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Testimony to Senate Appropriations Committee - April 12, 2007

Dr. Elizabeth Hodgkins, DVM, Esq (Veterinarian)


Chairman Kohl, Senator Bennett, Members of the Subcomittee,

I speak today not as a previous pet food company employee, but as a veterinarian with deep concern for the health of my own pets and my many patients. Notwithstanding the pet food industry’s insistence that it is already stringently and adequately regulated, history tells us otherwise. In the past 16 months alone, there have been no fewer than three national level pet food recalls, including the most recent Menu Foods recall. Although the Federal Food Drug and Cosmetic Act requires that pet foods not be “adulterated,” the definition of which includes not containing any poisonous or deleterious substance, it is clear that breaches of this requirement are occurring at an alarming rate. The present pet food safety crisis is not an unfortunate aberration, but part of mounting evidence of a systematic breakdown in the commercial pet food safety assurances demanded by the pet owning public.

Pet foods carry both an implicit and explicit guarantee of safety in the label statement that they carry conferred by the American Association of Feed Control Officials. It is important to note that the government guarantees that are ubiquitous on pet food labels today cannot be found on any human food. No human food, whether it is fresh produce, meats, or commercially processed and packaged human consumables is allowed to bear such sweeping, broad guarantees of wholesomeness and nutritional adequacy.

Unfortunately, these guarantees are not based on routine testing of individual ingredients by either the companies under whose brands those foods will be marketed, or by the co-packers who oftentimes produce the foods for those companies at distant plants. There are no government requirements for certification or inspection of suppliers of these ingredients.

Similarly, the nutritional adequacy guarantee explicit in this claim is not based on long-term feeding of guaranteed foods. The most rigorous testing protocol for a lifetime adequacy claim is based upon the feeding of a representative food, not each food, to a very small number of animals for a short period of time, only several months. As long as no disastrous effects of the representative food are seen in these few test subjects, over a very short period of time, the representative food will gain the right to carry this long-term adequacy claim, as will all related, but untested foods.

Although the Act requires that meaningful inspections of production facilities must occur, the rapidly increasing size this industry has prevented this inspection process from keeping up with that growth. It is doubtful that that governmental inspection of plants can solve the problem of adulterated ingredients because of the sheer volume, variety and sources of those ingredients. It is even more doubtful that increased facility inspections can prevent the marketing of foods with misleading claims that they are safe and nutritionally adequate for the lifetime feeding of pets, since such authentication must be proven in long-term clinical studies.

I believe the letter and the spirit of the Federal Food Drug and Cosmetic Act already provide the framework for meaningful regulation without new laws and without a significant increase in the size of administrative government. What we need now is adherence to the existing regulations and the simple clear meaning of those regulations. The fundamental flaw in the present system that has allowed adulterated ingredients repeatedly to enter the pet food supply chain is the unreasonably easy access by essentially all commercial pet food manufacturers to scientifically unsubstantiated AAFCO label guarantees of safety and adequacy. This flaw is also responsible for the proliferation of “AAFCO statement labeled” foods that are far from adequate for long-term feeding of pets, as an exclusive diet. Pet owners and veterinarians have come to have blind faith in the safety and adequacy of foods bearing this statement, with no knowledge that the testing required to earn this statement is woefully inadequate and could never be used to justify such statements on any human food.

We do not need new regulations and a massive increase in any present federal administrative organization to improve this very troubling situation. In fact, the FFDCA already adequately specifies the quality of pet foods and their ingredients, and disallows unsubstantiated label claims on pet foods. What we need now is a faithful interpretation and application of the substance and intent of that Act. Over the past several decades, that substance and intent has been neglected, ignored and misconstrued by a rapidly growing industry that has become essentially self regulating.

To begin meaningful reform of pet food regulation, I propose that AAFCO and FDA adopt a presumption that all safety and nutritional adequacy claims for pet food are disallowed. Pet foods could be marketed without claims, as is the case with human foods, with pet food purchaser and veterinarians aware that the product carries no label claims for safety or nutritional adequacy.

Thereafter, the pet food industry and FDA/AAFCO might well work out a system to allow honestly informative label statements that adequately notify pet owners and veterinarians of the actual safety testing and adequacy testing to which each labeled food is subject. No implicit or explicit safety claims could be made without rigorous ingredient testing by the manufacturer and supplier certification. No long-term nutritional adequacy claims could be made without long-term, well-controlled clinical studies proving that adequacy, to genuine scientific standards.

In such an environment, prominent manufacturers would undoubtedly rise to the occasion and test their ingredients and their finished foods in order to gain the competitive advantage that honest label claims would provide. The pet food purchaser would have a much better informed choice of pet food quality, as indicated by truthful labels. Veterinarians would have far more meaningful guidance about what foods to recommend to their clients.

There can be no doubt that the present system of pet food regulation is in need of meaningful reform. I have no doubt that such reform can be achieved, as a first step, by a “truth in pet food labeling” initiative that would stimulate America’s best pet food makers to provide the quality that pet owners desire and deserve.

Thank you.

Dr. Hodgkins on proper diet for cats:


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