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,
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