Questions We’ve Sent To FDA Over The Past 6 Months – Truth about Pet Food

The FDA openly meets with, gives presentations to, and answers questions of pet food industry stakeholders. As example, in January 2022 FDA’s Dr. David Edwards gave a presentation to industry at the American Feed Industry Association Pet Food Conference.

The largest stakeholder of pet food is consumers. We are an official stakeholder organization – Association for Truth in Pet Food, meeting the same legal requirements of any other stakeholder organization. But, consumer stakeholders are NOT provided with the same FDA attention. In fact, we are mostly ignored.

Advocating for pet food consumers, below is what we’ve asked of FDA over the past six months:

Potential Label Violations

In early December 2021 we reported to FDA a potential pet food label violation by Mars Petcare’s Cesar dog food and asked the agency to respond if they will investigate or will not investigate the violation. This Cesar dog food makes the claim “Human Grade” on the label. Pet food regulations – of which FDA participated in developing – clearly state “the use of the term ‘human grade’ is only acceptable in reference to the product as a whole.” In order to use the claim Human Grade, the pet food must use 100% human grade ingredients and supplements and must be manufactured in a licensed human food facility. We asked Mars Petcare if the Cesar dog food was manufactured in a human food facility, they did not respond. Thus we asked FDA to investigate the label claim as it could easily mislead pet owners.

We sent a follow up email to FDA in mid-February 2022 and another follow up email was sent in late-February 2022.

The FDA has not responded.

Warning Notices on Labels

In early February 2022 we asked the FDA if they would require warning labels on feed grade pet foods that alert consumer to use of illegal waste ingredients. This request was following an apparent marketing stunt by celebrity chef Alton Brown eating his dog’s Hill’s Science Diet pet food.

We sent a follow up email in late February 2022 and again in May 2022.

The FDA has not responded.

Inconsistencies in Regulating

In late March 2022 we asked Dr. Steven Solomon, Director FDA Center for Veterinary Medicine (CVM) about inconsistencies in regulating pet food. FDA had just issued a press release of a consent decree the agency had issued against Bravo Packing (not Bravo Pet Food). The consent decree demanded this pet food manufacturer “come into compliance with the Federal Food, Drug, and Cosmetic Act”. We asked FDA how the agency can take this stance with one pet food manufacturer while at the same time allowing other pet food manufacturers to violate the very same federal laws with no warning or disclosure to pet owners.

We also asked how the consent decree addressed how Bravo Packing “continued to operate under insanitary conditions” while the FDA allowed Mars Petcare to continue to operate (with no Warning Letter or consent decree) under similar conditions. We reminded FDA of their 2017 inspection report of the Mars Petcare facility finding “Failure to take effective measure to exclude pests from your plant and protect against contamination of animal food by pests”.

We asked Dr. Solomon for FDA to explain to pet owners why the agency continues to allow diseased animals and animals that have died other than by slaughter in pet food with no disclosure on the label in order for consumers to make informed purchasing decisions. We requested FDA to publicly provide the science they based their belief this illegal material is safe in pet food. We also requested a public discussion on the issue, for consumers to provide FDA their input. As FDA regularly meets with industry, we requested the same discussion opportunity for pet owners. We also requested an explanation to FDA rationale of when and why law is enforced in some instances or not enforced in other instances.

On March 29, 2022 the FDA confirmed our questions were delivered to Dr. Steven Solomon.

On May 23, 2022 we sent a follow up email.

To date, Dr. Solomon has not responded.

Information FDA Provided to Congress

In early April 2022 we asked FDA a simple question regarding information they provided to Congress. When FDA asked the 2022 Congress for a ‘raise’ they provided elected officials with a “Justification Estimate”. In this document the FDA stated they “ranked the animal food inventory by risk (high and non-high) based on common risk criteria”.

We asked for a copy of that animal food risk ranking.

In mid-April we sent a follow up email. In mid-May we sent another follow up email.

To date, the FDA has not provided the requested information.

Establish Meetings with Pet Owners

In mid-April 2022 we asked the FDA to begin to establish quarterly phone conference meetings with consumers and consumer representatives. For years the FDA has met quarterly with industry representatives, we asked for the same time with pet owners, pet store owners, and veterinarians. We asked when we could schedule the first meeting.

A follow up email was sent in mid-May.

To date, the FDA has not scheduled our first meeting.

Avian Influenza

In mid-May 2022 we asked the FDA if the agency has given approval for rendered avian influenza poultry to be used in pet food. We also asked the agency if they believe pet food labels should disclose this information to consumers.

A follow up email was sent in late May.

The FDA has not responded.

Clarification on Label Claims

And on June 1, 2022 we asked FDA about quality of ingredient claims on pet food labels. We asked: “If a pet food claims to use “high quality” ingredients, yet they are using feed grade ingredients – would the product be mislabeled? Can FDA CVM provide clarification?”

We await FDA’s response.

It is unacceptable for FDA to ignore our questions, ignore our meeting requests, ignore our pet food concerns. Pet food consumers are the largest and most significant stakeholder, just like industry – we have an official stakeholder organization…we SHOULD NOT be ignored.

We will continue to ask FDA new questions and remind them of questions they have not responded to. And if FDA continues to ignore us, we will take necessary steps to get the answers and the meetings we deserve.

Wishing you and your pet the best –

Susan Thixton
Pet Food Safety Advocate
TruthaboutPetFood.com
Association for Truth in Pet Food

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