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Pet Food Regulations

We Did Not Find The Requested Records

What does FDA say when you ask for the science to prove illegal pet food ingredients are safe? “We did not find the requested records”. FDA could not provide science to prove illegal waste ingredients commonly used in pet food are safe.

What does FDA say when you ask for the science to prove illegal pet food ingredients are safe? “We did not find the requested records”. FDA could not provide science to prove illegal waste ingredients commonly used in pet food are safe.

On dozens of pages on the FDA website, the agency tells the public they are “science-based”. The FDA is a science-based regulatory agency.”

Under ‘What We Do‘: “helping the public get the accurate, science-based information they need”.
From ‘Science and Research – Food‘: “ensure that regulatory decisions about foods are science-based and transparent“.
Blog Post from FDA’s Deputy Commissioner for Foods and Veterinary Medicine: “Our Goal in Enforcing Food Safety: A Rapid, Science-Based Response”.

Touting to be a science-based agency, one could assume that FDA has science after science after science to validate their actions. One would be wrong to assume that.

Law says pet food containing the tiniest piece of diseased animal tissue or material sourced from dead/non-slaughtered animal carcasses is adulterated.

“Adulterated Food: (5) if it is, in whole or in part, the product of a diseased animal or of an animal which has died otherwise than by slaughter”.
FDA openly ignores that law; openly allows the pet food industry to source ingredients from diseased animal tissues and dead/non slaughtered animal carcasses.

“Pet food consisting of material from diseased animals or animals which have died otherwise than by slaughter, which is in violation of 402(a)(5) will not ordinarily be actionable.”

Being ‘science-based’ I asked FDA for the science to prove pet food consisting of diseased or non-slaughtered/dead animals are safe for pets to consume….

Freedom of Information Act Request 2016-4226:

FDA CVM has Compliance Policy relating to pet food and rendered ingredients. CPG 675.400 Rendered Animal Feed Ingredients and CPG 690.300 Canned Pet Food are the Compliance Policies that I am requesting data on.

I am requesting the CVM data that these Compliance Policies were based on – specifically the data that proves rendered diseased or non-slaughtered animals is not a risk to pets. It is assumed CVM has science to prove diseased and/or non-slaughtered are of no risk to pets. I am requesting the science CVM has on this issue (proof this material is of no risk to pets).

FDA response: “After searching our files, we did not find the requested records.”

FDAShowtheScience
The FDA also tells the public regarding the agency allowing pet food/animal feed to violate law they don’t believe Congress intended law to hold food for animals to the same standard as food for humans; “the Center for Veterinary Medicine does not believe that Congress intended the Act to preclude application of different standards to human and animal foods under Section 402. Different standards have historically existed for human and animal food concerned with aesthetics.”
Addition to FOIA Request 2016-4226:
Also CPG 675.400 states “In addition, the Center for Veterinary Medicine does not believe that Congress intended the Act to preclude application of different standards to human and animal foods under Section 402.” I am requesting the data that CVM bases their “does not believe that Congress intended the Act to preclude…animal food” on. Specifically I am requesting evidence CVM was provided by Congress stating FD&C Act excludes animal food.

FDA response: “After searching our files, we did not find the requested records.”
FDACongress2

 

FDA repeatedly tells the public the agency is “science-based”…BUT…FDA has not one tiny bit of science to prove the safety of diseased/dead animal carcass pet food ingredients. Zippo.

FDA tells the public Congress did not intend for the Federal Food Drug and Cosmetic Act to protect animals, but the agency could not provide any documentation to prove this.

Perhaps members of Congress should be informed that FDA is using them as an excuse.

Example letter to send to your members of Congress…

Dear______________

The FDA is using Congress as excuse to allow pet food to violate federal law. I would like to know if this is acceptable to you.

Congress defined food (in the Federal Food Drug and Cosmetic Act) as: “(f) The term “food” means (1) articles used for food or drink for man or other animals, (2) chewing gum, and (3) articles used for components of any such article.”

