FDA 101: Animal Feed

The Food and Drug Administration (FDA) on 06/10/09 published its FDA 101 on Animal Feed. Sounds interesting I thought when I found the announcement in my inbox. However, knowing what we all know I was skeptical of what it really means and if it is going to change anything for us pet owners. Here’s the wording, note that because of our specific interest as pet owners I rearranged the paragraphs a little:

Introduction
As long as the Food and Drug Administration (FDA) has been regulating food for people, it has also regulated food for animals, including animal feed for millions of chickens, turkeys, cows, pigs, sheep, and fish. In addition, FDA regulates pet food for America’s more than 177 million dogs, cats, and horses.
The Federal Food, Drug, and Cosmetic Act requires animal feed, like human foods, to
-be pure and wholesome
-be produced under sanitary conditions
-contain no harmful substances
-be truthfully labeled
As is also the case for human foods, the act does not give FDA the authority to require approval of animal feed, including pet food, before it is marketed. But the agency has the authority to take action against feed products that are in violation of the law. And FDA approves the additives or drugs that are used in feed products.
Animal feed manufacturers are responsible for ensuring that
-feed is truthfully labeled
-feed does not contain unsafe additives or contaminants
-if the feed contains drugs, the drugs are approved by FDA for use in animal feeds
Federal and state regulatory agencies work cooperatively to provide the rules, guidance, and oversight to assist industry in producing and distributing safe animal feed and feed ingredients.

Pet Food
Pet food, including dry and canned food and pet treats, is considered to be animal feed. Like other animal feed, FDA regulates pet food and establishes standards for labeling.
Pet food labeling is regulated at two levels: federal and state. The federal regulations, enforced by FDA’s Center for Veterinary Medicine, establish standards that apply to all animal feeds:
-proper identification of the product
-net quantity statement
-manufacturer’s address
-proper listing of ingredients

Some states also enforce their own labeling regulations. Many of these follow the model pet food regulations of the Association of American Feed Control Officials (AAFCO), a non-government advisory body with representative regulatory officials from all the states. These model regulations are more specific than federal regulations, covering aspects of labeling such as product name, nutritional adequacy statement, feeding directions, and calorie statements.
FDA carries out its animal feed regulatory responsibilities in cooperation with state and local partners, and works together with AAFCO on uniform feed ingredient definitions and proper labeling.”

These paragraphs deal with what we as pet owners are interested in: Pet food. However, as it states, “Pet food, including dry and canned food and pet treats, is considered to be animal feed”, I figured, I also share with you the paragraphs dealing more with other animals, like for example chicken or beef, i.e. the stuff what is being used in our pet foods. My desire of sharing the following paragraphs comes especially since it makes very clear what we may be faced with when we buy a bag or can of chicken formula for our cats and dogs, and what these chicken may have been fed before they found their final destination.

“Medicated Feed
Drugs may be added to some animal feeds to prevent or treat diseases, or to improve animal growth and productivity.
“The use of drugs in the food of animals is essential to keep animals healthy,” says Steven D. Vaughn, D.V.M., director of the Office of New Animal Drug Evaluation in FDA’s Center for Veterinary Medicine. “Administering drugs to animals takes into consideration the best methods for providing the needed medicine while minimizing the stress to the animals.”
For example, coccidiosis is a disease that commonly infects chickens and can cause death if untreated. The parasites responsible, coccidia, are passed in the droppings and can infect other chickens housed near the sick chickens.
“It’s not practical for the poultry farmer to isolate and individually dose chickens within a flock,” says Vaughn. “Catching, restraining, and handling chickens can be stressful and potentially harmful to the animals, particularly if they are already stressed due to disease. Providing medication through the feed or drinking water eliminates the stress to the animals. Medicated feed to treat all the chickens is necessary for good animal health, and ultimately to the health of humans who consume the chicken products.”
The types of drugs that may be used in feed include
-antimicrobials (such as antibacterial drugs) to fight infections
-anticoccidials to fight coccidial parasites
-hormonals to suppress estrus (the female “heat” cycle) in cattle
-anthelmintics to fight parasitic worms
-sulfonamidics to fight certain types of infections
-beta agonists to promote leanness in animals raised for meat
-anti-bloating drugs to prevent swelling of the stomach compartments or intestinal tract of cows caused by excessive gas.

