FDA Drops the Ball on Pet Food Recalls and Early Warning Notification System!

Whatever Happened to the Food and Drug Administration’s Animal Feed Safety System?

On the heels of the 2007 pet food scandal the shamed-faced FDA scrabbled to regain its composure by attempting to develop animal feed safeguards. As a result, in November of 2007 the FDA released its Food Protection Plan, aptly named the Animal Feed Safety System, or AFFSS. Unfortunately, rather than take responsibility the FDA offers us a spoonful of pabulum by referring to America’s previous safety record for animal feed. Conversely the FDA’s only mention of what really prompted their action is, “the public became alarmed last year when imported feed ingredients, contaminated with melamine and related compounds, were used in pet food, which resulted in sick dogs and cats.”

That is of course an understatement. Dogs and cats did not just become ill, they died! And America’s track record for animal feed safety may be “good” compared to third-world countries but this is America and Americans expect and demand higher safety standards. It could be said that it took the death of thousands of innocent American pets to get the FDA to take action on imported and domestic pet food products.

Supposedly the FDA Food Protection Plan’s intent is to identify potential food hazards before damage occurs. Here is the FDA’s own definition of the Animal Feed Safety System’s directive:

A risk-based, preventive animal feed safety program [that] will require producers and distributors of animal feeds to take into consideration hazards, whose presence in or introduction into their feeds pose an unacceptable risk to animal or human health and to develop a plan to prevent or eliminate, or reduce to an acceptable level, those hazards.

However, FDA bureaucracy enjoys adding more acts, programs, and titles, just to keep things complicated. So, not only is there an AFSS but the FDA Amendments Act of 2007 was passed to put the pressure on the FDA itself to “improve the safety of pet food and ingredients¹.” Title 10 of this act requires the FDA to establish, “by regulation, ingredient standards and definitions, processing standards, and labeling standards—including nutritional and ingredient information—for pet food. It also requires the FDA to establish an Early Warning Surveillance and Notification System to identify adulteration of the pet food supply and illness outbreaks and to notify veterinarians and other stakeholders of pet food recalls.²”

Confused by all the abbreviations, programs, titles, and acts? You are not alone! It’s no wonder that it takes a whole team of people to keep up with it all. This team is the Center for Veterinary Medicine (CVM), also part of the FDA. In April 2008 the CVM filed its 3rd version of the AFSS Framework Document. The idea was to identify and plug in any gaps found in the original framework document. The bottom line is, what have Americans received thus far? Revisions and more revisions — all with the idea of improving the initial AFSS food protection plan.

Currently, there are still no enforceable regulations to protect pets from food contamination. Yet, it is well over a year since the deaths of thousands of America’s pets that spurred the FDA to set up the AFSS in the first place. Never mind that the tainted pet food in early 2007 resulted in a 24 million dollar lawsuit. Or that there is still no early warning notification system in place. So when will regulations for ingredients, processing, and standardization of feed labels be introduced? And, when will an early warning notification system be in place? Your guess is as good as the FDA’s!

¹2008 - Volume XXIII, No. III, FDA Newsletter

²2008 - Volume XXIII, No. III, FDA Newsletter

I deserve healthy, safe pet food standards, don't you think?