Save all pet food do not return it for a refund. Only by petting and being near a given breed can you determine how much you will react, if at all. 33. If FDA is truly guided by FSMA and FD&C Act (instead of acting independent of law), there should be no differences between rulemakings of animal food and human food. Dander and protein can also be directly transferred to you when you pet your dog or if your dog licks you. b) Since veterinarians do not have the Centers for Disease Control to provide guidance to diagnose a food related illness (as human doctors are provided), we suggest FDA provide practicing veterinarians with on-going education to do such. http://salsa3.salsalabs.com/o/50865/p/dia/action3/common/public/?action_KEY=12303. 10. Dr. Klein points out that because smaller breeds have less of everything, they will also create less dander than larger breeds. Click Here to learn more about the failures of the U.S. pet food regulatory system. American . The proposed revisions did not address the disclosure of ingredient additives introduced by the ingredient supplier that are not required to be listed on a pet food label. What consumers need to demand is labeling that is He told me that for years hed thought I was just a tiny bit crazy because of the way I researched everything that our dogs ate ( I am, after all, a libraian and research everything ). Proposed Subpart FRequirements Applying to Records That Must Be Established and Maintained FDA includes Public disclosure as a proposed requirement of all records that would be required by the various proposed provisions. Since every person is an individual, every allergic response will be different. Policy. An overview of the categories, styles, legal requirements and recall data of commercial pet food in the U.S. Click Here. Size and Revenue thresholds must not excuse compliance, otherwise the integrity (effectiveness) will be undermined. Example to why such protection to the foods warehoused is needed is the 2008 seizure of pet foods warehoused at a Petco facility in Joliet, IL in 2008. Chinese imports? If something has a greater chance of triggering a reaction, its simply considered allergenic.. My notes on these proposed regulations. Are PF companies (PFCs) satisfied with average term lifespans, or to they aim for maximum? . There should also be a mandatory reporting system put into place for food borne illnesses and the offending food should be sent to a lab for testing. Heres my receipt number for my public comments: 1jx-88se-rew5. Its possible to be allergic to the pollen on your dogs coat when they go outdoors. . AAFCO is a private organization (not a government agency), and all AAFCO members must be federal or state government officials. There were three German Shepherd dogs who came in with their family and were hooked up to four intravenus lines each meant to flush the toxin from their bodies. Did you know that all pet food ingredients have a separate definition than the same ingredient in human food? If youve been around your dog or other dogs for an extended period of time, change your clothes right after to reduce the occurrence of an allergic reaction. Many pet food consumers pay high prices for specialty foods to address the allergy needs of a pet. . I dont define good health as absence of death, moreover. He is a loose canon and these things should not be allowed to continue. Im going to work on that very much appreciate the input. The passage of the Food Safety Modernization Act (FSMA) in 2011, which amends the FD&C Act and is the most comprehensive update to U.S. food safety regulation in more than 70 years, created new requirements and mandatory product safety standards for virtually all U.S. human food and U.S. pet food makers. FDA Product Regulation https://www.fda.gov/animal-veterinary/animal-food-feeds/product-regulation, Food Additive Petitions for Animal Food https://www.fda.gov/animal-veterinary/development-approval-process/food-additive-petitions-animal-food, Pet Food Labels General https://www.fda.gov/animal-veterinary/animal-health-literacy/pet-food-labels-general, Sub Chapter 660 - 699 Animal Feed https://www.fda.gov/inspections-compliance-enforcement-and-criminal-investigations/manual-compliance-policy-guides/chapter-6-veterinary-medicine, Guidance for Industry: Voluntary Labeling Indicating Whether Foods Have or Have Not Been Derived from Genetically Engineered Plants https://www.fda.gov/regulatory-information/search-fda-guidance-documents/guidance-industry-voluntary-labeling-indicating-whether-foods-have-or-have-not-been-derived, Federal Food, Drug, and Cosmetic Act (FD&C Act) https://www.fda.gov/regulatory-information/laws-enforced-fda/federal-food-drug-and-cosmetic-act-fdc-act. There is a concern that more FDA Compliance Policies will be initiated after the proposed regulations are made into law enabling manufacturers, ingredient suppliers, and warehousing facilities opportunities to avoid the law. I spoke with attendees and the agenda was very interesting. But the American Kennel Club (AKC) says that no dog is 100% hypoallergenic. The United States Food and Drug Administration (FDA)labeling requirements are currently regulated at two important levels: FDCA and the