One of the most striking and compelling points that illustrates immediately the
potential failure of resolving any of the pet food issues  by the combination of
standards of animals feeds and pet foods (and an action which accomplish an end
run around the purpose and intent of the FDAAA) -  we don't eat our pets.  We are
their guardians, care givers and love them as part of our families.

What our pets eat and the impact of those foods to their health is an alarm
system for not only what is happening in the feed industry, meat & poultry
industries, but also for what is happening in the human food, supplement and drug
industries.  The companion animal nutrition and health is a micro-lab filled with
people who are watching and closely caring for their needs. Livestock receives
care as a "product" and as livelihood. That is not the case with companion animals.

This makes the pet food industry stand far apart from the agriculture and livestock
industries whose goals are for profit and fast production of a product for human
consumption.

The mere size of and physiology of the companion animal removes it from the
scale of risk assessments, dilution theories, feed requirements and the safety
measures for the animals in the food supply industry, as well as a seemingly lack
of knowledge of their needs independent from the for-profit science skewed to
serve the financial purpose of the pet food industry.

The manner in which companion animals are housed also removes them from the
same category as food animals -   Sleeping with our children, our small children's
small hands in the food dish, the integration of that companion animal into a
household is something that would most likely not be common in the meat or
poultry industries. Those livestock are in fields, holding pens, barns.. not our
homes. Those animals are Not sharing the "companionship" and being integrated
and cared for as part of the family.

The pet food industry has historically been able to hide its attitudes, methods and
formulas from the governance of any government agency and has by promoting
their mythical advertising as truth about the nutrition and ingredients of companion
animal foods brought us to the point where we're not finding longer lives, but
companion animals with shorter lives and an increase in tumors, cancers, kidney
failures, liver failures & diabetes. You've talked about the increase in diabetes in
humans, take a look at what is happening with CRF, ARF cats and diabetic cats.   
We don't need designer foods. We don't need to worry about the penthouse
person and the pet food company formulating food that generates feces suitable
for white carpet on the 31st floor.  We need to be able to protect our companion
animal health, read the label and know what it contains, where the ingredients
came from, who manufactured it, the pet food company name and to be able to 
trust that the food provides the nutrition needed and that it will not endanger us or
or animals.

Also, look at the catastrophe in March 2007 and look at your records where
cyanuric acid or melamine were found separately in products killing companion
animals and notice, please notice, that the production dates are not in the range
you have presented to the general public.

That's part of the issues the FDAAA was legislated to solve.  It fell short of the
need, a desperate need, for the FDA/CVM to have mandatory recall authority over
a renegade and arrogant pet food industry. There are good pet food companies,
but they are not perfect. Therein lies the need for regulation, uniform nationwide
standards and enforcement and the continued vigilance of pet food consumers.

Our veterinarians and associations also need to step up to the plate and either
communicate companion animal health issues to the CDC or form post haste a
system of alerts and monitoring of issues in companion animals. That needs
reporting from vets needs to be mandated in the same manner as human health
issues.

There are some pet food companies who are happy to only conduct random tests
to make sure vitamins, supplement & minerals are "within limits" with no tests
done for the safety of the combination of supplements/ingredients and no tests
done for the safety of the formulas on the target consumers,  No knowledge of the
actual nutritive value of the true proteins and some will test for Melamine but will
NOT test for cyanuric acid.  We know from many media reports that the Chinese
have added cyanuric acid for "years". While AAFCO has allowed nonprotein
nitrogen in pet foods, the pet food companies themselves have not seen fit to
address the nutritional value and impact of such ingredients. The NPN in the
livestock industry has its place. It has no place in pet foods consumed by
companion animals. The industry purchasing the animals feed does not remotely
relate to the consumer purchasing for a much loved companion animal.

AAFCO needs to be able to regulate the standards or the pet food companies
need to remove the "certification" from their labels. As it stands - It is false,
misleading, deceptive and is abused by the pet food industry that knows there are
approximately 25 states that use the AAFCO standards and that it is not reflective
of safety or nutrition AT ALL!

And, as we've seen from Evanger's dispute of the FDA notice on LACF at their
facility and calling  it mistaken, a boilerplate notice and declare it was "only" a
paperwork issue and had no bearing on the safety of their product.  What they
don't talk about are the rusted, bent & dented cans in addition to that. The industry
feels it can outsmart the FDA due to the lack of the FDA/CVM ability to regulate
them. (See Richard Sellars AFIA article "Recall Realities":  "Firms should agree
upon their objectives before dealing with media calls. There are no mandatory
recalls in either federal or state feed laws. " ..."FDA asks to be notified of recalls
immediately, but there is no legal obligation to do so. It is usually better to contact
the state feed control official (www.aafco.org) and discuss the scenario before
contacting FDA or other agencies. To notify an agency or official is a business
decision. Downstream customers may notify regulatory agencies in due
time..."http://www.petfoodindustry.com/ViewArticle.aspx?id=18136 )  That attitude
has been recently displayed all over the Internet by Evanger's - the disregard for
and the denial of the severity of the issues of botulism, safe pet food and
companion animal health.

Consumers and companion animals are the ones who are abused by the pet food
industry  and are the ones that truly suffer from the lack of regulation of this pet
food industry.  Livestock and animal feed companies have understood regulation
and oversight - the pet food industry has pounded its proud chest and
proclaimed "self regulated" and so well done that they should not have regulations.
They are stubbornly refusing to accept responsibility for the safety and the
concerns of the consumers, and ultimately they are not caring for the health of the
companion animals.

Consumers are patronized, lied to, misdirected and given "feel good" ads by the
pet food industry as they hide and conduct business for the buck, not for the
actual nutrition, safety of their product and health of the companion animal.  Their
ends cannot justify their continued escape from regulatory oversight by the
FDA/CVM.

Regulation of the pet food industry and nationwide uniform enforceable standards
are needed, now. 

The aftermath of the catastrophe has left damaged animals and unanswered
questions about the long term prognosis for our companion animals health.  There
have been many statements that the inflammation and necrosis found in
necropsies far exceeded the number of crystals. Redacted and unspecified other
contaminants also had an impact leaving the vets and the consumer dealing with
the health and nutrition of their companion animal in the dark.. and the pet food
industry trying to make sure that they remain in the dark.

That makes it imperative that action as called for by the FDAAA is not buried in
the mire of another industry, animal feed. The pet food industry has established a
mote around itself and that mote needs to be bridged by regulation and the
FDA/CVM authority to issue mandatory and public recalls of their products.

The day animal feeds are advertised in the same way and in prime time markets is
the day the two systems, animal feed & pet foods,  should be combined.

That day has not arrived and will not arrive until the pet food industry comprehends
regulation and the authority of the FDA/CVM to recall and demand safe nutrition
foods for companion animals. That industry is not remotely there yet, in spite of
the pet food catastrophe 2006-2007. Most likely they will go kicking and
screaming to the table of responsibility for their products. You need to take them
there and not continue to give them the blanket of the animal feed industry to
continue to hide under.

Please adhere to the intent of FDAAA and do not leave companion animals and
consumers in the lurch until the next lurking catastrophe strikes.