The Pay Per View Regulation of Pet Food

The Pay Per View Regulation of Pet Food

 

Your tax dollars are paying for it, but you have no access to what you’ve paid for. Another huge absurdity for pet food consumers.

One of you great pet food consumers in Florida wrote their State Department of Agriculture asking for public access to pet food ingredient definitions. The response from Florida proves that consumers are the absolute last consideration of regulatory authorities. But perhaps even a bigger disclosure learned from Florida’s response to this consumer is that we (consumers) pay double for something we are never provided access to.

At the upcoming Association of American Feed Control Officials (AAFCO) meeting (July 30, 2018), discussion will include “confusing pet food names”. What this topic means is that industry has requested regulatory authorities to change the name of some pet food ingredients. Industry believes consumers are confused about ingredients such as by-products. (To learn more about this discussion click here.) A Florida pet food consumer wrote his Department of Agriculture requesting the agency take action on behalf of consumers. He asked for these ingredient definition names to NOT be changed – so not to further confuse consumers. And he also asked Florida to publish the legal definitions of all pet food ingredients on the Florida website (currently all consumers across the U.S. are provided no access to pet food ingredient legal definitions).

This is the response he received from the office of Florida Commissioner of Agriculture Adam Putnam (bold added for emphasis):

We have received your request and we are taking your concerns and suggestions into consideration regarding topics to be discussed at the AAFCO meeting. Regulators from FDACS will be present and we will do our best to make decisions and provide suggestions at the meeting based on facts regarding what we deem most appropriate for the industry.

Florida told this consumer they would act on what is “most appropriate for the industry” – not on what is most appropriate for consumers.

As absurd as it is, most educated pet food consumers know very well that regulatory authorities take little action to protect consumers. The above attitude from Florida was no real surprise.

But what did come as a surprise was this…

This consumer also asked Florida Department of Agriculture to provide free public access to pet food ingredient definitions. (Background information: every single pet food ingredient has it’s own legal definition that is very different from the definition of the same item in human food. Example chicken: chicken in human food means USDA inspected and passed meat; chicken in pet food can be anything from USDA inspected and passed meat, to chicken skin and bones (little to no meat), to USDA inspected and condemned chicken not suitable for consumption.)

Florida responded with:

In regards to your request for the Department to publish all pet food ingredient definitions on the Department website, this is a request we are unable to fulfill as the material is protected by copyright and does not belong to FDACS.  One option that we can present to you is that we can provide the information to one of our FDACS inspectors that is located close to you and we can allow you to view (but not copy) the information. If you would like to pursue this option, please let me know and I will make arrangements.

To explain just how absurd this response was, the Association of American Feed Control Officials (AAFCO) Official Publication (the book that contains pet food/animal feed regulations and ingredient definitions) contains 686 pages. Based on size of the book alone, it certainly cannot be read in a few hours. And much of the information in the book is written in a legalese language that often takes several reads to understand. To suggest a consumer can come to a state regulatory office and sit down and just read the book is ridiculous.

This consumer wrote back to Florida Department of Agriculture asking:

Can you explain to me why I, as a consumer, am not allowed to access, read, and copy the information regarding products currently marketed to me? This appears to me to be a way to keep the information under a virtual lock and key since I would have to make arrangements to meet your representative and possess an eidetic memory in order to recall said information when I needed it. The public needs to know in order to make informed choices about these products. As long as this information isn’t freely distributed, I will not trust ANY pet food label, nor the representatives who do not help the general public access this information freely.

(Such a great response!)

Florida responded back to him with (bold added):

FDACS has paid to purchase a few limited copies of these materials for our roles as regulators but we do not have the right to reproduce/copy/distribute them. This is the only reason I indicated that we cannot allow you to copy this information.

Yes, you read that correctly. Florida Department of Agriculture disclosed to this consumer that they themselves – a state government agency – have to purchase the book of regulations and ingredient definitions from AAFCO in order to perform their job as a regulator.

Looking at this significant issue closely…

#1 Florida Department of Agriculture (and every other state Department of Agriculture) is a regulatory agency charged with enforcing the information contained inside that AAFCO book. And they HAVE TO PAY FOR access to it. Have to pay for access to “these materials for our roles as regulators”.

#2 Each State Department of Agriculture that participates in the AAFCO process (which is most states) – actually write the regulations and definitions that AAFCO holds copyright privilege to. Consider this…your state government pays the admission fees to AAFCO meetings for multiple representatives of your state for two meetings a year ($375.00 per person for regulatory attendees, per meeting). Your state pays the salary of these individuals while they are performing work at AAFCO, and pays for all travel expenses. The state authorities write, discuss and vote on regulations and definitions. The government authorities do all the work that is published in the AAFCO book. BUT…your state still has to purchase the work their employees participated in from AAFCO.

#3 AAFCO earns a significant income from sales of this book. Per Guidestar.org, AAFCO earned $413,978.00 in 2017 from sales of the publication.

#4 AAFCO is a private corporation. It is NOT a government agency. In other words, a private corporation is making significant income on a publication that tax dollar supported government employees actually write.

#5 Because each State Department of Agriculture are tax dollar supported agencies, in essence consumers are paying for regulators to write the regulations and ingredient definitions and then paying again for each state agency to purchase the book their own work is contained in.

#6 But you as the consumer/tax payer – have no public access to what your tax dollars have paid for.

This does not only happen in Florida. For every state that participates in the AAFCO process (which is most states) – State Government pays the salary, admission and travel expenses of multiple representatives to attend AAFCO meetings (two a year). Each state’s AAFCO representatives (State Government Representatives) help write the regulations, help write the legal definitions of pet food ingredients. Yet – not one state provides consumers public access to the tax dollar paid work they performed.

And by the way, for the human food industry – consumers have free public access to all rules and all legal definitions. ONLY in pet food do consumers and regulatory authorities have to pay to access regulations.

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Wishing you and your pet(s) the best,

Susan Thixton
Pet Food Safety Advocate
Author Buyer Beware, Co-Author Dinner PAWsible
TruthaboutPetFood.com
Association for Truth in Pet Food

The Pay Per View Regulation of Pet Food
Become a member of our pet food consumer Association. Association for Truth in Pet Food is a a stakeholder organization representing the voice of pet food consumers at AAFCO and with FDA. Your membership helps representatives attend meetings and voice consumer concerns with regulatory authorities. Click Here to learn more.

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The Pay Per View Regulation of Pet Food

The 2018 List
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