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Pet Food Regulations

What is AAFCO?

Here’s some official and some unofficial information to help Pet Owners understand what AAFCO is and isn’t.

AAFCO stands for American Association of Feed Control Officials.  From the 2011 AAFCO Official Publication “The purpose of the corporation shall be to establish and maintain an Association through which officials of any state, dominion, federal or other governmental agency on the North American Continent, and employees thereof charged with a responsibility in enforcing the laws regulating the production, labeling, distribution, or sale of animal feeds or livestock remedies may unite to explore the problems encountered in administering such laws, to develop just and equitable standards, definitions and policies to be followed in enforcing such laws, to promote uniformity in such laws, regulations and enforcement policies, and to cooperate with members of the industry producing such products in order to promote the effectiveness and usefulness of such products.”

AAFCO members are representatives from State Department of Agriculture.

AAFCO is not an enforcement agency; but the Department of Agriculture representatives who are AAFCO members are enforcement.  State Department of Agriculture representatives can test pet products at will and have the authority to remove pet products from store shelves.  AAFCO members develop ingredient definitions and labeling regulations, then individual states accept and enforce these definitions and labeling regulations or they don’t accept and enforce these definitions and labeling regulations depending on the state.  No two states are identical with their pet food/animal food regulations.  Are you confused yet?

Kentucky AAFCO Member Meagan Davis provided the following example of differences in states…with regards to pet food labeling…

In Kentucky, labeling means all labels and other written, printed or graphic matter including radio and television.  In New Mexico labeling does NOT include TV and radio.  So in New Mexico a pet food/treat manufacturer could air a radio or TV commercial and make claims that would not be allowed in Kentucky.

Some states license all pet products sold within the state boundaries, some states review all pet products sold within state boundaries.  Those that license don’t review labels.  From what I saw, those that review labels take this job very seriously.

Some states include a travel budget for their Department of Agriculture employees, some states don’t.  As example, 2010 AAFCO President Kent Kitadae – from California – was forced to take vacation time and pay his own expenses to travel to this meeting in Florida.

Department of Agriculture employees that accept positions of leadership in AAFCO or accept board member positions in AAFCO are not paid for their work by AAFCO; yes they receive their state salary but no additional salary is received for work done for AAFCO.  The only employee AAFCO has is Sharon Krebs assistant secretary-treasurer.

Within AAFCO are Officers, Board of Directors, and various Committees.   Committees are…
Collaborative Check Sample Committee (provide laboratory quality control tools)
Current Issues and Outreach Committee (disseminate information to AAFCO membership, industry and interested parties)
Education and Training Committee (seminars)
Enforcement Issues Committee (all issues of enforcement policy)
Feed and Feed Ingredient Manufacturing (define processes to prevent, eliminate or minimize contaminants)
Feed Labeling Committee (feed and pet food labeling)
Ingredient Definitions Committee (development and revision of ingredients definitions)
Inspection and Sampling Committee (inspection and sampling procedures)
Laboratory Methods and Services Committee (feed control laboratory)
Model Legislation and Regulation Committee (feed and pet food regulations)
Pet Food Committee (pet food regulations)
Strategic Affairs Committee (AAFCO by-laws)

Committees develop new regulations or definitions or testing protocol, the new regulation or definition is proposed at meetings, and committee members vote as to what stays and what goes.  It’s all quite official…“all in favor say I…all against?”  Before a new definition or regulation becomes official, discussion is heard from committee members, committee advisors, and anyone in attendance (which I didn’t understand until after several committee meetings).

Advisors to each committee are mostly from industry or trade associations.  There was no consumer advocate or holistic veterinary representative on any advisory committee; only members of industry or trade associations.  While these advisors are not allowed to vote, you can safely assume they do hold a certain amount of persuasion with committee members.

But not always.  As example…
During the Pet Food Committee meeting, the discussion of kcal (calorie) information on pet food labels was discussed.  The question of a time frame allowed to manufacturers was asked – how long would manufacturers have to implement the calorie information on pet food labels.  Nancy Cook of the Pet Food Institute (the lobby organization representing Big Pet Food) didn’t like the proposed six months for new products and 18 months for existing products implementation requirements.  In fact, she whined and moaned and went on and on and on (and on and on) about how impossible this was for manufacturers.  AAFCO members asked her how long she wanted…she wanted at least five years for both new products and existing products!  Five years to add one tiny line to the pet food label; five years to add calorie information that would be valuable information to consumers.  I was screaming inside (I wasn’t aware that I could have spoken up during this session – or believe me I would have!).

Jan Jarmon, AAFCO Representative from New Mexico didn’t agree with the whining from PFI’s Nancy Cook; she wasn’t swayed by the trade group.

Nothing was settled.  Calorie information will be required information on pet food labels in the future (it is only optional now) but it will take more time to implement into regulation.

AAFCO has historically been responsible for establishing the nutrient levels in pet foods.  However at this meeting there was some discussion of this practice being eliminated and nutrient levels for pet food/animal food would follow NRC (National Research Council) guidelines.

Some AAFCO Representatives showed they have the interest of industry in priority.  Others showed they really care about performing their jobs to assure the safety of pet food/animal food.  A couple showed real kindness and human concern.

After my interview with AAFCO President Chad Linton from West Virginia and Director Robert Waltz from Indiana (full interview will be posted soon), I headed to the ‘girls room’ before getting some lunch.  While washing my hands, I heard someone in a stall say “Oh no!…OH NO!”  A moment later a young pregnant woman came out of the stall; holding her belly.  I asked if she was ok, she said she was bleeding.  I walked her out of the restroom and tried to get her to sit down while I fetched her business associate – she insisted on going to get him herself.  I followed.  When we found him in a nearby restaurant, the quick decision was made that he would drive her to the hospital.  She was in tears by this point.

As the business associate of this young woman gathered everything together and ran to get the car, I slowly walked with the tearful mom to the front of the hotel.  As we were walking, Chad Linton and Robert Waltz (fresh from our talk) noticed us.  Chad mouthed to me (no words spoken so not to alarm the young mom – just moved his lips) ‘Is everything ok?’.  I mouthed back ‘No’.  I sat the young mom down, fussed at her a bit (I’m a fully trained mom – couldn’t help myself) to remain calm for her baby, and learned she was from New York, 7 1/2 months pregnant, this was her first child.  I tried my best to reassure her and keep her calm.  Within a few minutes, her business associate had pulled the car to the front and off they went to the hospital.

As I turned back into the hotel I noticed that both Chad and Robert had stayed within a close distance of the young mom and myself; just in case we needed help.  They weren’t involved, but they made themselves available just in case.  Hats off to you gentlemen!  You did good.  (No, I don’t know what happened to the young mom.)

The point of sharing this story with you is that from my experiences at the AAFCO meetings, I believe many of these folks are good people with good intentions.  AAFCO has people just like us along with wolves in sheep’s clothing.  Our task will be to figure out who is who.

 

Wishing you and your pet(s) the best,

Susan Thixton
Pet Food Safety Advocate
Author, Buyer Beware
Co-Author Dinner PAWsible
TruthaboutPetFood.com
PetsumerReport.com

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