Last Friday I was honored to have the opportunity of speaking at a public meeting held by the federal Food and Drug Administration (FDA) in Sacramento regarding the recently proposed rule that many hope will make sweeping changes to animal food regulation under the Food Safety Modernization Act.

The meeting – the third and final such gathering around the country to discuss the proposed regulation – attended by quite a number of officials from the FDA, including Dr. Dan McChesney, director of the Office of Surveillance and Compliance at the FDA Center for Veterinary Medicine, were there to to listen and respond to public questions and comments about the proposed rule for animal food.

All information and data submitted voluntarily to FDA during the public meeting become part of the administrative record for the rulemaking and as soon as a transcript is available, it will be accessible at http://www.regulations.gov Docket No. FDA-2011-N-0922, and once the recording has been made 508 compliant, it will be accessible at FDA’s FSMA Web site at http://www.fda.gov/Food/GuidanceRegulation/FSMA/default.htm.

In a room, filled to capacity with animal feed and pet food industry stakeholders, government officials, and media, I stood and read this statement on behalf of the Association for Truth in Pet Food and for all Americans who shares their homes and their lives with pets:

Thank you for the opportunity to comment on the proposed Current Good Manufacturing Practice and Hazard Analysis and Risk-Based Preventive Controls for Food for Animals.

My name is Mollie Morrissette, I am the co-founder of the Association for Truth in Pet Food, the largest pet food consumer stakeholder group in the United States, representing over 82 million U.S. households that that share their homes with pets. We provide a national forum to discuss current and emerging issues and information pertaining to all aspects of pet food safety.

While the efforts of government regulatory agencies often are credited with making the U.S. food supply among the safest in the world, I think we can all agree the system needs improvement, in particular concerning the animal food sector. It is critical that decision makers understand the relationship between animal health and food safety, which is a complex association requiring careful evaluation of many variables.

The Centers for Disease Control estimate that each year in the United States 48 million people (1 in 6 Americans) gets sick, 128,000 are hospitalized, and 3,000 die each year from foodborne diseases, a health burden that is largely preventable. Yet, unlike statistics kept for human foodborne illness, the burden of pet foodborne illness remains unknown.

What we do know is that nearly three-quarters of all U.S. households share their homes with pets and American’s are expected to spend $21.6 billion on pet food in this year alone.

Because so many American’s share their homes with pets, it is important to be cognizant of the frequent confluence of human and animal food ingredients and the risks they pose, to not only pets, but to the people living with them. As example, the Journal of Pediatrics published that human Salmonella infections were linked to contaminated dry dog and cat food, confirming that exposure to tainted pet food also made humans sick – including many children.

Six years following the largest pet food recall in U.S. history, when more than 8,500 cats and dogs died from eating contaminated pet food, Congress enacted the Food Safety and Modernization Act (FSMA) the most comprehensive reform of our nation’s food safety laws and regulations in more than seventy years.

That single event, the intentional adulteration of a pet food ingredient, exposed deep flaws in our food safety system. When the same contaminant was found in infant formula, it heightened public and media scrutiny of the entire food safety system and left American with a chilling thought: that the very same toxin that killed thousands of pets could kill them as well as their children, triggering Americans to question the safety of all food, not just pet food.

Although the proposed rule is similar to FDA’s Current Good Manufacturing Practice and Hazard Analysis and Risk-Based Preventive Controls for Human Food, there are significant differences in the way the two rules address relevant hazards.

Although there are many reasons why it would be of benefit to have separate rules to address the unique needs of animals, the intention of FSMA was to assure the safety of all food whether for man or other animals. However, it appears as if the Agency has selectively modified the applicability of those laws to adapt to the needs and requirements of the industry that makes the food, rather than to the animals who will consume it. As example, by the allowance of “waste” material in animal food, which by definition is an adulterant.

Despite the statute, the FDA makes a disturbing proposal: to allow adulterated material in animal food. In the proposed food for animals rule FDA redefines the meaning of an adulterant: “In some facilities, “waste” from human food production, such as by-products that may not be edible for humans, or lack nutritional value for humans, are used, or sold for animal food. Many species of animals have different digestive systems and nutritional requirements than humans, thus allowing for this use,”  and “that human food waste that is used for animal food would be treated as “food” for the purposes of its animal food use and as “waste” for the purposes of its role in human food.”

Most of us can agree that CGMPs should include rigorous adherence to sanitary manufacturing practices, and the Agency has provided extensive guidance on in the proposed rule on how to reduce insanitary manufacturing practices and how to protect against food becoming contaminated. Yet, it is baffling, even illogical, that the Agency has made the allowance for “waste” material in those same animal food facilities.

Domestic animals are perhaps the most vulnerable population of sentient beings. Under the law, they are the property of humans and enjoy extremely limited protections from abuse and neglect. Animals receive legal protections only when human, animal interests align, and when they conflict, laws are sculpted to further man’s interest at the sacrifice of the well-being of animals.

In this context, it is important to remember that FSMA was born out of the death of thousands of American pets – a result of the intentional adulteration of their food. The tragic irony is, that while those pets brought about the most significant advance in food safety in seventy years, has largely been forgotten as proposed rule for animal food applies completely separate and disparate standards for food for animals.

Like the millions of Americans who share their homes with pets, our hope for a better future where we can be assured of the safety of pet food rests entirely with FSMA. However, that dream will never be realized if significant changes are not made to the proposed rule. We ask you to consider modifying the proposals in favor of implementing this landmark law to bring about the change necessary to modernize the food safety system –- not just for man, but for the pets, we share our homes, and our lives with.

Thank you for considering my comments.

I got a mention in Veterinary Information News Network, which was nice:

…While the tone of the meeting was largely cooperative and respectful, not everyone was thrilled with the proposed changes.

Mollie Morrissette of the Association for Truth in Pet Food, an advocacy group for pets and consumers, expressed worry that the differing standards for animal and human foods would lead to lax standards in animal feed regulation. On the flip side, several representatives from companies in the animal feed industry expressed concern that the two standards were not different enough.

SOURCE: Animal food manufacturing overhaul aired