Feedback to FDA on Pet Food Safety Video

During the AAFCO meeting the FDA previewed a pet food safety video.  The following is the feedback I sent to Eric Nelson of FDA on the video.  

You should know - that FDA's Eric M. Nelson (Center for Veterinary Medicine, Division of Compliance, Director) was very friendly and very willing to put up with my endless questions during the AAFCO meeting.  It is my intention to maintain this open dialogue with him/FDA.

After the video was previewed, Eric Nelson asked for input to be sent to him.  The following was my input and was emailed Saturday 1/21/2112.  

Hello Eric,

Hope you made it home safe.  I'm VERY glad to be back to warm weather - I came home to sunny skies and 70 degrees!  I'm happy again.

Now for the bad news.  The video that was previewed...I have many thoughts -

If left as is, I can assure you it will anger many pet parents.  They won't just be upset, they will be downright angry; justifiably so.  If you doubt this, I'd challenge you to do a one or two day preview of the video on my website and you can read the comments as they come in - it won't be pretty.

Statements made in the video that struck me...
"pet food follows the same regulations as people food"
Nope, this is not a factual statement; that is unless 'people food' has FDA compliance policies that I'm not aware allowing 4D animals, euthanized animals, and rodent/bird feces infested ingredients into people food.  Pet food does not follow the same regulations as people food.  I guess it could be stated that pet food should follow the same regulations as people food - but certainly you must know they don't.

"pet foods are truthfully labeled"
Again, no.  Pet food labels and advertisements are as misleading as it gets.  Images of choice cuts of meats, fresh vegetables on the label - turn the bag or can over and you see nothing that comes close to choice cuts of meat in the ingredient panel.  Again, it could be stated 'pet foods should be truthfully labeled' - certainly you know many of them are not.

"everything used to make the food must be listed on the label"
No again.  Additives to ingredients added by the ingredient supplier do not have to be listed on the label.  The perfect (and dangerous) example is ethoxyquin added to fish meals and fish oils.  Fish meal suppliers add ethoxyquin prior to the meal becoming a pet food ingredient - 'e' is not listed on the label.

In reference to the video urging consumers/petsumers to report a pet food related incident, the statement the FDA can then take "quick action to eliminate the problem" is a concern.  While I agree all pet food related or suspect pet food/treat related incidents should be reported to FDA and to State Dept of Agriculture (and by the way I encourage everyone to do this) - the statement the FDA takes 'quick action' to eliminate the problem is not factual - at least not from a pet parent perspective.  I have personally followed up with dozens and dozens of pet owners that have reported a pet food/treat related incident to FDA.  Many of them shared that the FDA investigator was very kind and helpful - however, almost 100% of them have also shared that no follow up or no 'quick action' occurred.  All of these pet owners were left with a sick pet or a dead pet, significant vet bills, and no action by FDA.  Making that statement in the video would do nothing but hurt countless thousands of pet parents.  

If FDA's goal with this video is to shorten the great divide between petsumers and FDA - the entire video should be scrapped.  As it is, it will only strengthen the belief of educated petsumers that FDA does not care about our pets.  Might I suggest...a video following the investigation procedure of (as example) five different pet food related incidents reported to FDA.  Show in the video the investigative trail that FDA goes down.  Meeting with the pet parent, testing the pet food, speaking with the veterinarian and so on.  And be honest - don't make it 'Hollywood' or 'Once upon a time'.  Show the challenges of testing and trying to determine if it was a contaminant or a manufacturing issue and so on.  Perhaps provide pet parents with some assistance on how to determine what the contaminant or issue is.  Give us - as example - what the symptoms are of vitamin toxicity, mineral toxicity, and/or mycotoxin poisoning.  Give us helpful information!  The more we learn, perhaps we (pet parents) can be of greater assistance in future reporting issues and in turn, perhaps the contaminant will be found (saving lives).  

On a different note, day one of the AAFCO meetings a Dr. Ferrah (not sure about that spelling) stated to me that FDA meets with a pet owner advocacy group "several times a year".  He said it was Pet Food Safety Alliance.  The only organization I know of similar to that name is Pet Food Products Safety Alliance - Don Earl.  I contacted Don to confirm this and his response was no - FDA has never met with him or anyone from his organization.  So, can you provide me with the name of the consumer/petsumer organization that FDA meets with "several times a year"?  Would FDA be willing to meet with me and a handful of our pet parents several times a year?  As well, can you provide me with the proper spelling of Dr. Ferrah's name and his contact information; I would like to follow up with him.

On those nasty FDA Compliance Policies, can you provide me with the FDA science that proves ingredients sourced from 4D animals, euthanized animals, and rodent/bird feces infested foods provide nutrition to pets.  I'm not asking for the measurement of fat or protein of these ingredients, I'm asking for the science that FDA uses to determine these ingredients are safe for pets to consume and provide nutrients to pets.