CVM. He inched over until he could lean on me and finally made it up into my lap. Clarification needs to be developed for the consumer in relation to notification of product withdrawals done either publicly or privately (silent recall). As well, pet food regulations should include consideration of allergens. In addition, the proposed animal food CGMPs do not include a provision related to raw materials and ingredients, including rework susceptible to contamination with pests, undesirable microorganism, or extraneous materials complying with FDA regulations for natural or unavoidable defects if a manufacturer wishes to use such materials in manufacturing such food.. And we the Readers dont have nearly the background of Susan and Mollie. Once you have that all figured out, you can start to narrow down which breed is right for you. Do you know what the differences are between Feed Grade and Human Grade pet food? Not at all. I tried to make it as short as possible but including every point that needed to be addressed. However Salmonella should not be the only environmental hazard monitored. Many pet food consumers pay high prices for specialty foods to address the allergy needs of a pet. . Plus, allergy tests have come a long way. I agree with Charles; it would take more than a few moments to respond. Importantly, the laws and/or regulations developed by AAFCO are not directly enforceable by the organization. Click Here for definitions of animal protein ingredients. The Agency requests comment on whether the requirements in section 418 of the FD&C Act should be modified further for facilities that are solely engaged in the production of food for animals other than man, based on scientific and public health principles.. Not just in theory, or as a positive side effect? Conversely, manufacturers should be rewarded for compliance, perhaps be being labeled as FSMA Compliant or some form of seal of approval. In the last seven years many thousand pets have died due to tainted/poisoned products imported from China. Pet Food is regulated by federal and state authorities. A food may be considered misbranded if its labeling is false or misleading in any way or fails to include required information. (FDCA). These breeds are considered as such because they have more predictable, non-shedding coats that produce less dander. Or could there be other options? Please do not copy word for word what I write below I suspect duplicate (word for word) comments will be discounted. I think they have forgotten what it is like to be a pet food consumer what we are up against. Afghan Hound. Also under Background A. Hello Susan. Cleveland Clinic 1995-2023. I became very attached to Winston and his humans. 8. Example: The use of risk concepts is not new for the Agency, as FDA routinely tries to estimate public health impact in deciding where to focus regulatory effort in general.. 8. Written Recall Plan. The FDA proposes to require that the written recall plan be developed for animal food with hazards that are reasonably likely to occur. As well, pet food regulations should include consideration of allergens. We have more than 100 days to comment. Click Here. Because no one is going to buy any food that intentionally is permitted to do the opposite (allow your pet to die prematurely or of a chronic disease). If there isnt a truly hypoallergenic dog, and you believe you may have allergies, does that mean all hope is lost? Any packaged food containing one or more of the eight current major food allergens (e.g., milk, egg, wheat, peanuts, soybeans, tree nuts, fish and crustacean shellfish), or containing . We love them so much that about 63% of U.S. households have one. Using a standard blood draw, allergen component testingcan get extremely specific. it will not take a few moments to respond unless i just cut and paste your points. AFSS identified the component The levels of regulatory oversight are commensurate with risk to human and animal health. FDAs approach seems mainly focused in risk to humans. These supplements are considered either new animal drugs or foods". Then you read the carefully crafted sections that just neglected to include (important) parts of federal food safety law. Additionally, many state governments regulate animal feed labeling requirements beyond federal standards. 23. If anyone has any questions, please let me know. Labeling is an important piece of this puzzle assuring safety within the product. Therefore, its important to physically interact with your chosen breed before you acquire apuppy or an adult dog. Cover bedroom vents with a dense filtering material like cheesecloth since air conditioning and heating can spread dander and other allergens throughout your home. And in terms of dog ownership, that can have a huge impact. People have a right to know what is in their food and in the pets food and where and how it has been processed. Im sure Mollie wont be offended I just wanted to explain how truly challenging it is at times. I submitted my comments tonight, including how my pet was sickened and ultimately lost due to the recalled melamine tainted food in 2007. Please do not ignore this very real threat. I usually dont fret over what people will think (obviously! Innovative industry efforts to incorporate a wide array of new products and bi-products into animal feed have in many instances increased food safety risk that challenges the acceptable boundaries of FSMA required cGMPs (current Good manufacturing practices) designed to manage these risks. Current Approaches to Animal Food Safety 12. FDA discusses Animal Food Safety Compliance Policy Guides. Id really like to know. What if AAFCO Nutrient Profiles are Linked to DCM? Proposed 507.25(c)(10) recommends that animal food be protected from contaminants that may drip, drain, or be drawn into the food. These are the American Kennel Clubs recommended breeds for allergy sufferers: There is a wide range of less allergenic dog breeds, from the large, intelligent, and protective Giant Schnauzer to the tiny, calm, and hairless toy Xoloitzcuintli. 1. Everybodys allergies are different, ranging from mild to severe. Many pet food consumers believe they are long overdue. According to Dr. Klein, its not necessarily the fur, but the dander, that causes allergic reactions in people. (Ive spent 35 yrs in the corporate world). 15. Prevention is key. Section E. Animal Food Safety Incidents of Background, Examples and Monitoring, the FDA discusses 2. This classification depends on the intended use of the product. There are multiple ways to reduce dog allergens, including grooming and keeping a clean home. Consumers deserve to be notified of a risk pet food/treat in a very prompt manner. And in that case, Dr. Klein says so-called hypoallergenic dog breeds are likely the safer choice. Many pets have severe allergies to certain foods and their owners go to great lengths and expense to assure their choice of pet food contains none of these allergens. Proposed regulations cover facilities that manufacture, process, pack, or hold animal food. VIII. We could do the same. Law Guidance Registration Cottage Food Data **Cottage Pet Treat Update** Starting July 1, 2023, registered Minnesota cottage food producers may ship cottage pet treats in the mail or by commercial delivery to the end consumer. My fear is, no one will take the trouble to read them. The Ingredients A month or so after I brought my girl home my husband came home from work and said hed like to have a talk. As for food additives, the Dietary Supplement and Health Education Act (DSHEA) of 1994, exempts many substances from regulation considering them drugs or food additives if the intended product meets the definition of a dietary supplement. 3. He fought bravely. Susan and others on the committee, do you and/or your acquaintances have media connections so this issue can get some airtime? 4. Current Approaches to Animal Food Safety the FDA discusses AFSS Working Group. I will also plan to write the FDA as Ive done in the past (to which they responded). Last week, the FDA announced proposed revisions to regulations governing pet food and animal food. In fact, hypoallergenic dogs may produce just as many allergens as their shedding, furry cousins. Believe me, when you are as immersed in this as much as we are (live, eat, breathe pet food) plus when you hear gut wrenching stories on a daily basis of a pet death or serious pet illness as both of us do its a real challenge to curb your tongue (I guess curb your tying fingers in this case). Under Background Section C FDA Food Safety Modernization Act, Item 2 Requirements for Agency Rulemaking, subsection f The Agency requests comment on whether to include potential hazards that may be intentionally introduced for economic reasons. It is certain that some suppliers are likely to be associated with more risk (due to their product), however all should be held accountable to uphold the same safety procedures. Proposed 507.1Applicability and Status FDA is proposing in 507.1(a) that the criteria in determining whether an animal food is adulterated to include only two sections of one very large law. From choosing baby's name to helping a teenager choose a college, you'll make . You can even use a HEPA air cleaner in your bedroom as an extra precaution. If your pet required veterinary care, ask your veterinarian to report to FDA. 27. Although whats causing your allergies might seem obvious, dont self-diagnose, because your symptoms could be unrelated to what you suspect. Please ask every pet food consumer you know to post comments as well. In the 60s, when you would assume that PF formulas werent very sophisticated, I remember many neighborhood dogs and cats living long lives, being pretty healthy until the days of senility, and often passing away simply from old age.. Read on to see if owning a dog, even if you have allergies, might be in your future. Natural or unavoidable defects would apply to many adulterants that could pose a health risk to the pet and the pet owner. Please compile your input and post a comment on the Regulations.gov website. There is no mention in the proposed FDA regulations of the Silent Recalls many pet food/treat manufacturers utilize. Everything had to be verified, a triple checked. 