Offy,

That's excellent!

5CatMom
₌^..^₌

http://www.regulations.gov/fdmspublic/component/main?main=DocketDetail&d=FDA-2007-N-0442

this is where I posted mine but don't see it either---I have tried now three times---anybody else can help us?

"How can I verify that my comments or submission has been received by the Department or Agency?

For Federal Register documents with an open comment period, federal Departments and Agencies generally do not acknowledge that they have received specific public comments. However, when a Department or Agency establishes a public docket for a specific rulemaking, public comments are placed in that docket. The Department or Agency will process your comments upon receipt, but the availability of your comments in the public docket will depend on the particular Department or Agency's process. Many Departments and Agencies place public comments in their public docket as they are received.

The electronic comments you submit directly through the Regulations.gov Web site are transmitted to the proper Department or Agency. The Department or Agency receiving your comment is considered the official custodian of the comment. Your comment will not be considered until it has been properly received by that Department or Agency in accordance with the requirements described in the Federal Register document. Users who want to verify that a Department or Agency has received their comment are urged to check directly with that Department or Agency."

http://www.regulations.gov/search/footer/faq.jsp#15

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Looks like it's up to the agency to place the comments.

5CatMom
₌^..^₌

Cross posted from Pet Connection--the number I called was 301-827-6860



I just talked to Ryan at the phone number provided by Christie-to find out why my comments are not showing up—he said the reason indiviual consumers’ comments are not showing up is they are posting only companies comments-he said they have too few people working on this and too many comments to post them all—he suggests saying you are part of an organization so the comments are public—he also told me he had just gotten a picture of a dead cat but I think it might have been the picture I attached of Smudge who is still alive but this pix was taken in March of 2007—he said that was not a good idea but I said that this is what happened to our pets real fast and I think it is very appropriate the FDA members see it. He said even though the comments are not made public they are sent on to the FDA members..
Sorry if I sound mad but this has been like the merry go round ride of March 2007…

Comment by Carol V — May 14, 2008 @ 11:31 am

Thanks, Offly.  I used Pet Owners Network and called it a consumers group.

I found I couldn't write about Ellie and Bart.  This is a bad time of year for me.  I wrote a rather large list of mandates I feel the pet food industry should be operating under.

The pet food standards need to be separated out from animal feed standards.  These animals are not livestock.  Pet owners are not raising their pets for consumption.  The goal of pet ownership is not rapid growth with an eye to future profits. Pet owners are primarily concerned with the safety of the pet food and the health of their pets.

The pet food industry requires certain mandates. 

First, there have to be guarantees that all ingredients are safe. When a new vendor of raw materials is engaged, the corporation should be paying for testing at an independent, certified lab. They need to be sure of the products they receive from the importers. Accepting foreign certificates of purity has been proven to be useless and fatal.  If the importers want to sell such materials in this country, they should be paying for testing at an independent, certified lab.  The testing should be made available to the manufacturer, the distributor, and the consumer.

Second, labels need to be clear.  Terms need to be defined.  What is organic, premium, human grade, pet food grade?  If a chicken variety of food is made from beaks, feet, and intestines, the industry should be required to put that information on the label or not use that material. If the majority of the material comes from rendering plants, the consumer should be informed.  If they are using non-protein nitrogen products, they need to inform the consumer. If the majority of the material is from grains and vegetables, and not meat, the consumer should know that. I would like to see labels the same as human food labels, giving serving size, number of calories, grams of available protein, fat content, carbohydrates, phosphorus and calcium levels, etc.  A label listing Taurine as 0.20% is not helpful, when many nutrition texts say 100 to 300 mg per day. 

Third, they need to remove nutraceuticals from their formulations and stop making bogus health claims.  I have seen DL-Methionine (a urine acidifier) as an ingredient in several brands of cat food.  However, when I look that ingredient up, I see warnings, such as “use with caution in patients with kidney failure, liver, or pancreatic disease” or “can decrease the effects of aminoglycoside (gentocin) and erythromycin medication.”  There are no such warnings on the cat food containers.  Either the corporations are risking certain cats’ health, or there is so little of the ingredient present, that it’s meaningless and shouldn’t be there.  Glucosamine and Chondroitin are also included in some “healthy joints” formulations of pet foods.  There is no dosage listed on the containers.  Is it a therapeutic level or is it fraud?  If a pet is already on glucosamine chondroitin, can this food cause an overdose? Again, there are no warnings on the container, and no proof that this product will help.

Fourth, the corporations should test for toxins, such as heavy metals, pesticides, pharmaceuticals, various organic compounds, possible counterfeit ingredients, etc. on a regular basis and make that information available to the consumers.  It’s probable that safe levels of many of these toxins are not known for pets, but the information should be made available to the consumer anyway.  It will certainly help with the decision making process of which food to feed.

