This is an important article about how the pet food industry stonewalls consumers and doesn’t allow them access to information about the food they put in their animals’ mouths. We hope you find this helpful.
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FDA directly lied to us for 6 weeks, denied pet owners a voice. What is it going to take for pet owners to be provided with access to the legal requirements of pet food? What is it going to take for pet owners to be able to make informed pet food decisions?
In human food, should you wish to research the legal requirements of chicken in your TV dinner – you have public access to a multitude of laws. Anyone can read the legal requirements of every detail of chicken in human food. Human food labeling laws – public. Human food nutritional information – public.
To the contrary, almost every detail about the legal requirements of a cat food or dog food is kept hidden from pet owners. The Association of American Feed Control Officials (AAFCO) owns and copyright protects the nutritional requirements of pet foods – no pet owner can research how much protein or calcium or vitamin D is required. No pet owner can read the legal definition of chicken or beef or pea protein…AAFCO owns and copyright protects that information too.
The injustice of pet owners being denied public access to information about pet foods and treats ONLY happens because of an ‘agreement’ between FDA and AAFCO – officially termed Memorandum of Understanding 225-07-7001. Because a tax dollar supported government agency (FDA) agreed to collaborate with a private corporation (AAFCO), pet owners have NO public access to information that would help them understand the products they feed to their pet.
We (really) tried…but FDA slapped us in the face.
The AAFCO/FDA Memorandum of Understanding was set to expire October 1, 2019. We (AssociationforTruthinPetFood.com/TruthaboutPetFood.com) started communication with FDA regarding the renewal of this concerning agreement in January 2019 – 9 months in advance. On January 28, 2019 we told the FDA “One of our concerns is due to this agreement FDA has with AAFCO, pet owners are denied public access to all regulations governing pet food and significantly all pet food ingredient definitions. Pet owners are forced to pay AAFCO $120.00 per year to even understand what ingredients are included in their pet’s food. Let it be noted here – as an official stakeholder representative of pet food consumers – we are contesting the MOU as it is currently written and wish to collaborate with FDA on any renewal or future MOUs between FDA and AAFCO.”
Knowing the clock is ticking to the renewal of the AAFCO/FDA agreement, FDA waited two months to respond (April 5, 2019) – completely ignoring our concerns of pet owners being denied public access to pet food laws. Click Here to read FDA response.
We continued to request a meeting with FDA – specifically we discussed our concerns about the AAFCO/FDA agreement with Mr. Neil Kaufman, Health and Human Services (division of government FDA is under) mediator. In early June, 2019 – Mr. Kaufman told us in a phone conversation that Tracey Forfa (Deputy Director of FDA Center for Veterinary Medicine) would provide us a “facilitated dialogue” regarding the AAFCO/FDA agreement.
On June 12, 2019, as instructed by Mr. Neil Kaufman, we emailed Tracey Forfa regarding our promised meeting. Click Here to read those emails confirming FDA agreeing to discussing the AAFCO/FDA Memorandum of Understanding agreement with consumer representatives.
FDA continued to delay our promised meeting for 7 more weeks – over 25 separate emails, using every excuse in the book.
And then on August 1, 2019 – FDA’s Tracey Forfa sent us a message telling us “we wanted to let you know that the MOU with AAFCO has been renewed.” FDA renewed the agreement with AAFCO, without giving pet owners a voice in the agreement as they had promised. Click Here to read this email.
But…
We later discovered that FDA had been lying to us for 6 weeks. FDA had renewed the AAFCO Memorandum of Understanding agreement six weeks BEFORE – on June 20, 2019 – without telling us, and all while continuing the ruse that pet owners would be provided a voice in the renewal.
All of the following emails were sent back and forth with FDA regarding our promised meeting – AFTER the FDA had secretly renewed the agreement with AAFCO without telling us/without giving pet owners a voice in the renewal.
June 25, 2019 from Susan Thixton (ST) to FDA Tracey Forfa (TF) – asking for meeting date
June 27, 2019 from FDA Jessica Zeller (JZ) to ST – “Please find attached letter regarding the proposed meeting between you and FDA…” (Click Here to read.)