Residues and Resistance
FDA is responsible for assuring that animal drugs and medicated feeds are not only safe and effective for animals, but that food products from treated animals are safe for humans to consume. This safety responsibility includes making sure that drugs used in medicated feed
do not leave hazardous residues in human foods, such as milk, meat, and eggs do not contribute to antimicrobial resistance—the ability of bacteria and other microbes to grow in the presence of a drug that would normally kill them or limit their growth Before a drug can be approved for a food-producing animal, FDA requires the drug sponsors to provide data to show how much drug remaining in the animal’s system (residue) would be safe for people to consume that the concentration of actual residue in the edible part of the animal would not result in a person consuming more than the safe level the potential for the drug, if it’s an antimicrobial drug, to contribute to antimicrobial resistance FDA has produced guidance to help drug makers provide these data. For example, FDA provides a scientific process for determining the likelihood that an antimicrobial drug used to treat an animal may cause an antimicrobial resistance problem in humans consuming products from that animal. This process can help prevent drugs with a high risk of causing such problems from being improperly used in food-producing animals, potentially leading to antimicrobial resistance in humans.

While recognizing that drugs in animal feed are essential, FDA encourages food-animal producers and veterinarians to apply good judgment and common sense in using animal drugs.
“The judicious use of all drugs in animals, particularly food-producing animals, is very important,” says Vaughn. “The use of medicated feeds in food-producing animals is evaluated and regulated to prevent harmful effects on both animal and human health.”

Manufacturers can do their part in providing safe and effective feed products by properly mixing the feed and complying with regulations that require current good manufacturing processes (cGMP) for medicated feeds. In addition to guidance, FDA provides brochures, videos, and other products on its Web site to encourage judicious drug use in animals.
The law requires feed manufacturers to be licensed if they use certain types of medication in manufacturing their feeds. FDA and the state inspect these licensed facilities routinely to make sure they are complying with cGMPs. During FY 2008 (Oct. 1, 2007, through Sept. 30, 2008), FDA conducted 453 inspections of licensed medicated feed manufacturers throughout the United States.”

I think at this point you may agree with me, it sure makes me think twice not just about what I feed my companion animals, but also what I feed my family and myself. And makes me also to reconsider possibly other food types like for example organic, or with ingredients from free range and pasture fed animals.

To me the bottom line is this: This all sounds good in theory. But unfortunately we also know that it still leaves a lot of lead way for pet food manufacturers. They still can stretch pretty far what they are doing with regards to manufacturing processes and ingredient composition and legally get away with it.

But, as always there is hope: The FDA also provides an outlook for the future and promises quite a few changes, which possibly could improve things in general:

“Improvements to Feed Safety
FDA is improving its Animal Feed Safety System, a program first established in 2003 to protect human and animal health by ensuring safe feeds. The system covers a broad range of agency activities from pre-approving additives for use in feed, to establishing limits on feed contaminants, providing education and training to federal and state feed regulatory personnel, conducting inspections, and taking enforcement actions to ensure compliance with agency regulations.
FDA is also taking action to improve the safety of pet food and ingredients used to make pet food, such as
-establishing ingredient standards and definitions, processing standards, and labeling standards for pet food
-establishing an early warning system to identify pet food in violation of regulations, to identify illness outbreaks, and to notify veterinarians and others of pet food recalls
-establishing a searchable database of recalled human and pet foods to ensure effective communications during a recall
-establishing a “reportable food registry” for animal feed as well as human food. Reportable food -is any food that carries a reasonable probability that its use or exposure to it will cause serious health consequences or death to humans or animals
-collaborating with state regulators and academic partners to set up a network for reporting and investigating unexpected and undesirable signs (adverse events) in pets”

It all sounds promising. My only questions are, how long will it take and how severe will the impact be on future pet food safety. As always I would like to say, let’s be optimistic. On the other side, I have been around long enough to already know today, the differences are not going to be revolutionary. Let’s keep chipping away, one little piece at a time. And keep in mind, not everything finding the FDA’s blessing is always in the best interest of our pets. Stay tuned for more on this hot topic.

Note: Visit the FDA site to read the article in its entirety.