Industry Impact

Failure to provide clarifying definitions will likely result in the creation of a nutritionally deficient and highly adulterated consumer climate that FDA is tasked to prevent.  As FDA and State Departments lose credibility with the public through public arguments over testing methodology and recall enforcement, consumers begin using unregulated DIY grocery store products, and inaccessible co-op products. These products are known to contain higher levels of pathogens and lack of nutritional adequacy for all life stages through long-term use. In the last 3 years the pet food industry has lost $2.7 Billion in revenue.  Those consumers did not lose their pets and simply decide not to get new ones. Those consumers likely switched to homemade or co-op pet foods that are inaccessible to regulatory testing, advisement and monitoring.  Every 1% of pet owners that switch to homemade or co-op increases the risk of consumer illness and death, as well as nutritional inadequacies in pets.  This is known because pet owners handle and increased amount of raw grocery store meats in their homes and pets bowls, often following poor advise from uneducated veterinarians (as Vets know little of AAFCO or nutrition beyond what is taught by Hills or Royal Canin in college). Either that or they disregard veterinary advice because they have no trust in advice provided by kibble manufacturers. Further, while co-op products may be registered with states, they are inaccessible to regulators through retail channels and therefore come with increased risk of toxin contamination and nutritional inadequacies.

As FDA, AAFCO and State Departments are tasked with maintaining nutritional adequacy and preventing adulteration in the pet and ag feed supply, the more consumers that move to DIY and co-op products, the more control the FDA and State Departments lose in the consumer market and thus attainment of regulatory goals. Raw pet food manufacturers are being slowly eliminated from the market due to lack of clarity in the definition of pathogens.  As this occurs, more consumers switch to DIY and co-op products. The addition of clarified parameters that merge law and science under which to regulate specific bacterial pathogens would increase adherence to law, provide parameters under which manufacturers can clearly abide, and increase consumer trust in the regulatory entities affiliated with said product enforcement operations. Ultimately, adding these definitions would prevent the FDA and State Departments of Agriculture from failing in their mission to protect the public.

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