You suck FDA

Half-baked new FDA animal food law leaves pets at risk: PART II

One messed up animal food law

The much-anticipated, but highly disappointing, proposed rule Current Good Manufacturing Practice and Hazard Analysis and Risk-Based Preventive Controls for Food for Animals meant to require livestock feed and pet food manufacturers to adopt food safety practices similar to those in the proposed rule for human food, falls miserably of protecting pets. The similarity quickly evaporates once you realize the Food and Drug Administration’s (FDA) definition of food for animals is vastly different from food for humans. Oceans apart.

Close, but no cigar

In Part I of my analysis of the proposed rule I explained how the FDA neatly cherry picked through the Federal Food, Drug & Cosmetic Act (FD&C Act) to continue to allow adulterated ingredients in pet food and animal feed. The Agency rationalizes their allowance of adulterated ingredients with this faulty logic:

…some facilities “waste” from human food production, such as by-products that may not be edible for humans, or lack nutritional value for humans, are used or sold for animal food. Many species of animals have different digestive systems and nutritional requirements than humans, thus allowing for this use.

The Agency is proposing a clear distinction between food for humans and food for animals. The FD&C Act, this country’s basic food and drug law, defines food as:

articles used for food or drink for man or other animals…and articles used for components of any such article

And it makes no distinction for whom the food is intended.

The Act clearly defines food as:

(f) The term “food” means (1) articles used for food or drink for man or other animals.

However, the proposed rule for animal food the Agency turned the definition of food into a whole new level of sick. What they believe is appropriate, healthy and safe for humans is vastly different from what they believe is nutritious and wholesome for animals.

Yummy ingredients, such as, “human food waste,” food “unfit for human-consumption” and “lacking in nutritional value,” are considered acceptable in food for animals.

In recreating the definition of food the Agency they made the words “food” and “waste” interchangeable when it applied to animal feed and pet food.

Follow the word maze in the proposed rule and see how they made mincemeat out of it:

“Food” used in proposed part 117 (see the document for the proposed rule for preventive controls for human food (78 FR 3646)) would be read to include “animal food” when the facility is applying proposed part 117 to the animal food. For example, human food waste that is used for animal food would be treated as “food” for the purposes of its animal food use and as waste for the purposes of its role in human food production. The Agency tentatively concludes that this will provide facilities the flexibility to streamline their compliance efforts, while also ensuring human and animal food safety.

So, lemme see: Waste is food for animals, but and waste is actually waste in food for humans.

Get it?

It’s a simple equation:

WASTE = FOOD in animal food

WASTE = WASTE in human food

Let ’em have it; comment on the proposed rule

The proposed rule Current Good Manufacturing Practice and Hazard Analysis and Risk-Based Preventive Controls for Food for Animals is published in the Federal Register so you can review it and submit comments.

Don’t miss the chance to tell them what you think of their rules; you have 120 days from the date it was published in the Federal Register to submit your comments.

I’m still working on mine – it’s gonna be a doozie!

For information on the proposed rule, read:

Stay tuned for The shocking truth about the new animal food rule: PART III, tomorrow.

 

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Mollie Morrissette

Mollie Morrissette, author of Poisoned Pets, is an animal food safety expert and advisor to AAFCO. Help support her work by making a donation today.

Comments (6) Write a comment

  1. Pingback: Glaring Ommissions in Proposed Rule for Animal Food Leave Pets at Risk: PART I - Poisoned Pets

  2. When will part 3 be posted? Sharing parts 1 and 2 this morning, along with Susan’s post about the proposed rules.

    Reply

    • Soon! Soon! I have been given some feedback on how to make the 400+ page document accessible and understandable to the lay person – so I am entirely revising my approach. It may take a day or so. Which means scrapping a allot of work. Thanks for your interest Angel Paw!

      Reply

  3. Thank you Mollie for “digesting” and then dutifully “dissecting” for the “average reader” this otherwise beauracratic mumbo-jumbo. My take away is that it was done to fulfill a requirement being the result of the 2007 Recall, definitely favoring the PFI. I do not feel the FDA has a real understanding of the consumer’s standpoint, but has been heavily influenced by the Industry, and perhaps (deceptively so) “reassured” by the PFI that all is not as bad, as has been assumed. Therefore, allowing the FDA to make these “watered” down “should’a” type recommendations, instead of making statements of requirements and consequences for failure!
    Along with many followers I believe the Industry won’t change (no matter what the FDA does) until everyone realizes that smart (former) consumers just make their own food for peace of mind. I don’t have cats, so for me, a home made canine diet is a no-brainer. I hope to extend my older dog’s life as long as possible, without taxing his urinary and renal system with overly (deficient) processed kibble. Though I give a special “call out” to Nature’s Logic and Fresh Fetch for doing it right!!!!
    Thank you Mollie for hours and hours and hours of excruciatingly hard work, especially interpreting this current document.

    Reply

    • Thanks, Kelley! I try. And thanks to you for your help and feedback. Because of your advice, I am scrapping my summary article and revising it entirely. I hope that makes you happy. LOL.

      I make my own cat food (nat) and it is all raw, which creeps people out, but I feel it is best. The meat I buy comes from a farm close to me and I know the owner. I buy it at the Farmers Market in great quantities.

      It is incredibly difficult as a vegan to buy meat and eggs for my cats. If cats weren’t obligate carnivores I would have another option, but I don’t. So the best I can do is make sure that the animals used for my cat’s consumption did not live tortured, miserable lives. If I had a farm, I would raise my own chickens.

      On the other hand, I’d probably never be able to kill them. I’d have them all named and tucked up in eiderdown beds…someday I’ll have to write about my rescue of a Banty rooster named Henry.

      Reply

  4. Great blog. Our best friends share the same physiology with some differences such as the distribution of nutrients, snd differences in nutrient requirements. This does NOT mean that the quality of nutrients should be less than humans.
    I no longer trust commercial foods, and while it takes a bit to learn the right recipe, it is well worth it. I cook fresh whole food and the proof is Sophie went from picky eater to robust eater. No more expensive, and I make 5 dsys worth. Recipes abound,.

    Reply

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