0ATIafFerejFbJ1AoThjEi0VDcFE The FDA, FPI and AAFCO are considered good sources of information. Arghhh!!! Who is feeding them this?
Do you have a link to the documents you talk about in this post that doesn’t go through your website? I would like to send the link to them, but I am concerned that they may have been brainwashed against you.
Susan Thixton
September 13, 2019 at 7:50 am
The best to share with vets would be the FDA Final Response posted here: https://www.regulations.gov/docket?D=FDA-2016-P-3578. They can download it directly from the Regulations.gov website and read that FDA doesn’t think diseased animals and animals that have died other than slaughter are safe.
Ms. B Dawson
September 13, 2019 at 10:46 am
This is a perfect example of stating a few facts and then mixing in industry double speak. What makes this “education campaign” infuriating is that it whitewashes all the heinous violations that Susan is so dedicated to exposing.
Here is AAFCO’s definition: “Meat by-products is the non-rendered, clean parts, other than meat, derived from slaughtered mammals. It includes, but is not limited to, lungs, spleen, kidneys, brain, livers, blood, bone, partially de-fatted low temperature fatty tissue, and stomachs and intestines freed of their contents. It does not include hair, horns, teeth and hoofs. It shall be suitable for use in animal feed. If it bears a name descriptive of its kind, it must correspond thereto.”
The legal definition of by-products excludes the things your vet claims and therefore s/he has made a truthful statement. It has been my experience that consumers DO believe horns, hooves, hair, teeth, beaks and such are included in by-products. While these things may find their way into feed, they are not legally allowed.
However, your vet’s statement “A by-product comes from the same sources as human food” as an absolute is blatantly false and your vet needs to amend that. The only way this would be true is if you argue that ALL livestock is raised for human consumption and ignore the fact that even if the animal dies by slaughter, the carcass can still be deemed unfit for humans when inspected. This is, of course how the industry uses information to mislead.
In order to get through to vets, you need to separate out things like the above. Vets, just like consumers, have limited time to research things that have already been pre-digested (no pun intended) for them by sources they have been taught to trust. Your vet has been taught to trust AAFCO and consumers are taught to trust their vets. It is a difficult chain to interrupt.
Kudos to you Dianne for trying to help your vet gain a better perspective. Be persistent, it can be a long road and you never know what the ‘ah-ha!’ moment will be for your vet.
Dianne & Pets
September 14, 2019 at 2:39 am
this is the response I made, but, it would seem that I was not accurate. Per AAFCO/FDA ingredient definitions, by products can be
“slaughtered or non-slaughtered whole animal
carcasses or any part of the animal including horn,
hoof, hide and intestines. Any animal species is allowed in this
ingredient.” However, animal digest “is material sourced from any species of slaughtered or non-slaughtered animal carcass or
animal part that has been partially processed through
chemicals and water – hydrolysis. Animal digest does
not include hair, horn, hoofs. Any animal species is
allowed in this ingredient.”