Fifth, the pet food industry needs to be regulated by an outside agency.  AAFCO has failed miserably at the helm.  They do not test products for safety; they do not mandate quality control procedures. The giving of AAFCO certification is merely a paper exercise. The recalls have proven these companies are not capable of regulating themselves. They need to be forced to implement GMP and QA.  The FDA needs to be able to step in strongly and mandate recalls of pet food. The FDA complaint coordinators need to make themselves available to the public.  Vets need to be notified immediately of potential problems and need an organization similar to the CDC to report their findings to. The AMA needs to be informed if there is a potential for zoonotic disease, such as there was with the Salmonella recall.

Sixth, the media and all retail establishments need to be pressured to notify the public immediately. The retail establishments need to be pressured to remove ALL suspect material from their facilities and to train all staff not to override the bar codes on recalled material.

I wonder if it will show up...

I put this on the other thread too.  Anyone who submitted comments directly to Walter Osborne early on do not have to resubmit them. Any comments now need to go thru the docket system.


There is no need to resubmit comments to the Docket.  The Federal Register notice announcing the public meeting was the first official announcement about submitting comments; the earlier notice (for which I was the contact) announced FDA's intent to hold the public meeting and noted that comments would be accepted and they have been.
 
The changes to our Dockets system are not a result of FDA's changes; they are government-wide and FDA had no control over the system nor the inability to meet the January 15, 2008, date for complete migration of all the data from the old system to the new one.  But the migration of data was completed in early April.
 
Over the course of the past several months, I have received about 90 comments; these have all been forwarded to Dockets for inclusion in the Public Docket for this initiative.  If you do not see your particular comment(s), it may not have been scanned into the electronic (on-line) version of the Docket, but all comments are included in the hard-copy file located in the Public Reading Room at Dockets and all comments will be reviewed as part of the initiative for pet food standards, etc., as we move forward.  If you would like more information about the Dockets procedures, you may call the Reading Room at 301-827-6860.
 

 
 

Here is my comment:

In response to 2007N-0487 public comments on Pet Food Safety

1. Pet Food Labels should be updated to reflect similiar information that we see
on human food labels to include % of ingredients by serving in addition to the
current differing measurements used. I should not have to email my pet food
maker to figure out how to determine how many mg per cup of Glucosamine is in
the food so I don't over supplement my dogs. We should know what % of fat and
protien, for exampe is in each serving. The GA is confusing!

2. Ingredients should be listed in categories with % per serving just like we as
humans use the Pyramid!

For example:

Meats 60%: Chicken Meal, Lamb Meal, Salmon Meal ....
Grains 10%: Rice meal, Corn Meal ....
Vegetables / Legumes 5%: Soy meal ....
Fruits 4%: Apples ....
Botanicals .05%: Marigold, Rosemary ....
Nutracuticals .05%: Glucosamine ....
Vitamins, Minerals, Amino Acids 10%: L-Carnatine, Vitamin C ....

3. I am not opposed to botanicals but there should be a warning label that states
that some botanicals may interfere with some pet medications and should be
verified with your vet.

4. No 4 D's in pet food - we are feeding members of our family.

5. All pet food as a final product should be tested for known and unknown toxins
and at the lowest levels possible.

6. Date and Time stamps should be standard so we don't have to guess. Plus we
should know which plants our pet food is made at (some have SHADY histories!).
MM-DD-YYYY or MONTH-Numerical Day-YEAR with the manufacturer cleary
marked, what plant, date and time of production and good through date.
For example: MARCH-01-2008.Crosswinds.13:00:00.MARCH-01-2009.


7. Pet food companies should be held responsible for a pets death if caused by
food that was recalled or recalled too late. Testing should stop any need for
recalls. Either way the pet food company should have to pay for all medical (even
if the pet didn't die but was caused by the food) and at a minimum $5,000 per year
of the pets life that dies from their food as well as the original cost of the pet if
purchased from a breeder, store or adopted.

8. Before any claim can be made or if any claim is made the exact product used
in the study must be presented and available for the public to view. For example:
Purina talks about their ground breaking study on the Dog Chow commercial...so
it is implied that Dog Chow was used....but then Purina states the same study
comments on another Purina brand site....so what product was used in the
study?

9. Define Organic, Human Grade or any other "buzz word" used to market the
product.

10. Require recalls to be announced via TV, radio, internet and newspapers as a
FREE public service announcement.

11. Country of Origin. For example: Ingredients sourced from world trading partners: US, Mexico, Canada, China

Thank you.....I almost missed the posting deadline!!!! Glad I checked the forum here tonight....