The PFCs didn't have such a massive problem with consumers until the poisoning of our pets.  I vow going forward that I will excerpt the Government Sentencing Memorandum statement and send it to any PFC/lobbyist/blogger that criticizes the consumers for hyper vigilance, paranoia or condemn them from questioning any sudden change in their pets' health status.  It is a clear marker for the damage done to consumers by Menu Foods, Wilbur Ellis, Chem Nutra, the PFI (in hearings) and their ongoing attitudes towards consumers and pet food safety.

They did it to themselves, they did it to us.  They did it to our government and as a results thousands upon thousands of taxpayer dollars were/are spent chasing evidence and getting information, court expenses, etc. to prevent the silent recalls and disregard for animal health. For disregarding excercise of due diligence, gmps and quality assurance/control & verification of product/ingredient safety BEFORE it is sold to people to feed their animals.

That document alone should diminish the influence of the pet food/animal feed industry upon FDA/FSIS pet food safety reporting requirements... after all, the FDA bore the brunt of chasing the deaths, sicknesses reported due to lack of due diligence of the pet food industry...and still do with the silent recalls, delays in months doing a recall as they try to discredit the consumer, publicizing the recall, etc.


"Because of the neglect of these defendants, because they failed to exercise foresight
and vigilance, the public suffered greatly. Thousands of innocent pets became seriously ill and
many suffered death. It is impossible to talk about this case without realizing that the defendant’s
criminal conduct posed and caused substantial physical injuries, death, and psychological injuries."


The FDA needs to remember that the industry opinions & actions led to a major health disaster for our companion animals and damaged the consumer and IMO will again lead to another one if their continuing attitudes & opinions as evidenced in the docket alter the course of pet food safety regulation and FDA mandatory recall authority.  IMO, the 2006-2007 poisoning & criminal actions negated the voice of the pfc in determining what is needed for recall, public information & pet food safety laws. IMO, every recall or withdrawal after that has been a perfect example of attitudes & opinions which are the foundation of the failure to protect the consumer and the companion animals.

FDA take away the PFC/PFI voice and give us pet food safety laws and FDA mandatory recalls.

WHY WERE THESE GUYS ALLOWED TO COMMENT AFTER CLOSURE OF COMMENT PERIOD?
And consumers just getting notice today!!!!!!!!!
AFIA pdf content:

http://www.regulations.gov/search/Regs/home.html#documentDetail?D=FDA-2008-N-0546-0018.1

