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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