FDA May meetings on Pet Food Safety & Labeling -- another take

http://petfoodsafety.wordpress.com:80/2008/08/06/fda-discusses-pet-food-labeling-and-safety/

While reasonably well attended, the meeting did not spark much public debate. FDA purposefully had little to say (the meeting was to collect outside opinions, and assumedly the agency did not want to hinder that process by espousing any preconceived positions of its own).

Only three outside groups offered verbal comments:

The Association of American Feed Control Officials (AAFCO) made some brief remarks regarding implications new federal regulations would have on the current state regulatory oversight of petfoods;
The American Veterinary Medical Association voiced support for mandatory calorie content statements on dog and cat foods and put forth a very interesting proposal to require a “not evaluated by FDA” disclaimer on petfoods bearing health-related claims; and
Defend Our Pets, a consumer advocacy organization formed as a result of last year’s recalls, made the most extensive comments. The group presented a long list of suggestions, including some form of country of origin labeling (e.g., disclaimers when the product contains ingredients from countries that do not meet US standards) and “total elimination” of what it considers confusing and misleading labeling requirements (apparently from the AAFCO Model Pet Food Regulations). This organization also recommended actions beyond FDA’s authority to implement on its own (e.g., mandatory recall authority, approval of grants by petfood companies to veterinary schools).
Scheduled for a full day, the meeting lasted only a couple of hours, even with a long break in the middle. Because the due date for submission of written comments on this matter was a month later, most organizations with a stake in the matter decided to withhold verbal comment until they could evaluate the comments of others and react at a later time.

In fact, the written comments, posted on www.regulations.gov (re: Docket #FDA-2007-N-0442), are extensive and include input from many organizations, including the Pet Food Institute, the American Feed Industry Association and both the American College and Academy of Veterinary Nutrition.

Separate petfoods from feed?

AFSS is intended to address pet food as well as livestock feed safety. To me, this makes sense, as it would allow for a more effective and efficient program to the benefit of all. Interestingly enough, Defend Our Pets is adamantly opposed to grouping petfood with feed in the system. Notwithstanding that AFSS has been in development since 2003, the consumer group believes AFSS would “dilute the intent and authority” of FDAAA.

You can go through post-hearing comments here:
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=Docket%20%23FDA-2007-N-0442&sid=11B99B4F7554

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