Public Comment on Pet Food Safety

Sandi K

Hero Member

Posts: 1963

Public Comment on Pet Food Safety

« on: January 23, 2008, 10:03:33 AM »

Hi I posted this under recall realted also but thought this might be a good place for it also...

Hi, I finally contacted FDA regarding Docket 2007N-0487 Meeting to Obtain Public Input for Ensuring the Safety of Pet Food. That notice advised that the docket was available for public input on-line. As many of us have found out, its not. When I inquired why, I was advised to contact the FDA Public Room. I just did that this morning and was told, guess what? Its not available for on-line public comment.....gee, I thought we already knew that. I asked if they could make it aceesible on-line as soon as possible and was told it wont be partly due to a new system they are putting in place. I advised them we have a large group of people that want to make comment. He said we could fax our comment to 301-827-6870. He said their was a lot of "disconnect" between agencies....need I say more? Im still not giving up, the notice had the name of a person to contact for further information so I sent this e:mail to him. Other people might want to contact him also , that would help show the number of people that want to make comment on-line. The e:mail addy is : walter.osborne@fda.hhs.gov <walter.osborne@fda.hhs.gov>

Mr. Osborne, FDA recently put notice out that there will be a meeting planned to obtain public input for ensuring safety of pet food. This notice says Docket 2007N-0487 is open to receive electronic comments. If you go to that site at fda.org, you will find that it is not open for electronic comment, there is no place to submit comments on-line. I have called the FDA Public Room and was advised it is not open, partly due to a new system being set up. We have a large group of people that are waiting to submit their comment on-line. The person at the FDA Public Room advised me it wont be available on-line for public comment for a very long time. I was advised we could send our comments via fax however it is very difficult for people to get access to fax machines. Is there anything you can do to make this accessible for on-line public comment right away? I might add that Im very disappointed that this notice would say its available for on-line comment when in fact its not which indicates no one reviewed it before submitting the notice. I would appreciate any information you can provide, thank you,

I might add that I sent my e:mail receipt attached and he did just read it so it will be interesting to see if he responds and how....will keep you updated.

Another update! This is the response I received just now so it looks like snail-mail or fax will be the only way to submit comment:

Thank you for contacting FDA about this Docket. First of all, the new electronic commenting system is not FDA's; it is a government-wide system that was launched January 15, 2008, over which FDA had, nor has, any control. I have spent hours on the telephone trying to obtain explanations about what happened, what is being done, and when the problem will be resolved. All I have learned is what you already know, specifically, that the new system is not up and running and will not be for an unknown period of time. Regrettably, I have no control over accessibility of the government-wide electronic commenting system.

The available means of submitting comments to this docket are: (1) via FAX as you already know; (2) mailing hard copy to the Dockets Management Division; (3) hand-delivery of hard-copy comments; or (4) e-mailing them to me. I have established an electronic folder that I am saving comments in, which will be sent to the Dockets Division. I encourage you and your colleagues to choose one of these alternative means of submitting comments to this Docket.

I am sorry that I do not have better news for you at this time.

This was my response to him:

Thank you Mr Osborne, for the information. I will pass this on to the folks that are interested in submitting public comment. One thing I might suggest is the notice should be amended indicating this is not available for electronic comment as it is very mis-leading and confusing and its causing alot of people to withhold comment waiting for the electronic capability. Thank you, Sandra


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SusanP

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Re: Public Comment on Pet Food Safety

« Reply #1 on: January 23, 2008, 10:37:26 AM »

Thank you for this information, Sandi. I would like to give this information out on the radio, if that is ok with you.


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Sandi K

Hero Member

Posts: 1963

Re: Public Comment on Pet Food Safety

« Reply #2 on: January 23, 2008, 10:53:57 AM »

Sounds fine Susan, thank you for getting the word out, the more comments they receive, the better.


