04/21/2020
Susan Thixton:
Millions of pounds of illegal pet foods are allowed to be sold to unknowing consumers each day. How can government regulatory authorities allow law to be violated? They are paid to.
When U.S. federal law says one thing: “The term “food” means (1) articles used for food or drink for man or other animals“…and “A food shall be deemed to be adulterated” (in part) “(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”…
…but pet food government authorities enforce something completely different – “we do not believe that the use of diseased animals or animals that died otherwise than by slaughter to make animal food poses a safety concern and we intend to continue to exercise enforcement discretion where appropriate”…
…aren’t these government regulatory authorities violating their sworn duty “to place loyalty to the Constitution, laws and ethical principles“?
Yes, they are. So…if these government regulatory authorities are violating their duty, how does illegal pet food happen? How can billions of dollars of illegal pet food be sold each year with no law enforcement?
It happens through a complex system of government and private organizations.
The system: Pet food is regulated on a federal level by FDA and on a state level through each state’s Department of Agriculture. With federal and state laws specifically prohibiting pet food ingredients to be sourced from diseased animals and animals that have died other than slaughter, government pet food regulatory authorities need some assistance. That assistance comes from the private organization Association of American Feed Control Officials (AAFCO) and a regulatory system developed by FDA and AAFCO, the Animal Feed Regulatory Program Standards (AFRPS).
AAFCO writes the definitions of all pet food/animal feed ingredients. These ingredient definitions become accepted as law in each U.S. state – BUT, unlike all other laws, these legal definitions of ingredients are NOT published as state law for public review.
Example: chicken. The food item ‘chicken’ must abide by the federal laws The Poultry Products Inspection Act. All of these laws are public information, including all legal definitions. But pet food ‘chicken’ isn’t held to the federal laws of The Poultry Products Inspection Act. The private organization AAFCO provides pet food chicken it’s very own legal definition that doesn’t require it to be sourced from inspected and passed poultry (as the federal Poultry Products Inspection Act requires). In fact, AAFCO’s definition of chicken allows it to be sourced from condemned chicken or chicken bones (little to no meat).
Remember, AAFCO is a private organization…it can write the legal definitions anyway it wants. The tricky part comes with enforcement of this definition of chicken – since it is opposite of federal law.
With enforcement, FDA and AAFCO have worked out a system – a financial reward system to states that ignore federal and state law, and blindly follow the illegal pet food system; the Animal Feed Regulatory Program Standards.
Below is a map of states that FDA pays (via your tax dollars) to participate in the illegal pet food system.
United States Map displaying 23 FDA funded AFRPS CAP states: AL, CA, CO, CT, FL, GA, IA, KS, KY, LA, MI, MN, MO, NE, NJ, NM, NC, PA, SC, TN, TX, WA, WV
As example of how much a state benefits from enforcing pet food regulations the way FDA