The crimes ignored in pet food are many, but all of us can battle the injustices together. Here are some of our recent efforts and how you can help with pet food advocacy.
FDA and AAFCO Memorandum of Understanding
One of the worst injustices that pet owners face is no public access to pet food ingredient definitions and being provided with a public voice in the process. For human food, every legal decision is published in the Federal Register allowing anyone to provide comment. The same is not true for pet food.
In pet food, chicken (as example) doesn’t mean the same thing as chicken in human food. Pet food chicken has it’s own legal definition (a definition VERY different than that of human food), and it’s a privately owned definition. AAFCO – the Association of American Feed Control Officials – owns all pet food ingredient legal definitions and charges $120 per person per year to view/read the legal definitions. For a pet owner to provide comment on a pet food ingredient definition, they must attend AAFCO meetings which cost $550 each meeting (not including travel expense and hotel).
AAFCO is allowed this unique privilege to own and write law because of an agreement – termed a Memorandum of Understanding (MOU) – between FDA and AAFCO. We oppose the current MOU between FDA and AAFCO, we believe pet owners should be provided public access to all pet food ingredient definitions and be provided with public comment opportunity to each definition. How can any pet owner understand what they are feeding their pet without this public access?
The good news for pet owners, is the current FDA/AAFCO Memorandum of Understanding expires October 1, 2019 – six months from now. In late January 2019, we sent FDA questions about the current MOU agreement and officially challenged any renewal; “Let it be noted here – as an official stakeholder representative of pet food consumers – we are contesting the MOU as it is currently written and wish to collaborate with FDA on any renewal or future MOUs between FDA and AAFCO.”
But…FDA has not responded to our questions. The agency has ignored our multiple requests (through follow up emails) for input on the renewal of the current misguided agreement.
How you can help…
Send an email to FDA at AskCVM@fda.hhs.gov. Express to FDA your opinion on their current Memorandum of Understanding agreement with AAFCO. Example email:
Re: current MOU between FDA and AAFCO
I am contesting the current Memorandum of Understanding agreement between FDA and AAFCO. Due to this current MOU, pet owners are denied public access to pet food ingredient definitions and are denied a public voice in the definition process. This lack of public access denies myself and all pet owners basic rights as a US citizen – Freedom of Information rights. If another MOU is being considered with AAFCO, all pet food ingredient definitions and the definition process must become public information – free for pet owners to read and comment on.
Public Meeting with FDA
In mid-October 2018, we asked FDA for a public meeting with pet owners. The FDA has provided this opportunity to industry year after year, but the agency has never provided a public meeting to pet owners. We asked for the meeting, asked for the meeting to be recorded and filmed as a Facebook live event for all pet owners to see.
All meeting requests (original and multiple follow up emails) were ignored by FDA. The agency finally responded on December 14, 2018 with “We intend to get back to you early in the New Year with more information and potential dates.”
But…the FDA did not get back to us, we have no potential dates for a public meeting with FDA.
How you can help nudge FDA into meeting with pet owners…
Send an email to FDA at AskCVM@fda.hhs.gov asking the agency to arrange a public meeting with pet owners.
Freedom of Information Act (FOIA) requests
The Director of FDA’s Center for Veterinary Medicine (CVM) – Dr. Steven Solomon – gave a presentation to industry in September 2018. A FOIA request was sent in October 2018 asking for a copy of FDA’s presentation and speech. The reason this particular industry speech is so important (why we requested it) is Dr. Solomon told industry ‘pentobarbital in pet food is more of a problem than we thought‘.
Pet owners deserve to know EXACTLY how much of a problem pentobarbital in pet food is – and we deserve to know what FDA is doing to stop it.
Another FOIA request was sent to FDA in November of 2018, asking for all pet food complaints received by FDA since 1/1/09. This is a simple request actually, as FDA has a complete database of this information. But, in a follow up email to FDA asking when receipt of this request can be anticipated, the agency said this: “CVM processes requests on a first in first out basis, the estimated wait time for this request is about 18-24 months. Our oldest requests are from 2012 so yours is relatively new.”
It’s unacceptable that FDA can delay these Freedom of Information Act requests for up to 2 years. Unfortunately, there is little that we can do about this but wait.
Citizen Petition
A Citizen Petition is not a typical gather signatures petition. A Citizen Petition is the formal way to ask the FDA to change their opinion/change their actions on a particular issue. In October of 2016, our consumer association – Association for Truth in Pet Food – filed a Citizen Petition with FDA asking the agency to end policies that allow illegal ingredients in pet food with no warning or disclosure to the pet owner.