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menusux

Guest

Re: Public Comment on Pet Food Safety

« Reply #3 on: January 24, 2008, 01:23:21 PM »

If anyone wants to see how PFI and its' allies comment on dockets, here are some links:

http://www.fda.gov/ohrms/dockets/dailys/02/Sep02/091902/80027f6d.pdf

http://www.fda.gov/ohrms/dockets/dockets/02n0209/02n-0209-c000098-vol19.pdf

PFI 2002-Docket 02N-0209

http://www.fda.gov/ohrms/dockets/dailys/03/Feb03/020503/8004d34a.pdf

http://www.fda.gov/ohrms/dockets/dockets/02n0273/02n-0273-c000118-01-vol21.pdf

PFI 2003-Docket 02N-0273

http://www.fda.gov/ohrms/dockets/dailys/01/Nov01/111901/ch00010.pdf

Nutro 2001-Docket 01N-0423


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BruinMike

Full Member

Posts: 90

Re: Public Comment on Pet Food Safety

« Reply #4 on: January 26, 2008, 09:01:12 PM »

I talked with Mr. Osborne personally about 4 days ago and he apologized for all the
problems with the electronic comments forms.

He advised me that we could send our comments and observations about the
pending hearings directly to him at:

walter.osborne@fda.hhs.gov

He will make sure that all comments are properly directed until the new
website for electronic comments is up and running properly.

Mike
mike@defendourpets.org


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Sr. Member

Posts: 229

Re: Public Comment on Pet Food Safety

« Reply #5 on: January 26, 2008, 09:53:05 PM »

Good job, Mike!!


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Sandi K

Hero Member

Posts: 1963

Re: Pet Food Safety meeting-new info

« Reply #6 on: April 07, 2008, 05:05:58 PM »

I received this, it sounds like the public meeting for that docket we were submitting comments on is May 13th, so if you havent submitted your comments yet, there's still a little time.

http://www.fda.gov/cvm/AFSSUpdateIV.htm

FDA’s Animal Feed Safety System (AFSS) Project Plans Update #4

The Center for Veterinary Medicine has scheduled the fifth public AFSS meeting for May 14, 2008, in Gaithersburg, MD. The AFSS meeting will immediately follow a Food and Drug Administration-sponsored meeting on new requirements stipulated by legislation for pet food safety.

At the previous AFSS public meeting, held in May 2007, the AFSS Team explained the exposure component of the risk-ranking model it had developed. The Team discussed, for an example, the pathways by which swine would be exposed to dioxin via various swine diets. For the next meeting, the Team plans to present methods for ranking risks associated with biological and chemical hazards in feed, again using swine feed as an example. Details of these methods will be discussed at the meeting.

FDA will use the model internally to determine how best to use feed safety resources to make sure the Agency is addressing feed hazards with the greatest risks to public and animal health.

At previous public meetings, the AFSS Team discussed the concept of risk, saying that risks can be assessed relative to each other and subsequently ranked by:

Identifying potential hazards;

Characterizing the consequences of the hazard (the likelihood and severity of illness);

Characterizing the likely exposures to the hazard; and

Ranking the risks (the likelihood that something will go wrong) of the hazard, compared to other hazards.

Originally, the AFSS Team discussed using the model to assess physical hazards along with chemical and biological hazards. However, the Team has not been able to locate sufficient data on physical hazards. Therefore, the Team is concentrating its efforts on the analysis of chemical and biological hazards in the risk-ranking model.

The Team also plans to briefly present the risk-based approach being developed to prioritize inspections done by FDA under the Agency’s feed compliance programs.

In addition, at the upcoming meeting, the Team plans to present a third draft of the AFSS Framework document and to discuss in more detail several of the gaps identified in the recently revised Framework document. Additional steps are being taken to improve feed defense, which continues to be a priority for the Agency. Further, measures are being developed to ensure more widespread understanding and adoption of the AFSS initiative by our stakeholders.

Memorandum of Understanding about feed ingredient definitions

In August 2007, CVM signed a Memorandum of Understanding (MOU) with the Association of American Feed Control Officials (AAFCO) to cooperate in the review and development of definitions for animal feed ingredients, as part of the AFSS initiative to strengthen the U.S. feed safety system.

