It seemed there are some really mixed messages in that docket entry.
"AFIA is concerned about the impact on the animal food industry of the Food and Drug Administration Amendments Act (FDAA) of 2007. In AFIA’s discussions with the principal sponsor of the Senate bill that became incorporated into FDAAA as Section 1002, it is clear that pet food was the sole focus and intent of Section 1002 of the act and extension of this section to all animal food would ignore this clear congressional intent."
""The pet food labeling system currently in use in the U.S.A. has evolved over several decades and is required under state pet food regulations. Federal changes to pet food label requirements would cause serious disruption with the state requirements, as FDA was not provided any federal preemption authority in FDAAA."
"AAFCO spent several years discussing and drafting feeding directions requirements for both pet food and non-pet animal food. The consensus reached and adopted by 18 states has been well-received and should not be changed."
(snork!!
18 states do not a majority make.. oh right, when they finished there weren't that many states in the USA
)
AFIA believes the development of such a mandatory regulatory program (i.e. AFSS) is premature. The agency should seriously consider a cGMP-(current good manufacturing practices) type approach to pet food regulation until the agency and state investigators become familiar with both the pet food industry and cGMP regulations developed for that specific industry. Development of this type of national regulatory program would allow time for both the industry and regulators to adjust to a “next-step” approach beyond cGMPs. In fact, most firms have in place similar programs, and although, many have risk-based approaches, development of a regulatory program utilizing AFSS as a basis would be a major rule for the industry and the cost/benefit ratio would be extremely high for an industry with rare safety issues. Moreover, such standards would hamper technical innovation by likely applying a “one size fits all” standard program to the highly innovative and competitive pet food industry.
In response to FDA’s request for information on what to include in an approach to regulations,
AFIA believes the most comprehensive list of criteria to include comes from those in the medicated feed cGMP regulations (Title 21, C.F.R., Part 225). These have served the agency and affected industry well for over 35 years and resulted in very few contamination events.
AFIA urges the agency to seriously consider the utilization of these categories in development of
cGMP regulations for pet food manufacturers. "
Maybe they've halfway realized that the FDAAA will be impacting them in ways they didn't consider when this was slammed into one package. But, isn't AAFCO the one writing the FDA to begin with that got it all wrapped into this pile of inept reviews that cannot accomplish anything for centuries?