2) source of ingredient (specific food/mineral source e.g. After the 2007 recall, Congress demanded FDA update pet food regulations (which should have been completed by 2009). . So, despite their label,there is no guarantee a hypoallergenic dog breed wont trigger your allergies. Or what if youve already had a dog allergy diagnosed? Under A. Although its a difficult decision, on the rare occasion that you cant find the right match, Dr. Klein advises that it might be wiser to not acquire a dog, rather than bring one home only to relinquish it for rescue. The FDA should monitor any and all manufacturing establishments! 14. He had worried that I was too obsessive. If the Food Safety Modernization Act applies food to include animal food and the FD&C Act defines food to include food for animals, how can FDA conclude there are any differences between human food and animal food? Section 402 of the FD&C Act 2. (and in numerous locations throughout the proposed regulations), the FDA quotes Section 402 of the Food Drug and Cosmetic Act with conspicuous exceptions. Without legal limits for various pet food nutrients, the proposed hazard analysis and preventative controls will have holes in regulations that could effect animal health. The study found that the allergen levels were actually higher in hair and coat samples from the dogs that were supposedly hypoallergenic. 29. What questions should you ask a breeder? In most breeds, shed fur can carry proteins and dander all over your house. Cleveland Clinic is a non-profit academic medical center. And I think to make the decision, to make that claim, implies that some PF (either way) has or doesnt a longevity advantage (as in fact it should). Final rule will be determined after consideration of comments received during the required comment period. These requirements are found within FDCA sections 402 and 403. And then, can the PFC even set out to prove such findings scientifically?? On the Regulations.gov page, right side you will see a button that states Comment Now!. Even though the comments would be the same, the power of volume in voices heard will have a greater impact on their decision. Of significant concern is Chinese foreign suppliers. I wanted to get all of the details out there, because main stream media was making these FDA proposed regulations sound like it was the greatest thing since sliced breadI wanted pet food consumers to know the truth. It was a doozie picking through the 400+ page document for omissions. Up to 30% of people who only have a Can f 5 sensitivity may be able to tolerate a female dog or a male dog that has been neutered. These proposed revisions to pet food regulations were over 400 pages in length. . If you care about our future, our animals future, their health, indeed your own health, you are obliged to make a statement. Regardless of the breed you choose, once you bring your dog home, there are steps you can take to lessen the severity of your allergy symptoms. If your pet has become sick or has died you believe is linked to a pet food, it is important to report the issue to FDA and your State Department of Agriculture. The answer is obvious. Today, Your email address will not be published. It is important that US and foreign suppliers be held to the same regulations. www.PetsumerReport.com, Cooking for pets made easy, Dinner PAWsible, Find Healthy Pet Foods in Your Area Click Here. While skin prick tests and traditional blood tests both help a clinician diagnose allergies to common causes like pets, new blood tests that examine allergens on the molecular level can provide clinicians with even more information. While no dog is truly hypoallergenic, some breeds are better than others for allergy sufferers. The Regulations Click on that button and complete your information. Even if the PF Industry has conducted such long term studies, or embraced cumulative findings, then the next question is, would what theyve learned in terms of increasing the highest values of the PF for that goal, either pay them (profit wise) to make it that way? So, please, join us in making your voice heard comment on the rule. The changes of societys expectations are outrageous. Proposed 507.7 (A)(2) Documentation Related to Food Safety Practices at a Facility FDA states the owner, operator, or agent in charge of a qualified facility certifying that facility has implemented preventative controls, and the facility is in compliance. Some waste which is currently allowed into pet foods is not nutrition, is illegal per FD&C Act and should never be allowed into pet foods or animal foods. By only recommending that no contaminant be allowed to drip or drain or be drawn into the food, FDA is enabling another massive recall to happen. Consumers want to know what additives are included in their pet food purchases; these additives should be a requirement in the ingredient panel. And there are steps you can take to minimize your exposure. Under Current Approaches to Animal Food Safety subsection 6 Animal Food Labeling, FDA states: In addition, the FDAAA required FDA to issue regulations to update the standards for pet food labeling. 