And sorry - one more thing.  Can FDA make public the product pull information on pet foods - and promptly?  I believe it was you that shared with me a manufacturer is required to report to FDA within 24 hours of a product pull (when there is a health risk), can FDA please post this information for the consumer/petsumer's protection?


I hope you take the above feedback into consideration and I hope you will continue to keep the dialogue open.

Susan Thixton


I've already heard back from Eric Nelson, below is his response...

Susan, we must not live in the same part of the country. I returned to snow freezing rain and chilly temps. Your comments are detailed which will require a little time to ponder. Hopefully I can get back to you before the end of the month.

Eric


Thank you to FDA's Eric Nelson for promptly responding.   I'll keep everyone posted as I hear more.

 

Wishing you and your pet(s) the best,

Susan Thixton
Pet Food Safety Advocate
Author, Buyer Beware
Co-Author Dinner PAWsible
TruthaboutPetFood.com
PetsumerReport.com


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Comments (11)

Said this on 1-22-2012 At 03:06 pm

Good job, Susan!  So glad to have you on our side. Hugs and kisses from all our pets  :o)

Reader
Said this on 1-22-2012 At 03:16 pm

Absolutely an incredibly well articulated rebuttal of the proposed Pet Food Safety Video!!  So well said in fact, that if they choose to go ahead with it means the FDA remains in complete denial of the facts on record.  It proves they value (perceived) public relations instead of the public's welfare.  It shows they aren't accountable to, nor do they feel obligated to, the people who pay their salaries for the honest oversight that is supposed to justify their existence!  I hope they are really following your website now, and will indeed, read all pet parents' comments.  

Said this on 1-22-2012 At 03:21 pm

What a great service you have done to help provide our beloved pets with the very best we, as consumers, can provide for them.  Your attending the AAFCO meetings and relating these very poignant critiques will go a long way to help solve these problems and educate all of us.  You are a courages lady. My hat is off to you.  Thanks.   

joan
Said this on 1-22-2012 At 03:49 pm

I will be waiting for his response.  I hope he doesn't try to deny or sugar-coat the truth because we already know what the truth is.  I hope he tells us the direction he will go, to make pet food safe and appropriately nutritious

J King
Said this on 1-22-2012 At 05:22 pm

Great letter Susan!!  Thank you for speaking out for us.  But unless Mr. Nelson can bring about change that makes the statement "pet food follows the same regulations as people food" true in the real world, there's little we can do except home cook for our pets and hope there isn't too much FDA-speak about food certified for human consumption.

Said this on 1-22-2012 At 05:56 pm

It wouldn't be "pretty"?  I am enraged, just reading your comments back to him.  You make a good point, offering to "preview" it on your site for feedback.  I am grateful for your pressure on behalf of all conscientious pet parents.

I've written a few essays on the issue of pet food myself, and each of the points you single out, was immediately "angry," as you suggested to Mr. Nelson pet parents would be.

Late last year my cat suffered food poisoning after consuming a well-known "premium/holistic/grain-free" food.  At one point, I thought he had already died.  The manufacturer left me high and dry with a "we've determined we're not responsible" letter.  I submitted a(n) FDA "pet food incident report" and can tell you that months later, it has been met with zero response.

Tim
Said this on 1-22-2012 At 06:08 pm

The FDA caters to the financial interests of the industries that taint and poisen human foods. With this lack of credibility and integrity so well documented, how can anyone expect this bought and paid for group of industry insiders to maintain safety standards for our pet companions?

Donna
Said this on 1-22-2012 At 06:52 pm

Susan

I just came across you and your site a few months ago, and I am thrilled I did.  You have shed light on and helped me be more aware of the deception that happens in our furry family's world.    It's no consolation, but the FDA plays games with human food as well.  Mostly big corps buying silence for the wrongs they commit against us.  Thank you for all that you do.

Said this on 1-23-2012 At 11:47 am

BRAVO !!!!!!

Andrea
Said this on 1-23-2012 At 02:10 pm

Susan, I'm wondering if the video was intended for public release or for the pet food manufacturers?  If for the mfg, then stating that the ingredients MUST be listed on the label and the advertising MUST be truthful would be correct wouldn't it?  Wouldn't it be putting them on notice that they MUST follow FDA's guidelines as they would for people food?  Just curious.  That is what we really want them to do.  To put pet food manufacturers on notice that food has to be made of a higher standard and be equivalent in safety as human food (although sometimes I even ponder just how safe that really is since the age of pre-packaged junk food).  Thanks for standing up for us and taking them on!  You are appreciated more than you know! 

Susan Thixton
Said this on 1-23-2012 At 03:04 pm

No - this was for consumers.  I felt it was a (failed) attempt to soothe the anxieties of petsumers.  It was not good.  The uneducated petsumer might find comfort in it - but I felt it was a slap in the face to many - especially all of those that have experienced one of those pet food adverse events (resulting in death or serious illness of a pet).  It just wasn't factual. 

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