The FDA openly allows very inferior wastes into pet food – with no warning to the pet owner – through the agency’s Compliance Policies. These wastes include (but not limited to) “material from diseased animals or animals which have died otherwise than by slaughter“. Just one example (of many) of this type of material allowed in pet food was the millions of carcasses of drown livestock from Hurricane Florence and currently the millions of carcasses of drown livestock in Nebraska. These drowned animal carcasses will be/were rendered and sold to pet food with no warning to pet owners.
So, in October of 2016 we asked the FDA to stop this horrible practice of waste being disposed of in pet food by filing an official Citizen Petition with FDA. Seven months later after a meeting with FDA, we also asked FDA to clearly label pet foods either as feed or food (dog feed, cat feed or dog food, cat food) in an addendum to our Citizen Petition.
But…more than 2 years later (29 months after original Citizen Petition) and as serious as this issue is, FDA has not responded.
So…impatient with FDA’s lack of response, in December of 2018 we contacted the mediation department of FDA and asked for mediation assistance to get a resolve to this concerning pet food issue. We were told yesterday (4/1/19) FDA Center for Veterinary Medicine refused to participate in mediation. The mediation division of FDA shared Center for Veterinary Medicine responded to the mediation request with: “he did not think it would be helpful right now“.
How you can help…
Again, pet owners can email FDA at AskCVM@fda.hhs.gov. Example email:
Federal law declares material from diseased animals or animals which have died otherwise than by slaughter to be adulterated, yet FDA openly allows this adulterated material in pet food with no disclosure to pet owners purchasing pet food. Association for Truth in Pet Food has filed a Citizen Petition at FDA along with an addendum that I am asking for FDA to promptly respond to (see https://www.regulations.gov/docket?D=FDA-2016-P-3578). I do NOT want my pet to consume diseased animals or unslaughtered animals in their pet food and I deserve to be alerted/warned of the use of such material in any ingredient. Please address this concerning pet food issue very soon.
My thanks in advance to all pet owners that help in advocacy work. All of us and all our pets deserve far better than what we are getting from pet food. Speaking out together helps.
Wishing you and your pet(s) the best,
Susan Thixton
Pet Food Safety Advocate
Author Buyer Beware, Co-Author Dinner PAWsible
TruthaboutPetFood.com
Association for Truth in Pet Food
Become a member of our pet food consumer Association. Association for Truth in Pet Food is a a stakeholder organization representing the voice of pet food consumers at AAFCO and with FDA. Your membership helps representatives attend meetings and voice consumer concerns with regulatory authorities. Click Here to learn more.
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The 2019 List
Susan’s List of trusted pet foods. Click Here to learn more.
Cooking pet food made easy, Dinner PAWsible
Find Healthy Pet Foods in Your Area Click Here
Cannoliamo
April 2, 2019 at 3:09 pm
I’ve previously spoken with Jason Schmidt on this topic and he seems very receptive and pro-active with respect to consumer concerns. Maybe he could get you a conference call with some of the AAFCO Pet Food Committee members to present your concerns and suggestions.
Susan Thixton
April 2, 2019 at 3:12 pm
Association for Truth in Pet Food – our consumer association – is an advisor to AAFCO’s Pet Food Committee. We attend (2 of us including myself) every meeting. AAFCO is well aware of our concerns.
dalo488
April 5, 2019 at 11:11 pm
So exactly what is AAFCO doing about it?
Cannoliamo
April 2, 2019 at 3:18 pm
Kristen Hamilton was also helpful. She sent me the following AAFCO Policy Rules for proposing changes ….
COMMITTEE GUIDELINES
Committee Issues Committee chairs, members and investigators should use the following criteria to determine if an issue or a proposed/suggested change needs to be addressed by this Association. The criteria are applicable to all AAFCO investigators and the following committees: Collaborative Check Sample, Communications, Environmental Issues, Feed Labeling, Feed Manufacturing, Ingredient Definitions, Inspection and Sampling, Laboratory Methods and Services, Long Range Planning, Model Bill & Regulations, Pet Food, and States-Industry Relations. At this time, the other Associations committees do not address issues or changes impacted by these criteria. Committees listed should use the following criteria if presented with an issue or change as appropriate. Task forces and working groups are charged by the Board or the President.
Does the issue or change:
1. Provide protection for the consumer and the regulated industry.
2. Safeguard the health of humans or animals.
3. Provide a structure for orderly commerce.
An issue or proposed change should meet at least one of the three criteria to be considered by a committee/investigator. Committee chairs and their members determine whether an issue or proposed change meet the criteria. Committee chairs may seek guidance from the AAFCO Committee Coordinator (President-Elect) for issues that do not meet any of the above criteria prior to becoming a committee/investigator project.