And Congress defined an adulterated (illegal) food (in the Federal Food Drug and Cosmetic Act) as (in part): “(5) if it is, in whole or in part, the product of a diseased animal or of an animal which has died otherwise than by slaughter”.

The above definition of adulterated food is not enforced by FDA in pet foods. Through FDA Compliance Policies the agency tells industry “Pet food consisting of material from diseased animals or animals which have died otherwise than by slaughter, which is in violation of 402(a)(5) will not ordinarily be actionable.”

The FDA tells the public the agency is “science-based”, however a request was made (via FOIA) asking FDA for the science to prove ‘material from diseased animals or animal which have died otherwise them by slaughter’ is safe for pet consumption; the agency responded with “After searching our files, we did not find the requested records.”

The FDA tells the public the agency “does not believe that Congress intended the Act to preclude application of different standards to human and animal foods“. Through FOIA request, the agency could not provide any evidence Congress intended animal food/pet food to be held to a different standard than human food; the same response was received. “After searching our files, we did not find the requested records.”

My questions to you are…did you as my Representative in Congress give FDA authority to pick and choose which laws to enforce? Do you agree with FDA or do you disagree with FDA; should pet food be allowed to include ‘material from diseased animals or animals which have died otherwise them by slaughter?

I would appreciate your response to the above questions.

Thank you –

 

To find your members of Congress visit: https://www.govtrack.us/congress/members

 

This is wrong FDA. #ShowUsTheScience or #EnforceTheLaw

 

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

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14 Comments

14 Comments

  1. Joan Johnston

    July 22, 2016 at 2:00 pm

    This is really weird. Usually someone is getting paid under the counter by a company who benefits from such misrepresentation.

  2. Sage

    July 22, 2016 at 2:52 pm

    Hi Susan

    Can you use FOIA / Freedom of Information Act to demand of the FDA that they produce these records (or prove they don’t exist)?

    • Susan Thixton

      July 22, 2016 at 2:53 pm

      I did. Through FOIA request they could not provide any documents.

  3. Mary Meyer Johnson

    July 22, 2016 at 3:15 pm

    I sent Susan’s email to my Texas representatives and will post their responses when received.

    • Susan Thixton

      July 22, 2016 at 3:17 pm

      Thank you Mary!

    • Trouble

      August 5, 2016 at 5:07 am

      I’m going to look up my state’s representatives via the link Susan posted, and contact them as well. But quick question, for Susan or for anyone else who can answer this I suppose? In the example letter Susan posted in this article, I noticed that some parts have links to different pieces of information/facts/data, etc on Congress’s .gov site… am I to include those links in the letter as well? Or are the links in the example letter for our reference only? Just wanted clarification on that first, before I contact my state’s reps.

      I’d most likely use the example letter that Susan posted above… It’s certainly a lot better than anything I could say to my state’s reps, as far as it looking somewhat formal/professional, giving facts and information, rather than just expressing feelings about how the FDA is doing things (I imagine that most government reps are more likely to take some sort of action, make change, or listen to a factual, information-based letter to them, as opposed to someone expressing their ‘feelings’ about the topic.. lol).

      Anyways, thanks in advance to any responses I get to my question. 🙂 I’m looking forward to contacting my reps about this, and seeing if I get a response back (hopefully I do).

      • Susan Thixton

        August 5, 2016 at 9:07 am

        Either way would work – you can provide the all the links if you like.

  4. Reader

    July 22, 2016 at 3:37 pm

    I don’t understand. If the FDA can’t supply facts (or evidence) to prove the safety of commercial PF (wet and dry), then why do they have all the facts they need to disqualify the use of raw PF?

  5. Dianne & pets

    July 22, 2016 at 3:39 pm

    I expect that in Canada, we could reword it and send it to the minister of trade, whoever looks after agricultural products and Canadian Border Inspection services. Can anyone think of anyone else?

    • Jane Democracy

      July 23, 2016 at 12:37 am

      Just so you know… there is no pet food regulation in Canada, the only time the CFIA gets involved is if the product is being exported.