February 19, 2010
Division of Dockets Management (HFA-305)
Food and Drug Administration
5630 Fishers Lane, rm. 1061
Rockville, MD 20852
RE: Comments submitted in reference to Docket No. FDA-2008-N-0546
Now celebrating its Centennial year, the American Feed Industry Association (AFIA),
based in Arlington, Va., is the world's largest organization devoted exclusively to
representing the business, legislative and regulatory interests of the U.S. animal feed
industry and its suppliers. AFIA also is the recognized leader on international industry
developments. Members include more than 500 domestic and international companies
and state, regional and national associations. Member-companies are livestock feed and
pet food manufacturers, integrators, pharmaceutical companies, ingredient suppliers,
equipment manufacturers and companies which supply other products, services and
supplies to feed manufacturers .
We are writing in response to the Agency's Comment Request; Pet Food Early Warning
Recall Rational Questionnaire as Part of the MedWatchPl. Portal and Rational
Questionnaire Initiative, Docket No. FDA-2008-N-0546. Many AFIA members
manufacture pet food and supply ingredients to pet food manufacturers, therefore, this
collection of data could have an effect on these firms.
The information collected through the MedWatchPl. Portal is key to the successful
determination of whether a product has a potential adverse issue. Therefore, AFIA
believes it is crucial all of the information be provided by the submitter and the data
collected on a potential concern be shared with the company who produced or marketed
the product.
AFIA is concerned the name of this report is not reflective of all products consumed by a
pet in the household. That is, "pet food" is only a portion of the products that might be
consumed by an animal . Most consumers think of "pet food" as a dry, extruded kibble F DN - .2 0 aB-N-aSy&I"' 2 101 Wilson Boulevard, Suite 916, Arlington VA 22201 USA
Telephone (703) 524-0810 - Fax (703) 524-1921
..~.,~,,.~.. ,...,. _ .~,.<,... ..~ ,.,...
only. Therefore, the name of the document and the questions should reflect pet foods,
treats, pig ears, supplements, and other items consumed by pets.
Additionally, it should be clear the MedWatchri. Portal submission is to report suspected
or potential product issues or suspected adverse events. "Adverse events" should be
clearly defined for consumers in the form. In short, it should be clear to the submitter the
issue is not necessarily a direct result of the food consumed. Consumers frequently
forget the fact that while "pet food, treats, pig ears, supplements, etc." have been
consumed, the dog or cat also may have consumed other foods or even rodents, rabbits,
birds etc. Therefore, it should be required of the submitter to identify if consumption of
other foods or animals occurred .
The "reporter" is not a preferred term in this instance. A more appropriate term would be
"submitter." In any event, the submitter should be clearly identified so the claim can be
evaluated and all facts can be ascertained. Therefore, contact information should not be
optional, but instead mandatory.
In regards to the form, the following ideas should be captured:
Regarding "what type of report are you submitting" the terms, "adverse event,
product problem, or both." are unclear. Submitters may be reporting anything
from a lethargic animal to vomiting to the death of a pet. The list should be
expanded to include a number of different scenarios as opposed to simply an
"adverse event or "product problem, or both."
To better clarify "indicate any other parties that you notified about this issue," the
drop down list should say "veterinarian, manufacturer, state or store where
purchased."
The "Affected Animal Information" should be listed after the "Product
Information."
Additional space and/or instructions to fill out another form should be provided so
the submitter can address multiple pet households. "Animal name/identifier"
does not appear to have the option to list multiple pets.
Under "species" and "breed" it is assumed there will be a drop down list
providing options for the submitter.
"Date of death" should be followed by "(if applicable)."
In order to add clarity for the consumer, the "RJPC from label" should contain a
picture so consumers can understand the required information.
It is unclear what package types are going to be listed . Many consumers are
unaware of differences between pouches and canned products and may simply
refer to them as "wet." Therefore, there should be a comprehensive drop down
menu representing all package types and "other."
"Package size" should indicate whether the product was purchased collectively in
a case or multi-pack.
To help distinguish between a possible manufacturing issue and a possible
individual bag problem it is important to understand if the package was damaged.
Therefore, additional questions should be added: Was the package damaged?
Were there abnormalities in the appearance and/or smell of the food? Was this
the first feeding from the bag?
The phrase "if the product was reconstituted, what is the percentage of the product
that is water" will be lost in consumer translation and should therefore be in
simple terms such as "did you add water to the product before feeding, and if so,
how much?"
"Describe how the product was used or administered" should be "describe how
the product was fed."
Under "firm/organization name" it needs to be apparent this is the firm or
organization "from the label: "
"Product lots" information needs to be moved to just below the product name.
The "lot number" and "expiration/use-by date" are critical pieces of information
that should be mandatory. Additionally, a picture needs to illustrate the type of
information needed and where it might be found on the label.
In regards to "was a veterinarian consulted," descriptions regarding the animal's
medical status should be determined with "is the animal up to date on veterinary
visits and vaccinations?"
Finally, it is unclear what will prompt action by the FDA or what that action will be.
AFIA encourages the Agency to be open in lines of communication with the respective
company and share details of the potential concern so companies can use due diligence in
the evaluation of consumer concerns. In conclusion, AFIA is committed to working with
the Agency in finalizing the questionnaire and hopes to see the results of this commenting
period in another notice for comment.
Respectfully submitted,
~c
Jac~rod H. Kersey a
Director, Ingredients and State Legislative AM

3cat asked:

WHY WERE THESE GUYS ALLOWED TO COMMENT AFTER CLOSURE OF COMMENT PERIOD?
And consumers just getting notice today!!!!!!!!!

Because consumers are idiots, and cannot understand terms like "reconstituted"  

The phrase "if the product was reconstituted, what is the percentage of the product
that is water" will be lost in consumer translation and should therefore be in
simple terms such as "did you add water to the product before feeding, and if so,
how much?"

End of rant