In late October, a consumer advocate started a petition on the “We the People” page of the White House website (www.whitehouse.gov). The petition requests that the Obama Administration instruct the US Food and Drug Administration to enforce a strict interpretation of the Federal Food, Drug and Cosmetic Act (FFDCA) as it pertains to suitability of ingredients for use in petfood or, lacking that, require a label disclaimer on all petfoods that do not meet the standards as set forth by the exact verbiage in the law.
Among other rights granted by the First Amendment of the US Constitution, people have the right “to petition the government for a redress of grievances.” The Obama Administration started the We the People page as a new means to file petitions electronically (see https://wwws.whitehouse.gov/petitions).
Any matter can be brought forth by this method, but there are conditions. For example, the petition must receive at least 150 signatures before it will become searchable on the website, and before the administration will consider its merits, the petition must receive at least 25,000 signatures within 30 days of posting.
It is assumed these thresholds are to prevent an individual or small group from potentially posting thousands of nuisance filings. However, if a petition meets these conditions, the White House promises to review it, send it to the appropriate policy experts for consideration and issue an official response.
The breadth of topics on the We the People site is fascinating. Petitions range from broad issues dealing with taxes, economics, religion, voting and political reform to very specific matters such as requests for pardons of incarcerated individuals and pleas to save the dunes sagebrush lizard under the Endangered Species Act.
An inordinate number of the 135 open petitions appear to deal with repeal or reform of existing marijuana laws. In fact, when a White House response to previous petitions regarding marijuana was not terribly sympathetic to the cause, several new petitions popped up demanding the dismissal of the policy expert that issued the official response.
A petition posted on the We the People site is limited to a 120-character title and 800-character description, so the petitioner must succinctly state its case. This petfood petition (http://wh.gov/blb) reflects more extensive comments made by the same person through a citizen petition filed with FDA in August 2010.
Briefly, the petition contends that under current FDA enforcement policy, petfoods are allowed to be processed using materials from diseased, downed and euthanized animals, as well as those containing rodent feces and insect infestations, which it sees in violation of FFDCA. “Food” under the law includes petfood, so when FFDCA states that adulteration of food includes any use of materials from animals that die by means other than slaughter, the law should apply regardless of intended species or consideration of whether a deviation from the law constitutes a true safety concern or simply aesthetics.
Notwithstanding (or perhaps more accurately, because of) FDA policies that dictate provisions for safe use of ingredients in animal feeds that usually would not enter the human food chain, the petition wants enforcement precisely as written in the law. Further, because consumers do not know these materials may be in petfoods, it asks that the labels for petfoods that do not meet FFDCA bear a warning statement to that effect. The suggested phraseology for the statement is, “Warning: This pet product could contain illegal ingredients and could put your pet’s health at risk.”
At the time of this writing, three days after the petition was posted, it had received approximately 400 signatures, or about 135 per day. Reportedly, many people have been having trouble logging on to the site to submit their signatures. I understand that some websites do not make it easy to interact, but considering that tens of thousands of supporters of marijuana law reform have been successful in signing petitions on the site, I find it hard to believe the process is too complicated.
Anyway, if that rate of signature collection continues, the petition will fall far short of the 25,000 required by the end of November. Personally, I’d like to see it reach that threshold if only to see the official response. To the best of my knowledge, FDA has yet to respond to the aforementioned citizen petition, so it would be interesting to see how the government views this matter.
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The intent was to educate regulators and industry about the Model Pet Food Regulations
Committees discussed key proposals such as a possible shift in the oversight of animal feeds
The mid-year meeting addressed several regulatory matters affecting petfoods
Processors should carefully develop, validate and implement an effective kill step to support production of pathogen-free petfoods
What you need to keep your manufacturing line clean, safe and contaminant-free
Safe, nutritious, tasty petfood requires careful handling and processing of raw meat ingredients
Seems to me the next petition that needs to be happen is one demanding "Dr" Dzanis be removed from this site. His comments are about as mature as my 5 year old. It shows total disregard and respect for pet owners. If you cant be a professional, the Pet Food Industry site should remove you. But Im sure they wont as your attitude is right in line with the pet food industry as a whole. I can safely say if you were my vet, you would be sent packing in a nano-second. Grow up Dzanis.
Dr Dzanis, I met you personally just a few months ago while attending your lecture at Superzoo. I am deeply disappointed that a man of your stature and credentials would not support legislation that would enforce regulations that directly affect the health and longevity of our pets. You, above all else, knows what can and does get added to our our pet's food, and yet you chastise efforts made to better the industry? Despite your underhanded disdain evident in this article, it cannot be denied that the petition represents the fast-approaching future of the pet food industry, where transparency and appropriate ingredients are highly valued. Are you afraid of becoming obsolete? Or is it that dogs and cats are merely livestock, worth only the monetary value that can be collected during their short lives?
Dr. Dzanis:You may not remember me from Cornell. I graduated from the College of Agriculture and Life Sciences with honors, majoring in Animal Science. My focus was nutrition. I also graduated from Cornell's Veterinary College in 1991.I am quite dismayed by your above response, especially from a Cornellian. Why aren't you speaking to the issue of what is actually in pet foods? You write that FDA has "provisions for safe use of ingredients in animal feeds that usually would not enter the human food chain" yet you do not address why it is fine for our pets to eat what is not safe for us... What really puzzles me is that the pet food industry is very quick to tell pet owners that feeding fresh, real food that is fit for human consumption is inappropriate. And if they are feeding it raw, it will surely kill their dogs and possibly even their family!Seems to me there is some serious spinning going on, and not the kind that happens at the gym.Laurie S. Coger, DVM
Dr. Dzanis:Your response to the above petition seemed to deal more with the rules and process of petition posting and signing than the issue raised. Why don't you take your paid pet-food-industry advocate hat off and put on your DVM hat and respond to the issues raised?
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