  6. Cheryl Bond

    July 22, 2016 at 6:11 pm

    Once again, the FDA PROVES what deceitful little liars they are! Oh, how convenient that they “cannot find” the information. We all know thats bull****! Even if it were true, it would prove how incompetent they are! What! a Gov’t regulatory agency at the highest level, “just suddenly incompetently loses important legal documents” REALLY!?! FDA! I guess that’s the new normal in gov’t…files just can “disappear” and no-one is held accountable!

    Do they think we all agree really that stupid?! I guess they really believe (or know) that they can get away with ANYTHING they damn well want to! ?

    • Trouble

      August 5, 2016 at 5:26 am

      Hey now… Maybe they’re not lying. Maybe they’re being completely honest when they say, “We did not find the requested records.”

      As soon as I started reading this article, the first question that came to my mind was, “Is the FDA stating, in a vague, roundabout sort of way, that…..these requested records can’t be found because they don’t exist?” That’s how I interpret the statement, “We did not find the requested records.”

      I guess I have to ask Susan: Has the FDA ever told you this before, when you’ve requested any sort of information (about anything in general, not just this particular piece of information)? Have you ever received the response that they couldn’t find the requested records? If you did… what was it that they said in the past that they couldn’t find, and did they ever eventually find that information for you, or explain why they couldn’t find it? If you haven’t ever received this response from the FDA before, then…. What do you think it means? Like I said, I’m inclined to think it means, “The requested records cannot be found because they do not exist.”

      If the records DO actually exist, I find it hard to believe that the FDA would be so obvious about their incompetency, or so obvious about their lack of organizational skills and record-keeping. It just seems unlikely that they would want to draw attention to their crappy record-keeping skills (especially with almost everything being digital/electronic records nowadays…lol. I would think that the FDA would have both a digital/electronic copy of their records, as well as a physical, paper copy of those records, just in case something should happen. It could be devastating for them if something happened and they lost important documents, records, data, information, etc… So I would think they keep their records in both formats – digital and physical/paper.

      To say they “can’t find the requested record,” doesn’t really indicate to me that they can’t find it as in they’ve lost it… But more so that they can’t find a record that simply doesn’t exist. I’m very curious to know if the FDA has ever used this particular excuse before when Susan has requested information from them about anything… Especially if it’s information they don’t necessarily want her (or the public) to have or know. Buuuut, you’d think that the FDA would want to show their information, their “science-based” data that proves that these ingredients that are used are totally safe and fine for our pets to eat. So if the records do exist (which I don’t think they do, obviously), I would think the FDA would be jumping at the chance to show those records off, basically to…prove Susan wrong in a way. In a very childish manner, it would be similar to, “Nanananabooboo, I’m right (the FDA), you’re wrong! (Susan and all of the well-informed pet owners, such as ourselves, lol.) This (the records) even proves that you’re all wrong, and we’re right!!” *FDA blows raspberries at us all* Because… that’s just how I imagine them all being. Childish and immature, irresponsible people, blowing raspberries at us. Lol.

      Anywho… I’m interested to know Susan’s thoughts on my personal take on the FDA’s response to her request for the information….And I’m curious to know if there’s anything that can be done to…sort of force the FDA’s hand as far as forcing them to find these records and show them, or forcing them to prove that the records either don’t exist, or absolutely, without a doubt, cannot be found despite all efforts to locate them – and at that point it’s the same as saying they don’t exist at all, lol.

      • Susan Thixton

        August 5, 2016 at 9:09 am

        That is exactly how I took the response too – the records don’t exist. Which poses a serious problem. FDA states they are science based, that their actions are based on scientific information. With no records, this proves they are acting on opinion that this material is safe. No science.

  7. Linda Horn

    July 23, 2016 at 12:19 am

    FWIW, I wrote an actual paper letter and mailed it to my Congressman. It will be interesting to see what, if any, response I get. BTW, I sent a paper letter, because I’ve heard politicians are more impressed with an actual letter, since it requires more time and effort (and money!) to send than an email.

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