AAFCO publishes an annual Official Publication (OP) that includes a list of all ingredients the Association has reviewed and found suitable for use in animal feeds. The OP also contains cross-references to certain sections of the Code of Federal Regulations that list approved food additives and ingredients that are considered by FDA to be “Generally Recognized as Safe” for specific uses in animal feed. The OP is considered to contain the most current and extensive list of common or usual ingredient names.

In the past, FDA has cited the OP’s ingredient definitions list and has acted as AAFCO’s scientific advisor in reviewing petitions for the addition of ingredients to the list or for changes in the ingredient definitions. However, although the definitions in the OP ingredient list can be enforced by those states that adopt the list, the OP list does not have a comparable status for FDA.

The MOU will clarify the responsibilities of FDA and AAFCO during the feed ingredient definition process and will provide mechanisms for resolving disputes that arise and for modifying the process when required.

Under the MOU, CVM assigns scientists to work with AAFCO in reviewing petitions for new feed ingredients or for modifications to existing ingredient definitions. Also, before it adopts a new feed ingredient definition or amends an existing one, AAFCO will ask CVM for advice and a letter of concurrence. In addition, the MOU requires AAFCO to remove a definition from its OP if FDA provides convincing scientific evidence that the ingredient is no longer suitable for its intended purpose.

FDA’s recognition of the AAFCO process is one of the specific recommendations made in the AFSS Framework Document. The document is available at http://www.fda.gov/cvm/AFSS2ndDraftFramework.html.

The MOU went into effect on August 30, 2007, and remains in effect until September 1, 2012.

FDAAA legislation

In September 2007, President [edited] signed the FDA Amendments Act of 2007 (FDAAA), which, besides continuing FDA’s user fee program for human drugs and devices, has some significant new requirements in the area of pet food safety that are parallel to the work of the AFSS Team.

Section 1002 (a) of FDAAA gives FDA two years to establish, “by regulation,” ingredient standards and definitions, processing standards, and labeling standards, including nutritional and ingredient information, for pet food. The December 2006 draft of the AFSS Framework Document had identified the AFSS Team’s intent to develop process control regulations for all animal feed, including pet food. The Framework Document also indicated the need to recognize the ingredients listed in AAFCO’s OP as acceptable for use in animal feeds.

The law says this rulemaking will be done in consultation with stakeholders. On January 7, 2008, FDA published a Federal Register notice announcing its intent to hold a public meeting to obtain input from its stakeholders and opening a docket (2007N-0487) for receiving written comments. The public meeting is being planned for May 13, 2008, at the same site of the next AFSS public meeting, which as indicated above will take place the day after the FDAAA meeting. More information will be provided in future Federal Register notices and on CVM’s Web site.

April 2008

Web page updated by mdt - April 7, 2008, 10:43 AM ET


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Sandi K

Hero Member

Posts: 1963

Re: Public Comment on Pet Food Safety

« Reply #7 on: April 08, 2008, 10:07:42 AM »

This is some info I got from Walter Osborne:

> The notice to announce the May 13 meeting should be appearing in the
> /Federal Register/ by Monday, April 14th. That notice will describe
> in detail the format of the meeting, pose some specific questions FDA
> is seeking public input on, and explain how individuals can sign up to
> speak at the meeting, which _is_ open to the public.

Perhaps I might bring up the subject of silent food "withdrawals" such as what is being done by NV in addition to the comments I already sent them. Angry


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Carol

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Posts: 1999

Harry with the "Golden Bone" 6/29/05--4/24/08

Re: Public Comment on Pet Food Safety

« Reply #8 on: April 16, 2008, 04:47:46 PM »

Bump

( posted by MariManu at Recall News )

http://www.regulations.gov/search/search_results.jsp?css=0&N=0&Ntk=All&Ntx=mode+matchall&Ne=2+8+11+8053+8054+8098+8074+8066+8084+8055&Ntt=2007N-0487&sid=11920417CA26

Type in the docket number: 2007N-0487

Another page will come up

Click on: "Send a Comment or Submission".
You can type your comments in here. You might want to get them ready in advance and either just send as an attachment, or copy and paste the info.

