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.
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,
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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