pet connection

Tomorrow, Tuesday, May 13, 2008, in Gaithersburg, Maryland, the FDA will hold a public meeting intended to improve — excuse me, “discuss” — pet food safety standards.

As we wrote earlier this year, FDA is looking for pet food owner input on this matter prior to the meeting, and will also accept comments until June 13.

Here’s where it gets a bit tricky, however.

There has been a docket number change (new docket number is FDA-2007-N-0442), and I was not able to get a definite confirmation as to whether or not comments submitted under the old docket number (2007N-0487) are being included. Also, FDA had some problems with its online comment system.

If you submitted a comment, you can check to see if it was received here. There are currently only 23 comments listed.

I contacted FDA, and was told that if someone submitted a comment and doesn’t see it, they need to call the “reading room” and ask to have it scanned. The number is 301-827-6860.

If you want to submit a comment, it’s not easy. I know my way around the Interwebs pretty well, and it took me, oh, an hour to figure it out. But now that I’ve done that, I have a little map for you to follow.

First, go here.

There is a line that says “Meeting Being Planned to Obtain Public Input for Ensuring the Safety of Pet Food,” dated January 7, 2008. At the far right on that same line, there is a little yellow button in the “Add Comments” column. Click on it.

What is the meeting intended to cover? You can read the whole announcement here, but it’s pretty hard to slog through. Notice that the first part is aimed not at the general public but more at industry and regulatory agencies, and there’s also discussion of a second meeting about animal feed regulation on May 14. All of that is coverered before you get to the part on pet food and the kind of input they’re looking for.

Section A basically sets forth the proposal to make the labeling and other requirements of pet food match not human food, but animal feed:

(B)ecause pet food is well-integrated into the overall animal foods and feeds industry, FDA is concerned that certain new requirements, if limited to pet food only, would be impractical to implement, difficult to enforce, and would not effectively provide the safety enhancements intended by FDAAA. Furthermore, because the standards mandated by FDAAA do not currently exist for any animal food or feed, limiting new requirements to pet food only would fail to address the broader food safety concerns associated with food intended for other animal species, particularly food-producing animals.

FDA is interested in obtaining input from interested stakeholders and the public as to whether the ingredient standards and definitions and processing standards should be developed for all animal feeds. There appears to be little or no difference between ingredients intended for use in pet foods and those intended for use in other animal foods and feeds. Therefore, the agency believes the most appropriate course of action is to develop ingredient standards and definitions and processing standards for all animal feeds, including pet food. FDA believes that such an approach would more effectively carry out the safety objectives of FDAAA, and the broader human food safety provisions of the Federal Food, Drug, and Cosmetic Act.

I can now see every rancher and agribusiness interest in the country going excuse me, what? We’re supposed to label livestock feed the same way some latte-sippin’ liberal out in California needs to have their organic teacup poodle chow from Whole Foods Market labeled? Say what? Talk about de-fanging this whole proposal before it’s even in its final form.

When you get to Section B, where the considerations are actually spelled out, including things like nutritional labeling similar to what’s on human food packaging, it’s easy to see how rolling this into an animal feed regulation is going to seriously dilute what can be done to improve pet food labeling. You tell me what you think the chances are that we’re going to see livestock feed labeling issues like these be taken seriously?

1. How could the nutritional information (e.g., guaranteed analysis, nutritional adequacy statements/life-stage claims) already present on pet food labels be improved?

2. How could the ingredient information already present on pet food labels (i.e., the ingredient list) be improved?

3. How could the current feeding instructions/recommendations section already present on pet food labels be improved?

4. Should feeding recommendations be required on the labels for all types of pet food?

5. Should a Nutrition Facts box, similar to the format that appears on human food labels, replace the current Guaranteed Analysis that currently appears on pet food labels? If so, how could this Nutrition Facts box be made to clearly distinguish it from human food labeling?

6. What other information should be required on pet food labels that is not generally present on pet food products sold in the United States?

7. Are there existing state laws, regulations, guidelines, or other models that FDA should consider when drafting the proposed pet food labeling?

In case anyone’s keeping track, I am adamantly in favor of a “yes” answer to number 5. There’s no consumer-benefiting reason to use the “guaranteed analysis,” which you need a calculator to get any useful information from, instead of the simple calories per serving, serving size, calcium/fat/protein/carbohydrate per gram, and other useful, easy-to-understand facts that human food is required to include. It serves only an industry that wants leeway in what it includes in the food from batch to batch to do it the other way. It’s not acceptable to me as a consumer.

And I can’t even begin to understand why the box needs to “clearly distinguish it from human food labeling.” Huh? I don’t know, put “PET FOOD NUTRITIONAL LABEL” on it?

Section C discusses issues related to standardized ingredient definitions.

Section D returns to a discussion of combining regulation of pet food with regulation of animal feed. The basic description of animal feed systems is here, and while it’s extremely vague, it’s easy to see that simply writing one standard for both is going to make any kind of meaningful consumer reform of pet food labeling and processing far more difficult both to write and to “sell.”

Please let us know if you submitted a comment, if it’s showing up on the comments page, and your thoughts on these proposed changes.