You will also want to sign up for the "Notification" part so you can keep updated on the submissions of the Pet Food Institute and other corporate multinationals who have taken the position that it's fine to continue to let the industry regulate itself.

Meeting Being Planned to Obtain Public Input for Ensuring the Safety of Pet Food


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“Never doubt that a small group of thoughtful, committed citizens can change the world; indeed, it’s the only thing that ever has.” — Margaret Mead

United we stand Divided we fall....

Carol

Hero Member

Posts: 1999

Harry with the "Golden Bone" 6/29/05--4/24/08

Re: Public Comment on Pet Food Safety

« Reply #9 on: April 21, 2008, 02:22:18 PM »

http://www.fda.gov/cvm/CVM_Updates/petfoodstandards.htm
April 21, 2008

FDA Public Meeting on Opportunity for Public Input on Standards for Pet Food and Other Animal Feeds

The Food and Drug Administration (FDA) is announcing a public meeting to obtain input from stakeholder groups, including, but not limited to, the Association of American Feed Control Officials (AAFCO), veterinary medical associations, animal health organizations, and pet food manufacturers, on the development of standards for pet food, including ingredient standards and definitions, processing standards, and updated labeling standards. Establishment by regulation of such standards for pet food was mandated by the FDA Amendments Act of 2007 (FDAAA). FDA also would like to obtain input on whether the ingredient standards and definitions and processing standards should cover all animal feeds. Additional information about the meeting may be found in the April 21, 2008 Federal Register.

The public meeting will be held on May 13, 2008, from 8:00 am – 4:30 pm.

The public meeting will be held at The Gaithersburg Holiday Inn, 2 Montgomery Village Avenue, Gaithersburg, MD 20877. There is parking adjacent to the building. The building is also accessible by public transportation.

Although there is no registration fee for this meeting, pre-registration is required to ensure there is sufficient room. Please notify us through the pre-registration process if you wish to make a public comment at the meeting. To pre-register, please send an electronic message to nanette.milton@fda.hhs.gov Nanette Milton, Center for Veterinary Medicine, Food and Drug Administration, 7519 Standish Place, Rockville, MD 208755, (240) 453-6840, Fax: (240) 276-6880, no later than May 7, 2008. Your email should include the following:

Your name

Company or association name

Address

Phone number

E-mail address

State whether you are speaking on behalf of an organization or if you are speaking as an individual

Any special accommodations (wheelchair access, sign language interpreter, etc.)

You will receive a confirmation within 2 business days. FDA will also accept walk-in registration as the meeting site, but space is limited. FDA will try to accommodate all people who wish to make a public comment at the meeting, including those who register at the meeting site; however, the time allotted for public comments may depend on the number of persons who wish to speak.

To ensure consideration of your comments regarding the development of standards for pet food and other animal feeds, you should submit comments by June 13, 2008. While interested persons may comment orally at the public meeting, comments may also be submitted in writing or electronically in addition to, in lieu of, restating, expanding upon, or supplementing oral comments to the Division of Dockets Management (HFA-305), Food and Drug Administration, 5630 Fishers Lane, Room 1061, Rockville, MD 20852. Submit electronic comments to http://www.regulations.gov/ . Submit a single copy of electronic comments on two paper copies of any mailed comments, except that individuals may submit one paper copy.

All comments are to be identified with the Docket No. FDA-2007-N-0442 (formerly Docket No. 2007N-0487). Received comments may be seen in the Division of Dockets Management between 9 am and 4 pm, Monday through Friday. You may also view received comments at http://www.regulations.gov/.

For general information contact, Tracey Forfa, Center for Veterinary Medicine, Food and Drug Administration, 7519 Standish Place, Rockville, MD 20855, (240) 276-9000, Fax: (240) 276-9030, e-mail: Tracey.Forfa@fda.hhs.gov.

http://www.fda.gov/cvm/CVM_Updates/AFSSMtg0508Update.htm
April 21, 2008

FDA Plans 5th Public Meeting on Animal Feed Safety System

The Food and Drug Administration (FDA) has scheduled a meeting to continue public discussion of the development of the Animal Feed Safety System (AFSS).

