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.

I’ve seen a lot of nastiness, backstabbing, deceit, short-sightedness and propaganda in the ever-escalating battle over the mandatory sterilization of pet dogs and cats. It’s been particularly vicious here in California, where proponents of AB 1634 have shown they’re willing to say just about anything to push through their legislation.

They’ve even suggested this legislation — which exempts large commercial breeders and pet stores — will somehow help stop puppy mills, and outright blamed opposition on “greedy commercial breeders” regardless of the fact that it’s dedicated small hobbyists, show breeders and breeders of working dogs (such as search and rescue and law enforcement) who are fighting them. After all, why would the puppy millers fight them, since the law doesn’t apply to them in the first place?

Retired TV personality Bob Barker has been a longtime supporter of forced spay-neuter and AB 1634, and as is his right, he has spoken out on in favor of it. I think he’s on the wrong side of this issue, but I have no quarrel with him using his celebrity to bolster his position with lawmakers, or exercising his rights as a citizen.

But he issued a statement before the weekend that I do have a quarrel with — and I’m not the only one. (more…)

I’m sure Gina will have more to say about today’s Kentucky Derby, although perhaps she’s already saying it in the comments to her earlier post about the race. I’m here to talk about something she probably won’t touch.

As any of you who read my personal blog know, I’ve been spending way, way too much time over on Daily Kos, the largest and most popular political blog on the Internet. I’ve had an account there since the last presidential election, and did a lot of blogging there during the pet food recall, all from a political and regulatory perspective.

And if you read my blog, you also know I favor Barack Obama in the ongoing Democratic primary race. But I’m not mentioning that here in order to bring partisan politics to this blog, because that’s not what this is about. It’s about the Kentucky Derby, and the horse race of politics, and how disappointed I am that some of Obama’s supporters on Daily Kos don’t seem to share his vision for a new kind of politics in this country, because they’re willing to use what happened to Eight Belles at the Kentucky Derby today as some kind of cheap political metaphor. (more…)

Update 4/25: As mentioned by many of you, Evanger’s has now put a statement on their Web site:

Contrary to a news release issued by the FDA Thursday, April 24, 2008, Evanger’s continues to make and distribute its products with FDA approval. Evanger’s is working closely with the FDA and already has addressed many of the FDA’s questions. Evanger’s expects to have the few remaining FDA queries fully satisfied shortly.

No Evanger’s product has been recalled, nor is there any indication that any Evanger’s product is under-processed, unsafe, or contaminated in any way.

Here’s the rest.

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News release just in from the FDA:

Consumer Inquiries: 888-INFO-FDA

FDA Orders Pet Food Maker to Obtain Emergency Operating Permit

The U.S. Food and Drug Administration issued an order requiring that Evanger’s Dog & Cat Food Co., Inc., in Wheeling, Ill., obtain an emergency permit from the FDA before its canned pet food products enter interstate commerce.

A recent inspection revealed significant deviations from prescribed documentation of processes, equipment, and recordkeeping in the production of the company’s thermally processed low acid canned food (LACF) products. These problems could result in under-processed pet foods, which can allow the survival and growth of Clostridium botulinum (C. botulinum), a bacterium that causes botulism in some animals as well as in humans.

“As outlined in the Food Protection Plan, the FDA uses a risk-based approach to locate the areas of greatest risk for foods, and targets preventive controls and inspections to those areas, “ said Dr. Stephen Sundlof, director, Center for Food Safety and Applied Nutrition. “The FDA’s authority to issue an order requiring an emergency permit is an enforcement tool designed to prevent unsafe foods from reaching consumers.”

The FDA issues an “Order of Need for Emergency Permit” if the agency determines that a company fails to meet the regulatory requirements to process a product that does not present a health risk. For Evanger’s to resume business, the company must document that corrective actions and processing procedures have been implemented to ensure that the finished product will not present a health hazard.

Botulism is a powerful toxin that affects the nervous system and can be fatal. The disease has been documented in dogs and cats. Signs of botulism in animals are progressive muscle paralysis, disturbed vision, difficulty in chewing and swallowing, and progressive weakness to the body. Death is usually due to paralysis of the heart or the muscles used in breathing.

In light of human botulism illnesses and recalls that occurred due to under-processed hot dog chili sauce, and potentially under-processed canned green beans, FDA has urged all LACF processors to review their operations and the apply scientific principals and regulations that have been established to provide a safe product.

While FDA’s Center for Veterinary Medicine has authority over animal feed and foods, CFSAN is responsible for regulating all human and animal LACF processing. The two centers are collaborating on this enforcement action.

I was shocked to get a press release from the FDA that started out with these words (emphasis mine, but the missing period is theirs):

The U.S. Food and Drug Administration today issued a final regulation barring certain cattle materials from all animal feed, including pet food. The final rule further protects animals and consumers against bovine spongiform encephalopathy (BSE, also known as “mad cow disease”)

Can you imagine them even thinking about, let alone mentioning, pet food before the pet food recall? In the very first sentence, even.

The rest of the release was the usual kind of thing… blah blah, risk of BSE in the United States incredibly low, in fact, so low it’s amazing we’re wasting your time doing this, and please don’t look at the man behind the curtain fact that we actually prohibit farmers from testing their livestock for BSE in the first place, but honestly we care about you and your pets just not as much as agribusiness.

The entire release is under the jump. (more…)