http://www.regulations.gov/search/Regs/home.html#docketDetail?R=FDA-2008-N-0546PUBLIC SUBMISSION As of: January 04, 2010
Tracking No. 80a74c8a
Comments Due: January 29, 2010
Docket: FDA-2008-N-0546
Agency Information Collection Activities; Proposed Collection; Comment Request; Electronic Data Collection Using MedWatchPlus Portal and Rational Questionnaire
Comment On: FDA-2008-N-0546-0009
Agency Information Collection Activities; Proposed Collection; Comment Request; Pet Food Early Warning Recall Rational Questionnaire as Part of the MedWatchPlus
Document: FDA-2008-N-0546-0015
Don Earl - Comment
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Submitter Information
Organization: Pet Food Products Safety Alliance
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General Comment
The questionnaire should also ask for a timeline to onset of symptoms. For example, vomiting occurred half
an hour after consuming the food, abdominal cramps occurred two hours later, etc.. Knowing when it happened is
as important as knowing what happened, as time to onset of symptoms is often characteristic to specific toxins
or food borne illnesses.
It would also be helpful to provide a place for pet owners to provide information on any lab work performed by
their veterinarian. Most lab work is reported in the form of user friendly graphs/charts, which identify areas where
values are high or low. While the information is typically reported in code form, such as "ALT", "WBC", etc., if a
pet owner has the information available, it's information that would otherwise be difficult or time consuming for the
FDA to acquire. A place on the form to report abnormal values, even if the pet owner doesn't recognize the code,
would be information that would be useful to the FDA.
I would also suggest that
it should be mandatory for pet food companies to fill out the forms on any consumer
complaints communicated directly to the pet food company or retailer. A consumer suspecting problems with a
product is more likely to report it to the company than they are to look up contact information for the FDA.(emphasis mine)
A substantial effort to put veterinarians in the loop should also be initiated. Too often veterinarians overlook the
possibility a health problem is associated with pet foods. Worse yet, they are often unaware even when a recall
has been announced.
By all rights, veterinarians should be the first line of defense in reporting suspected problems,
rather than the last to know. Veterinarians should be encouraged, or required, to report any incidents that may be
connected to pet foods. On average, for the past ten years, a pet food recall is announced about every 4 months.
Increased awareness of a problem that is virtually endemic is essential among medical professionals.NOTE WELL: COMMENTS ARE DUE BY
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