June 27, 2019 from ST to FDA JZ – explanation of previous correspondence with Tracey Forfa.
June 28, 2019 from FDA JZ to ST – “Can you please give me a bit more information about your proposed areas of discussion related to the MOU?“
June 28, 2019 from ST to FDA JZ – providing details to all previous correspondence regarding promised facilitated dialogue regarding MOU
July 2, 2019 from FDA JZ to ST – “open to scheduling an in-person session” on July 11
July 2, 2019 from ST to FDA JZ – due to late date, waiting to hear from attorney if time is still available
July 3, 2019 from FDA JZ to ST – provided potential time of meeting as 2:00 PM or after
July 3, 2019 from ST to FDA JZ – informed JZ waiting to hear from attorney
July 3, 2019 from ST to FDA JZ – because of late notice, we cannot meet on July 11. Suggested during AAFCO meeting or dates in August
July 5, 2019 from FDA JZ to ST – agrees to ask CVM regarding meeting during AAFCO
July 9, 2019 from FDA JZ to ST – No, during AAFCO meeting will not work – “will have to get back to you on future possibilities”
July 9, 2019 from ST to FDA JZ – will check with my attorney and let know
July 9, 2019 from ST to FDA JZ – suggest a day within the week of August 19th
July 12, 2019 from ST to FDA JZ – asking for update on meeting
July 16, 2019 from FDA JZ to ST – CVM states our meeting regarding the MOU “overlaps” the Answers Pet Food lawsuit. “CVM staff will be unable to participate in a facilitated discussion regarding issues related to the lawsuit”
[Comment: This excuse to deny our promised meeting by FDA was absurd. The Memorandum of Understanding agreement between FDA and AAFCO has absolutely nothing to do with our concerns of the agreement.]July 16, 2019 from ST to JZ – we express we are confused by previous email. Our MOU discussion is not related to Answers pet food lawsuit.
July 17, 2019 from ST to JZ – “since FDA appears to be refusing to discuss the MOU with pet owner representatives based on an unaffiliated lawsuit, does this also mean that the current MOU will not be renewed until the unaffiliated lawsuit is settled?”
July 17, 2019 from JZ to ST – “Are you comfortable with me sharing this request with CVM?”
July 17, 2019 from ST to JZ – “Yes“
July 23, 2019 ST to JZ – asking again about meeting regarding MOU
July 23, 2019 JZ to ST – checking with CVM
July 26, 2019 JZ to ST – “do not have a clear answer back on this one but I expect to have more information early next week”
August 1, 2019 ST to JZ – “past promised time of ‘early next week’, when will meeting occur?”
August 1, 2019 JZ to ST – waiting to get “a final decision conveyed from CVM”
Over 25 emails, the FDA knowingly led us to believe pet owners interests would be considered BEFORE the Memorandum of Understanding would be renewed. They directly and intentionally lied to us…in 10 separate emails…all AFTER the Memorandum of Understanding was signed and renewed.
What is it going to take?
What do we have to do for pet owners to have access to vital information about their pet’s food that the US government requires them to have access to? What is it going to take for pet owners to be able to make informed pet food decisions?
In no uncertain terms, the Memorandum of Understanding Agreement between FDA and AAFCO denies the Freedom of Information rights of every single U.S. pet owner. No pet owner can make informed decisions about their pet’s food without public access to the regulations and legal definitions of pet food ingredients.
What is it going to take?…who knows. But, please send a message to FDA asking them to rescind MOU 225-07-7001 until all pet food regulations and legal definitions are public information. Email: AskCVM@fda.hhs.gov. Also, please send a message to your representatives in Washington DC demanding that pet owners have public access to all pet food regulations and legal definitions – tell them to require FDA to rescind the agreement with AAFCO that denies our Freedom of Information rights.
Wishing you and your pet(s) the best,
Susan Thixton
Pet Food Safety Advocate
Author Buyer Beware, Co-Author Dinner PAWsible
TruthaboutPetFood.com
Association for Truth in Pet Food
Source for this article.