675.100 Diversion of Contaminated Food for Animal Use, CPG Sec. Food Allergies | FDA Is there evensuch a thing as a hypoallergenic dog? And less dander could mean that you wont be a sniffling, sneezing, runny eyed mess on a regular basis. Required fields are marked *. Your action is needed. Existing FDA Compliance Policies that allow pet food loopholes to avoid federal law should be removed and none provided to replace them. Our job is to distill all that information into a digestible format. Pet Food Regulation - Pet Food Institute This company just weeks prior to a massive recall was provided a clean inspection report from a certified 3 party inspection service. For instance, AAFCO also covers the product name, feeding directions, specified calorie requirements for specific pets as a calorie statement, the guaranteed analysis, and in most instances a nutritional adequacy statement. As mentioned previously, various FDA Compliance Policies allow animals that have died other than by slaughter (died in the field or euthanized) to become pet food ingredients. Comment (wording) existing status (or N/A status) versus proposed status (i.e., is it a change, a delete or an addition)? Definition to be stated. Food Allergies Food allergies and other types of food hypersensitivities affect millions of Americans and their families. FDA is asking for input to define a very small business which would be exempt from these record keeping, good manufacturing practices and hazard analysis requirements. Surely the FDA understands that much of the general public isnt going to understand and/or have time to read, decipher and respond to a 400-page government document; therefore, a petition showing our collective response as written by our Angel, Susan, and electronically signed by consumers would get their attention. Look for This Sign, Allergy Tests: Now You Can Find Out if Youre Allergic to a Male or Female Dog, Get Some ZZZs With These Nighttime Allergy Relief Tips, Your Childs Classroom May Have More Allergy and Asthma Triggers Than Home. However a contact phone number or email address be included. The 2007 pet food recall might be history for FDA, but it remains a vivid reminder of what can happen to thousands of pet food consumers. And the home allergen concentrations for both sets of dog owners were about the same for each group. How do you find a reputable breeder? The FALCPA amended the Federal Food, Drug, and Cosmetic Act (FD&C Act) by defining the term " major food allergen " and requiring that foods or ingredients that contain a major food allergen be. Quentin Tyler, Director, MSU Extension, East Lansing, MI 48824. Again, this recommendation should be a requirement. The FD&C Act requires that all animal foods must be safe to consume, they must be produced/manufactured under sanitary conditions (including foreign produced feeds and feed products), may contain no harmful substances, and must be truthfully labelled. If FDA feels the need to consult with outside parties to determine requirements, a broad group of experienced parties should be consulted including animal food alliance groups, hazard analysis and risk-based preventive control experts, and health officials (veterinarians). As these regulations are being developed by FDA, it is suggested that pet food labeling requirements be equal to human food labels. This is our chance. Well do more on this including media if any media is interested in learning more. Feeding Directions Must be labeled 'treat' or 'snack' or 'intended for supplemental or intermittent feeding only' The FDA has many responsibilities for regulating safe animal feed products but manufacturers and producers in many instances have the final responsibility. 6. Pet food consumers should not be forced to learn the intricacies of pet food labeling laws in order to interpret their pet food labels. Protein? Petsumer Report tells the rest of the story on over 2500 cat foods, dog foods, and pet treats. ), but this is so important I want them to understand it. All parts of Section 402 should be applicable as the legal definition of food requires to animal foods and should be considered when establishing CGMPs. Major areas of concern (i.e., as in the structure of the regulation) such as Safety, Oversight, Enforcement, Penalty, Reporting, Record Keeping. The food should be human grade, period. This section is very grey and needs to be clearly defined what FDA considers as natural or unavoidable defects. I suppose I can always resort to begging. 2. Hypoallergenic dog breeds are often defined as those that either dont shed or are hairless. Information on Marketing a Pet Food Product | FDA 5. Interesting, Susan, that you request no FDA bashing. Many products (edible and otherwise, like Toms of Maine body, skin and hair products) list ingredients (on their labels or on their web site) with the following information: 1) name of ingredient (organic, if applicable) is this a model that can be used? FDA does not feel cross-contamination is an issue, however many pet food consumers would disagree. Proposed Subpart AGeneral Provisions A. If you havent discussed your allergies in-depth with your healthcare provider, talk to them about treatment options like. FMI | Navigating Food Allergen Labeling Requirements Or possibly, none will make a difference.. For those who live with pet allergies, is it actually possible to get a dog that is hypoallergenic?. If you purchase a product through this article, we may receive a portion of the sale.