The meeting will be held Wednesday, May 14, from 9 a.m. to 4 p.m., at the Holiday Inn in Gaithersburg, MD.

Since 2003, the AFSS Team organized by FDA has been analyzing the Agency’s feed safety program in the United States, identifying areas or “gaps” in which the system could be strengthened, and suggesting approaches to address those gaps.

Through a series of public meetings, the AFSS Team has presented its work in progress on a method for ranking animal feed hazards by their relative risks to animal and human health.

According to the AFSS Team, the relative risk posed by feed hazards can be ranked by combining a health consequence score for each hazard with an exposure score. The health consequence score considers the likelihood and severity of adverse effects if animals are exposed to the hazard in feed. The exposure score estimates the likelihood that an animal will be exposed to the particular hazard.

At the previous AFSS public meeting, held in 2007, the Team discussed the production of swine diets – nursery, grower, and finisher – to explain how exposure scoring would work. For the upcoming meeting, the Team will continue using swine feeds to further explain the risk-ranking model.

Please register for the meeting in advance. You can download a copy of the registration form at (insert link to registration form on AFSS meetings page). To register, fax the downloaded and completed form to Nanette Milton at 240-453-6880. Or send by E-mail the attendee’s name, title, firm name, address, and telephone and fax numbers to nanette.milton@fda.hhs.gov. You can also call 240-453-6840 with the information.

To make arrangements for special accommodations because of a disability, contact Nanette Milton no later than May 7, 2008.

Comments about AFSS can be submitted to the Division of Dockets Management (HFA-305) Food and Drug Administration, 5630 Fishers Lane, Room 1061, Rockville, MD, 20852. Electronic comments can be submitted to http://www.regulations.gov. Comments should be titled “Animal Feed Safety System,” and identified with Docket Number 2008-N-0189. Also, use the same Web site to review comments.

Additional information about the meeting is available in the April 21 Federal Register and is available on CVM’s Web site, at http://www.fda.gov/OHRMS/DOCKETS/98fr/08-1154.htm.

For general information about the AFSS public meeting, contact Zoe Gill, Center for Veterinary Medicine, Food and Drug Administration, 7519 Standish Place, Rockville, MD, 20855; 240-453-6867, Fax 240-453-6880. E-mail: zoe.gill@fda.hhs.gov.

Pet Food Standards Public Meeting

FDA has also announced that a meeting has been scheduled for 8:00 a.m. to 4:30 p.m. on May 13 at the same Gaithersburg location to obtain input from stakeholder groups on the development of ingredient, processing, and labeling standards for pet food. The FDA Amendments Act of 2007 mandated the establishment by regulation of such standards. Additional information about the pet food standards public meeting is available in the April 21 Federal Register at http://www.fda.gov/OHRMS/DOCKETS/98fr/08-1155.htm.

For general information about this meeting, contact Tracey Forfa, Center for Veterinary Medicine, Food and Drug Administration, 7519 Standish Place, Rockville, MD, 20855; 240-276-9000, Fax 240-276-9030. E-mail: tracey.forfa@fda.hhs.gov.

--------------------------------------------------------------------------------

Issued by:
FDA, Center for Veterinary Medicine,
Communications Staff, HFV-12
7519 Standish Place, Rockville, MD 20855
Telephone: (240) 276-9300 FAX: (240) 276-9115
Internet Web Site: http://www.fda.gov/cvm


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“Never doubt that a small group of thoughtful, committed citizens can change the world; indeed, it’s the only thing that ever has.” — Margaret Mead

United we stand Divided we fall....

Sandi K

Hero Member

Posts: 1963

Re: Public Comment on Pet Food Safety

« Reply #10 on: April 21, 2008, 02:30:59 PM »

Thanks for that Carol! I forwarded the info to Mike Floyd too for Defend Our Pets organization. Meeting time is getting closer, how I wish I lived there to be able to attend!


