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Why this is Important
We believe the FDA should enforce the Food, Drug, and Cosmetic Act (The Act) - as it is written - with pet foods. The Act clearly defines 'food' as that for humans and animals. Yet currently, the FDA allows materials from diseased animals, euthanized animals, downer animals, rodent feces and insect infested foods to be processed into pet foods/animal foods. Consumers are not warned their pet food purchases could contain illegal ingredients and often pay premium prices for such.
We request the FDA to be required to abide by The Act or request the FDA to require all pet foods that do not provide certification of compliance of The Act to be clearly labeled with a warning to the consumer.
Evidence supporting our position...
The Federal Food, Drug, and Cosmetic Act (The Act) defines food as: "The term ‘food’ means (1) articles used for food or drink for man or other animals, (2) chewing gum, and (3) articles used for components of any such article." Section 201 (f)
The Federal Food, Drug, and Cosmetic Act (The Act) defines food as: "The term ‘food’ means (1) articles used for food or drink for man or other animals, (2) chewing gum, and (3) articles used for components of any such article." Section 201 (f)
Clearly, pet food/animal food should be protected by Federal law.
The Act defines adulterated (prohibited) food as: "A food shall be deemed to be adulterated – (a) Poisonous, insanitary, or deleterious ingredients.” (a)(5) “if it is, in whole or in part, the product of a diseased animal or of an animal which has died otherwise than by slaughter." Section 402
Clearly, pet foods/animal foods that contain insanitary ingredients or ingredients sourced from diseased or euthanized animals would be prohibited to sell. But...
Despite Federal law, the FDA provides the pet food/animal food industry with loopholes to violate The Act; these loopholes are known officially as Compliance Policies.
As evidence:
FDA Compliance Policy CPG Sec. 690.300
"Pet food consisting of material from diseased animals or animals which have died otherwise than by slaughter, which is in violation of 402(a)(5) will not ordinarily be actionable, if it is not otherwise in violation of the law. It will be considered fit for animal consumption."
FDA Compliance Policy CPG Sec. 690.300
"Pet food consisting of material from diseased animals or animals which have died otherwise than by slaughter, which is in violation of 402(a)(5) will not ordinarily be actionable, if it is not otherwise in violation of the law. It will be considered fit for animal consumption."
FDA Compliance Policy CPG Sec. 675.400
"POLICY: No regulatory action will be considered for animal feed ingredients resulting from the ordinary rendering process of industry, including those using animals which have died otherwise than by slaughter, provided they are not otherwise in violation of the law."
"POLICY: No regulatory action will be considered for animal feed ingredients resulting from the ordinary rendering process of industry, including those using animals which have died otherwise than by slaughter, provided they are not otherwise in violation of the law."
FDA Compliance Policy CPG Sec. 675.100
"FDA does not object to the diversion to animal feed of human food adulterated with rodent, roach, or bird excreta."
"FDA does not object to the diversion to animal feed of human food adulterated with rodent, roach, or bird excreta."
FDA Compliance Policy 675.200
"The *Center* will consider the requests for diversion of food considered adulterated for human use in all situations where the diverted food will be acceptable for its intended animal food use. Such situations may include:
a. Pesticide contamination in excess of the permitted tolerance or action level.
b. Pesticide contamination where the pesticide involved is unapproved for use on a food or feed commodity.
c. Contamination by industrial chemicals.
d. Contamination by natural toxicants.
e. Contamination by filth.
f. Microbiological contamination.
g. Over tolerance or unpermitted drug residues."
"The *Center* will consider the requests for diversion of food considered adulterated for human use in all situations where the diverted food will be acceptable for its intended animal food use. Such situations may include:
a. Pesticide contamination in excess of the permitted tolerance or action level.
b. Pesticide contamination where the pesticide involved is unapproved for use on a food or feed commodity.
c. Contamination by industrial chemicals.
d. Contamination by natural toxicants.
e. Contamination by filth.
f. Microbiological contamination.
g. Over tolerance or unpermitted drug residues."
It is crystal clear; these FDA Compliance Policies allow pet foods/animal foods to violate the Federal Food, Drug, and Cosmetic Act. No Government Agency should have the authority to tell industry they can avoid the law.
We ask for one of the following...
1) FDA to immediately remove all Compliance Policies that allow pet foods and animal foods to violate The Act; immediately enforce The Act as it is written; or
2) FDA to immediately require all pet foods and animal foods that may include an ingredient which violates The Act to be clearly marked with a warning on the label. Only pet foods that certify compliance of The Act would be excused from the warning requirement. We suggest the following label warning on all other pet foods and treats: Warning This Pet Product could contain illegal ingredients and could put your pets health at risk.
2) FDA to immediately require all pet foods and animal foods that may include an ingredient which violates The Act to be clearly marked with a warning on the label. Only pet foods that certify compliance of The Act would be excused from the warning requirement. We suggest the following label warning on all other pet foods and treats: Warning This Pet Product could contain illegal ingredients and could put your pets health at risk.
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