So many issues from AAFCO meeting – Truth about Pet Food

From the worrisome African Swine Fever to DCM to excess vitamin D to controversy…a lot happened at this AAFCO meeting.

At the opening session of every AAFCO meeting, everyone is introduced including all regulatory authorities. When the FDA officials were to be introduced (45 FDA representatives in attendance), this slide was put up on the large screens in the room:

Though our group enjoyed the pun at FDA’s expense, it seemed inappropriate for AAFCO to poke fun at FDA.

From the Sunday event on the Food Safety Modernization Act laws, the event provided this slide on “Rising animal food safety issues“:

The only details provided on African Swine Fever was the following:

The information they provided states that dogs and cats are not at risk, however we can safely assume that a great deal of pork meal ingredients used in US pet foods are imported from China where this disease is currently prevalent. If your pet food contains the ingredient “pork meal”, and you are concerned, call your manufacturer and ask them for the “Country of Origin” of the pork meal (or for that matter any pork ingredient).

Regarding DCM, the slide included some Big Pet Feed promotion:

There is NO evidence that proves a pet food “made by a well-established manufacturer that contains standard ingredients” is a DCM prevention. In fact, although this slide includes the label “” – the FDA has determined the most common ingredient in pet foods linked to DCM is chicken. Further, “well-established manufacturers” are included in the FDA list of manufacturers (Mars, Purina, Diamond, Hills). It was VERY puzzling why false/misleading information was presented by a AAFCO representative.

And the slide from Rising Animal Food Safety Issues on excess vitamin D:

In a later discussion of future inspections, the discussion included the potential for inspections of pet food retailers (not only manufacturers – pet food stores). AAFCO representatives surveyed Department of Agriculture (state) members and provided this slide of the current inspections of retail pet food stores:

And as you can see from the slide below, their major concern was pet food stores that sell minimally processed pet foods:

This was blatantly bias – as the same “research” was not performed for retail stores of highly processed pet foods which statistically have caused significantly more human and pet illnesses.

There was a discussion of prescription pet foods that was (strangely enough) presented by AFIA – Animal Feed Industry Association, a trade association.

AFIA asked AAFCO to develop rules/laws governing prescription pet foods – as currently there are NO laws regulating them any differently than typical pet foods. I fully agree with this stance and went to the microphone to share with AAFCO that the current “FDA policy” that regulatory authorities regulate Rx pet foods under is NOT law. An FDA “policy” allows Rx pet food to be treated as a drug, even though no clinical trials or manufacturing safety requirements of drugs are required – and this FDA “policy” is not legally binding. Legally speaking, the FDA policy that allows Rx pet foods to charge exorbitant prices and require a prescription from a veterinarian to purchase is not worth the paper the policy is written on; it’s not legal.

Dr. Judy Morgan went to the microphone and expressed concern as well. She told AAFCO that as a practicing veterinarian she could not have confidence in a product that was treated like a drug but not held to any requirements of a drug. (Representatives of Rx pet food manufacturers were sitting behind us and were heard making jokes about Dr. Judy Morgan’s sentiment.)

It is unknown if AAFCO will take any action.

During the Pet Food Committee meeting AAFCO provided more details of consumer surveys performed by AAFCO regarding potential pet food labeling updates. The following slide was presented on potential warning statements for pet food. On the left side of this slide is the possible warning statement for a raw pet food and a kibble pet food:

Though not included on the slide, but stated at the meeting – the pet owners surveyed took little issue with the warning on raw pet food because they already understood safe handling is necessary when dealing with raw meat. But the pet owners surveyed were shocked that the same safe handling is necessary with kibble pet foods, something they had no understanding of at all.

And again in the consumer survey results, AAFCO learned that consumers has no understanding of meat meal ingredients:

This emphasizes our concerns brought to FDA of consumers having no public access to the definitions of pet food ingredients (including the definition of chicken meal discussed here). AAFCO owns the legal definitions and charges any and everyone $120 a year for access ONLY due to a agreement between FDA and AAFCO.

In another discussion was the following concern of some pet food manufacturers claims in marketing or on labels their product contains 50% or 60% or whatever percentage of meat when actually those numbers are inflated. Such as if the pet food includes meat meal ingredients, those are moisture removed ingredients. The claims of 50% meat (or other high meat claims) are sometimes based on miscalculations of the manufacturer by adding high levels of moisture back into their total meat calculations for the meat meal ingredients misrepresenting to the consumer an inflated ‘meat’ percentage than what is actually in the pet food. AAFCO asked manufacturers (in red below) to make these claims based on “total weight”.

The bison/water buffalo issue was finally defined at this meeting too. Pet food labels that previously stated “buffalo” will now be required to distinguish between the American Buffalo (or Bison) and Water Buffalo (commonly sourced from India). Labels will be required to state ingredients as “Bison” or “Water Buffalo”, though it is unknown how long manufacturers will be given to update labels.

Another issue of concern that happened at this meeting doesn’t directly effect pet owners, but it does indirectly. During the Ingredient Definitions committee meeting was discussion of the legal definition of the feed ingredient “Oat Fiber“. Several industry suppliers/manufacturers of this ingredient spoke out against the AAFCO definition claiming it was a definition specific to ONLY one manufacturer. They shared if AAFCO approved the ingredient, their businesses would be severely damaged. And then an attorney representing one of the other manufacturers (whose ingredients would not meet the new AAFCO definition) spoke. He quoted AAFCO policy that states the organization will not define ingredients that are specific only to one manufacturer – written in AAFCO official procedures. This attorney once again reminded AAFCO if they approve this ingredient definition, it would be proprietary to only one manufacturer and that is a violation of AAFCO written policy. AAFCO ignored their own policies, AAFCO ignored the multiple other ingredient suppliers who paid their $500 to attend and voice their opinion – and AAFCO approved the ingredient definition that was specific to ONLY one supplier excluding all the others.

It would not surprise me if we soon hear of several new lawsuits against AAFCO over this. Their actions were very biased.

Another AAFCO meeting done. Next one is scheduled for January 2020.

Susan Thixton
Pet Food Safety Advocate
Author Buyer Beware, Co-Author Dinner PAWsible
Association for Truth in Pet Food

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