Formal title: Docket Number [FDA-2007-N-0442] Opportunity of Public Input on Standards for Pet Food and Other Animal Feeds; Notice of Meeting
The Food and Drug Administration (FDA) held a public meeting in Gaithersburg, MD on May 13, 2008, to obtain input from stakeholder groups, including, but not limited to the Association of American Feed Control Officials (AAFCO), veterinary medical associations, animal health organizations, and pet food manufacturers, concerning the development of ingredient standards and definitions, processing standards and definitions, processing standards, and labeling standards, and labeling standards for pet food. These standards were mandated by the FDA Amendments Act of 2007 (FDAAA). The FDA also seeks written comments, as well as input on whether the ingredient standards and definitions and processing standards should cover all animal feeds.
The AVMA responded to the FDA's call for public input with three specific recommendations: 1) Modification of the labels on pet foods with health claims, 2) the addition of calorie statements to pet food labels, and 3) development of a formalized, multi-disciplinary emergency preparedness system utilizing the National Incident Management System (NIMS).
There are an ever-increasing number of pet foods that make various health claims. Veterinarians are expected to be able to discern whether the claims are substantiated, or not, before recommending them to their clients. This is a real challenge, considering the vast number of such pet foods, and the varying levels of available evidence. In the interest of pet safety, the AVMA recommends the FDA require all pet food products with implied or explicit health or drug claims to include a prominent statement on the label, indicating that such claims have not been evaluated or verified by the FDA.
In addition, pet owners do not always know how much to feed or realize the high calories content associated with some of the foods they feed their pets. To control obesity, we need to not only raise this awareness, but also provide easy and practical options for pet owners. AVMA recommends the addition of calorie statements to pet food labels, specifically:
- Calorie information on all dog and cat foods. That includes foods intended for long-term feeding and supplemental treats.
- That the calorie statement be expressed in both kilocalories of metabolizable energy per kilogram of food, and as kilocalories of metabolizable energy per familiar household measure, such as cans or cups. We recommend that the label expressly and clearly differentiate whether the calorie content label expressly and clearly differentiate whether the calorie content label information was determined by chemical analysis and calculation, or by animal feeding.
In response to the nationwide pet food recall in 2007, The AVMA recommends the development of a formalized, multi-disciplinary emergency preparedness system utilizing NIMS. As we become increasingly dependent on imported ingredients for the commercial manufacturer of pet foods, we must use the lessons learned from last year's pet food recall, during which time too many of our pets' lives were tragically lost. The AVMA fully recognizes the need for, and looks forward to, the achievement of an even stronger food safety system using the National Incident Management System (NIMS), which will help prevent such tragic losses.
View Federal Register document (PDF)
The AVMA responded on June 13, 2008. (PDF)