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Sandi K

Hero Member

Posts: 1963

Re: Public Comment on Pet Food Safety

« Reply #11 on: April 27, 2008, 03:40:28 PM »

Bumping this up so that anyone who hasnt submitted their input still has time before the May 13th meeting....

Quote from: Carol on April 21, 2008, 02:22:18 PM


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Carol

Hero Member

Posts: 1999

Harry with the "Golden Bone" 6/29/05--4/24/08

Re: Public Comment on Pet Food Safety

« Reply #12 on: April 27, 2008, 03:51:52 PM »

This is a copy of an email I sent to Nanette Milton (mailto:nanette.milton@fda.hhs.gov)on April 23, 2008. I wanted this to be posted so that it may give you ideas or just as a reminder to send one too as I will continue to fight for safe pet food for all of us here and elsewhere. No one of us can do this all by ourself but together with each one of us doing a little something----it surely will add up..

It was exactly one year ago on February 17 2007, that the first of my two beloved cats fell ill with acute renal failure. I never gave a thought to her food as the culprit. After all-- I fed her food that had been through actual "feeding trials" and had met AAFCO standards according to the foil packet. I had confidence in the safety of our food supply in this post 9-11 era. Three weeks later, March 11, 2007 my second cat, younger and stronger, fell ill with acute renal failure.

Here I sit now with one cat struggling with chronic renal failure and its many uncomfortable symptoms and one cat deceased with no change on the horizon for more enforceable regulations or positive changes to prevent this from happening again. Quite obviously to those of us who have watched this each and every day, and have taken the time to see how things are handled by the PFI and AAFCO, the existing regulations and statutes are grossly inadequate to protect our pets. In addition to having two acutely ill cats I was also a victim of “who to call”. Initially pet owners were told to call the manufacturer of the tainted food and report their sick pet to the FDA yet the FDA emergency operator told me personally on March 18th that this was not an FDA issue and asked why I was bothering her with this. It took me nearly round the clock dialing to the manufacturer and 4 days until I reached them and was told yes my food was on the list and to call my vet. My vet, who was less informed than I was about the recall, told me to call the FDA. Hence began my long merry-go-round ride.

I have a right--as a pet owner and a consumer-- to know what ingredients I am buying to feed my pets. I have a right to know where my food is manufactured and where the ingredients originate. I have the right to safely feed my cat and my dogs without fear of adulterated ingredients. I have a right to expect the companies who manufacture my pets' food to do proper quality control and are held responsible when the food proves to be defective. I have the expectation that regulations need to be enforced and penalties applied when not met. I have the expectation that food imports are inspected for safety. I have the expectation that when unsafe food products are discovered, immediate recall is begun for the safety of those involved.

This pet food disaster scenario can certainly happen again if the PFI, AAFCO and the FDA continue without significant changes. Mike Floyd, the founder of DefendOurPets.org, must be allowed to testify at the upcoming hearing on FDA Amendments Act. The FDA must step up to the plate now and see to it that the animals, who are beloved family members, have not died in vain.

Carol Vxxxxxxxx

on behalf of the deceased Jessica and the ill Smudge.


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“Never doubt that a small group of thoughtful, committed citizens can change the world; indeed, it’s the only thing that ever has.” — Margaret Mead

United we stand Divided we fall....

lesliek

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Posts: 2719

Trooper,Remy & Fragile

Re: Public Comment on Pet Food Safety

« Reply #13 on: April 27, 2008, 05:55:42 PM »

Carol- Great letter ! Already sent mine.


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"the world's most inept extortionist"

Offly_irked

Guest

Re: Public Comment on Pet Food Safety

« Reply #14 on: May 13, 2008, 11:10:48 PM »

Well, I put mine in the AFSS and pet food safety, I hope Sad

Quote

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.

It's almost 2:30 am and I am so upset because I realized they fully intend to leave/combine even tighter pet foods with animal feed.

We just can't let them do that to our companion animals!!!!!


« Last Edit: May 13, 2008, 11:30:15 PM by Offly_irked »	Logged

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	Author	Topic: Public Comment on Pet Food Safety (Read 1733 times)
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