This was a very unusual meeting. Back in 2016, when I first started attending AAFCO meetings, there was a lot more discussion. Some of the discussion was heated/opinionated. Not so much any more.
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This year, there were approximately 400 people in attendance – 100 were first timers – mostly new state regulators. Which is interesting in itself: the looming PURR Act may have led experienced state regulators to retire.
Here are the events as might pertain to our members:
Dr Tim Schell, acting director CVM (Center for Veterinary Medicine, FDA) spoke about African Swine Fever (ASF). Major efforts are trying to keep it out of the US. While the FDA has lost a lot of employees, they are hiring new.
Based on the above comment, perhaps manufacturers should consider adding a page in their food safety plan: a consideration of ASF and how to protect their food supply.
Numerous times through the 3-day meeting, a committee chair proposed new topics and there were no responses from the audience.
Sometimes it was a matter of nobody present to represent the question. Such as, there was no one speaking out on behalf of consumers.
Sometimes it was a matter of whether those present wanted to be involved in improving the system to try to make it better, but maybe instead preferred to sit outside of the system and not participate.
An example of this latter one is that I have been chairing a work group to rewrite some of the SUIP (Statement of Uniform Interpretation of Policy) guidance. And after four years, nine meetings, and multiple times where regulators volunteered to help with the language but then not answering emails, we finally determined that nobody in the audience of 370 people really cared. So we put the item back into the parking lot. (Basically, pet chews are not regulated unless they are either adulterated or make label claims of providing some kind of nutrition, or are sold in certain states which do regulate the chews.)
The above example ended up being the feel of the entire meeting. Not sure how much people really cared about anything that was being presented.
Perhaps it was because 25% of the people present were brand new and they don’t know what to think and how the system works?
Or perhaps it was because the PURR Act continues to gain momentum and people are afraid they’re going to lose their jobs?
I had a personal discussion regarding the PURR Act with Pat Tovey, the PFI (Pet Food Institute) representative – he has been receiving tons of questions how things would work if the PURR Act is passed. My question regarded funding the system. As the PURR Act is currently written, the states will continue to charge their fees, thus continuing to fund the state activities that are dependent on pet food registration. Simply, the states no longer get to approve what’s written on the label; that’s for FDA/CVM to approve labels under the proposed PURR Act. How that will be funded? Perhaps tax dollars as there are no specific provisions for funding increased work at the FDA.
In another committee, there was a proposal to talk about raw milk, specifically raw pet milk.
A state (we believe Washington) asked the chair of the Model Bill Committee to discuss raw pet milk. Before the discussion could start, the state representative left the room. Thus, when the chair brought up the topic, there was no discussion. Therefore, I took the opportunity to share with the room the issue as our manufacturers see it – afterall, it is NGPFMA members who are marketing raw pet milk.
Raw pet milk is clearly labeled for pets in very specific large font. Use by humans is not supported. Our trade association has multiple members selling raw milk across the country. Earlier this summer, Washington state contacted all out of state raw milk manufacturers stating they would not license out of state raw milk, citing human raw milk laws. This trade association strongly advises against that behavior because that sets the precedent to regulate all pet food based on human food laws. Again. That’s a very risky maneuver; only our manufacturers use ingredients that could be held to human food standards.
On another topic, there has been a change in leadership at FDA/CVM. Some of our “supporters” (Can I say supporters? At the least, not everyone at FDA is 100% against fresh and raw pet food) at FDA are still there. Which is really good to know from a continuity perspective. And, apparently, staff at the FDA has already received and reviewed the trade association comments regarding reducing regulation and potentially changing how raw pet food is regulated/governed. Again, good to know the system is moving information around as it should be.
We will keep our members updated as things evolve that may actually affect our members.
The kibble industry? What can I say? The industry is doing the slow six year phase-in plan for label modernization (PFLM). Deadline to implement is 2030. Of course, PFLM was mandated by Congress over 10 years ago. Now? The big concern? Printing costs. Yes. These giant multi-national companies want us to believe they have a warehouse dedicated to storing old-style labels – enough labels that will exceed the 2030 deadline. I’m sure even the giant multi-nationals batch print and use their labels within 6 months and have to print more. Frequently.
I continue to encourage our manufacturers to update their labels to the new PFLM format when they produce a new batch of labels – it only benefits our members and their customers to see what’s really in the package.
Food versus feed.
Another crazy topic that I’m not sure any of the 370 people present really cared about. There are places in the regulation where it’s called food, and there are places in the regulation where it’s called feed. However, the regulators defined the food to be interchangeable with feed. So no one cared to be uniform through the Model Bill.
So this is what they had to talk about this year.
Did you miss anything?
Not so much.
Except maybe for the raw milk thing.
Next Gen PFMA continues to work with its members to correct the Washington state raw milk policy; we will keep you in the loop.
