Fans of the band Asleep at the Wheel are likely familiar
with its version of the song "Across the Alley from the Alamo"
(much older folks will remember it as a Mills Brothers song).
In the case of the Association of American Feed Control
Officials (AAFCO) January mid-year meeting in San Antonio,
Texas, USA, it was right across the street from the Alamo. In
the shadow of this symbol of perseverance in times of
adversity, AAFCO deliberated on petfood regulatory matters.
After considering the report and recommendations of the
Calorie Statement Working Group, the AAFCO Pet Food Committee
(PFC) accepted, at least in principle, the American College of
Veterinary Nutrition proposal to require mandatory calorie
content statements on dog and cat food labels. It did not
accept any specific regulatory verbiage, however.
Still in question is whether this amendment should apply to
all dog and cat food products as originally proposed or whether
there should be exceptions (e.g., supplements and treats). A
new working group has been assigned to look at this. In fact,
PFC combined this group with another one assigned last August
to look at the issue of weight management/control claims and
develop a comprehensive approach.
Small business policy?
A new issue brought before PFC is whether there should be an
AAFCO policy regarding deviation from strict compliance with
state labeling or registration requirements for small
businesses such as pet bakeries and sellers of homemade treats.
The issue is that many of these modest enterprises are not
aware of the existing state requirements or find them too
burdensome, thus failing to register and subsequently avoiding
all regulatory scrutiny.
There was consensus among the attendees of the need for more
education and outreach, but less of a meeting of the minds as
to whether and what exceptions to the rules may be appropriate.
However, there is precedent in the Food and Drug Administration
(FDA) and US Department of Agriculture to make some regulatory
exceptions for small businesses. A new working group has been
formed to explore these matters and make recommendations.
The PFC formed yet another working group to look at the
proposed labeling for raw milk products as recommended by the
AAFCO Feed Labeling Committee. Also, the deliberations of the
expert panel in reviewing and revising the AAFCO Dog and Cat
Food Nutrient Profiles and feeding trials are continuing, as
are plans for AAFCO to host a Petfood Regulatory Workshop in
conjunction with the annual meeting in August. Finally, it was
reported that a revised edition of the AAFCO Petfood and
Specialty Petfood Labeling Guide is now available for purchase
from AAFCO's web site (www.aafco.org).
The Model Bill & Regulations Committee (MBRC) had a
number of action items on its agenda but became quickly bogged
down during discussion of the recently drafted Model Good
Manufacturing Practice Regulations for Feed and Feed
Ingredients. This was sent for consideration from the Feed
Manufacturing Committee (FMC) after years of deliberation.
The document raised a number of concerns for MBRC, but most
notable is the draft regulations' definition of adulteration.
It varies significantly from the definition for the term in the
Model Bill and, for that matter, from the Federal Food, Drug
and Cosmetic Act. The reported intent of FMC in drafting it
this way was to focus on cases of adulteration having direct
safety consequences while ignoring those that do not (e.g.,
viable weed seeds).
I don't think it's prudent or workable to have two AAFCO
documents with two different definitions for the same term; it
can only lead to confusion and inconsistent interpretation.
MBRC has requested a group comprised of members from both MBRC
and FMC be formed to resolve these concerns.
Not ingredient names
The item with the most potential to affect petfoods
discussed by the Ingredient Definitions Committee was the
proposed feed terms for various forms of carbohydrates, namely
fructans, starch and sugars. Of concern was the possibility of
misinterpretation of intended use of these terms. They are
intended to allow for claims and guarantees relating to the
concentrations of these substances in a product.
Current AAFCO policy does not consider claims for
carbohydrates to be necessary or meaningful, since it is a
vague term that comprises a large category of substances.
However, use of these more precise terms on the label could
have nutritional merit. The terms are not intended for use as a
part of an ingredient name, though. The addition of a
parenthetical "(nutrient)" after each term in its listing in
the AAFCO Official Publication will distinguish these terms
from those allowed to be used as part of an ingredient
nameusually distinguished by the parentheticals "(part)" or
"(process)" in its listing.
Longest acronym award
Perhaps the biggest topic discussed within several
committees was the new federal legislation affecting petfood
safety and labeling (see my December 2007 column). AAFCO has
formed a multi-committee Coordination Task Force to deal with
matters pertaining to the Food and Drug Administration
Amendments Act of 2007in doing so creating the longest acronym
I've seen in recent years (FDAAAAAFCOCTF, pronounced
eff-dee-aaaaay-eff-coke-tif). This task force will serve as the
liaison between AAFCO and FDA.
It gives more direct control to CVM in establishing and maintaining ingredient definitions
Committees discussed key proposals such as a possible shift in the oversight of animal feeds
The intent was to educate regulators and industry about the Model Pet Food Regulations
Public meetings invited comments and provided updates
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