All proposals submitted by a petitioner for issues or changes to be addressed by a committee/investigator should be presented with a justification stating:
1. The benefit of the proposal to humans and animals;
2. The benefit of the proposal to the consumer;
3. The benefit of the proposal to the regulated industry; and
4. The benefit of the proposal to the regulators.
An amendment to the AAFCO Model Bill and Regulations should only be made when it improves the clarity, design or intent of the statute or regulations, addresses a change in technology or enhances any of the three main criteria. Committee resources are not intended to address industry competitive based marketing concerns.
https://www.aafco.org/Portals/0/SiteContent/Publications/AAFCO_Procedures_Manual.pdf
Susan Thixton
April 2, 2019 at 3:25 pm
Perhaps you mean Kristen Green – who was the former chair of the AAFCO Pet Food Committee. The best I can tell you from personal experience is on the surface AAFCO appears to want to cooperate with pet owners. Some are very willing to listen, some are not (Kristen Green was never one to do that, in fact she outright refused to answer any more of my email questions). We keep trying however. We have another issue into AAFCO for consideration that was not discussed above and we are waiting for their decision.
bknuth96
April 2, 2019 at 3:27 pm
I sent three emails, I would like to share this to president trump too, so I will try.
bknuth96
April 2, 2019 at 3:31 pm
I sent this article to the president, I pray he will do something. Thanks for all you do. Beth Knuth
Lynnette Lorch
April 5, 2019 at 6:44 pm
How do you contact the president?
Susan Thixton
April 5, 2019 at 6:47 pm
You can use https://www.whitehouse.gov/ – I’m probably on a government watch list I’ve emailed the White House so many times over many years. 🙂
Cannoliamo
April 2, 2019 at 3:37 pm
I had the same problem in Kentucky …. this is the person I spoke with (I’m not even sure she’s on the Pet Food Committee, but she agreed with many of my concerns with respect to protein-sourced allergens that are in many of the pet foods) …..
Kristen Hamilton
Ag Program Specialist
Idaho State Department of Agriculture
1180 Washington St North
Twin Falls, ID 83301
United States
(208) 293-9744 (Phone)
kristen.hamilton@isda.idaho.gov
I have had no luck whatsoever in getting any kind of response from CVM and have decided it’s not an open channel for change. Hopefully you have better luck than I have had. ?
Tom Kirby
April 2, 2019 at 3:44 pm
Emails sent. Thanks, Susan!
~Pet Owner~
April 4, 2019 at 12:49 am
For PF enthusiasts sending an email to the ever unpopular, elusive, and mysterious FDA – in order to request ingredient definitions should become public information for free, be sure to include this timely link. It was one of the top GOOGLE News stories April 3rd, 2019, reporting on how pet owners are feeding whole food! Note that on their front page, GOOGLE seldom publishes much in the way of pet welfare (just recalls).
https://wtop.com/animals-pets/2019/04/forget-kibbles-us-sales-of-fresh-pet-food-are-soaring/slide/1/
Point being that because owners can NOT decipher what really goes into traditional commercial PF (because they don’t understand the ingredient meanings), they’ve given up. And would rather feed whole food, even spending more money. Meat Meal, Corn Gluten, Beet Pulp (as examples) are no longer doing it for informed consumers, in terms of building confidence! Therefore if a PROCESS was to be devised between the definitions committee and the Association for Truth in Pet Food (PF consumer stakeholders) then the PF marketplace could be re-stabilized eventually. I would add, that the internet provides so much information today, that manufacturers can no longer hide behind their euphemisms and pretty pictures. The best way to combat growing consumer cynicism is to work in good faith with them, meaning with those who represent transparency and forthright communication. If Industry has have nothing to hide (as they claim) this should be a mutually beneficial partnership. Also ask in your letter, wouldn’t Industry be interested in reclaiming their share of the market?
Just an observation of course, but I wouldn’t hold my breath waiting for any response. Interestingly ONLY the behavior of the PF consumer has changed during the past decade, giving opportunity for a rise in innovation and niche products. But sadly NOT the traditional (canned/kibble) industry which continues to act as they always have. Meaning, in blind faith that the average pet owner won’t notice.
Wrong!
Deb Mogan
April 6, 2019 at 7:29 am
It should also be noted for everyone to contact their representatives in congress (the House and Senate) as well including state representatives. We need to be relentless. Contact local media and ask why they aren’t covering this information.
Lynnette Lorch
April 6, 2019 at 12:48 pm
Thank you Susan. This was an incredibly informative article. I wish we could do something like protest the FDA/AAFCO with picketing and have the pres there. I don’t think enough people know about this. I post many of your articles on my Facebook page. It’s so disheartening that most vets are right along side of FDA/AAFCO.