Our Presentation to FDA – Truth about Pet Food
On February 9, 2023 the FDA hosted a virtual public meeting regarding the pet food/animal feed ingredient approval process. FDA allowed stakeholders to present opinions. We surveyed pet owners, and included your responses in our presentation to the Agency. Our slides and script from the presentation are below.
The FDA asked “What steps can FDA take to improve stakeholder understanding of FDA’s engagement in the AAFCO’s feed ingredient definition process and better communicate this information with the public?”
First of all, we believe it is significant for FDA to understand that the ‘public’ is a stakeholder of feed ingredients. The phrasing of your question – ‘improve stakeholder understanding’, ‘communicate with the public’ – examples a problem. The public – pet owners – are just as important of a stakeholder as industry.
Rephrasing your question…
“What steps can FDA take to improve understanding and communication with all stakeholders of FDA engagement in AAFCO’s feed ingredient definition process?”
In our opinion, understanding and communication of FDA’s role in AAFCO’s feed ingredient definition process can be improved if the ‘process’ becomes a public process.
How can stakeholders understand the process when much of / most of the process occurs behind closed doors/occurs behind a paywall?
How can communication improve with stakeholders when ‘some’ stakeholders are limited or prevented to provide input?
At AAFCO discretion only select stakeholders are allowed to participate.
In March of 2019, the stakeholder organizations Association for Truth in Pet Food and Next Generation Pet Food Manufacturers Association submitted to AAFCO proposed animal origin ingredient names and definitions. These proposed ingredients were submitted to provide clarity to pet owners – allowing them opportunity to understand what is in their pet’s food. And the proposed ingredients were submitted to provide manufacturers the ability to distinguish their ingredients. As example, we proposed ingredient names and definitions of Whole Poultry, Poultry Meat, Poultry Parts, and Poultry Frames to replace the existing catch all ingredient ‘Poultry’.
But…Both stakeholder organizations were denied the opportunity to participate in the working group, we were never provided with any updates, basically our request to AAFCO was completely ignored.
And then there is the potential conflict of interest influence of some stakeholders that submit ingredients for approval.
It is a concern that the same attorney is representing the organization that approves new ingredients and an organization that submits ingredients for approval.
If FDA wishes to improve understanding and communication with stakeholders – then FDA’s engagement in the AAFCO feed ingredient definition process needs to assure a level playing field.
We surveyed pet owners asking them how much they understand about how new pet food ingredients are approved and defined. We provided a range to response options, #1 being the pet owner knowing nothing about the ingredient approval process, to #5 the pet owner completely understanding the process. We received 796 responses.
The majority of pet owners responded they know nothing, with only 2 responses of they completely understand.
We also asked pet owners if they feel they are allowed to provide input on proposed pet food ingredients? Overwhelmingly pet owners did not believe they have a voice in the process.
Another question FDA asked was ‘What changes to FDA’s role in AAFCO’s feed ingredient definition process would be helpful to stakeholders and why?’.
Besides improved transparency, we believe the feed ingredient definition process needs to include Ingredient Standards.
As to why? After the 2007 Pet Food Recall – the deadliest pet food recall in history – Congress required FDA to establish by regulation ingredient standards and definitions. Pet owners were promised this update by Congress. But…FDA did not complete this.
FDA asked “If FDA made a list of AAFCO feed ingredient definition requests publicly available, where would stakeholders prefer to find such a list and what information would stakeholders like to see with such a list?” We would like to see that information on the Animal Food & Feeds pages for Animal Food, For Consumers and the For Industry page as well. The information we would like to see is ingredient name, definition and standard.
We asked pet owner opinion if all pending pet food ingredients should not only be available on the FDA website but also provide opportunity for public comment. Significantly pet owners responded with yes – they wish to view and be provided the opportunity to comment on pending ingredients.
We asked pet owners if all evidence to nutritional adequacy and safety should be public information prior to ingredient approval?
Overwhelmingly pet owners said Yes.
And we asked pet owners who should approve and define new pet food ingredients, AAFCO w/FDA, FDA only, or a panel of FDA, AAFCO, veterinarians and independent scientists.
The largest majority of pet owners wanted to see a panel of experts to approve and define pet food ingredients.
End of our presentation.
We don’t know if the FDA will listen to our input..here’s hoping they will.
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.
What’s in Your Pet’s Food?
Is your dog or cat eating risk ingredients? Chinese imports? Petsumer Report tells the ‘rest of the story’ on over 5,000 cat foods, dog foods, and pet treats. 30 Day Satisfaction Guarantee. Click Here to preview Petsumer Report. www.PetsumerReport.com
Find Healthy Pet Foods in Your Area Click Here
The 2023 List
Susan’s List of trusted pet foods. Click Here to learn more.
