In the last post, I let you know that I was going to the FDA on behalf of raw pet food manufacturers to discuss how we (NGPFMA and the FDA) can work together. While we all hoped for the best, which would be complete change in the FDA’s policy, reality said that was a very high, unrealistic expectation. In reality, our goal was to open communication.
And that’s what we did; we started a conversation. First, we discussed the history of the FDA’s policies on Salmonella. While Compliance Policy Guide 690.800 has only been in place since 2013, it was explained the current FDA regime is under the impression that the FDA has “always” had a zero tolerance policy on Salmonella. It’s an interesting assertion as it opens up further conversation; if this has always been their policy, then why was the CPG written in 2013? (Other Salmonella-related CPGs were also written in the 2010’s.)
Next, we learned we have a different definition of adulteration. Under USDA purview, and in lieu of the Supreme Beef vs USDA ruling, we (NGPFMA and raw pet food manufacturers) operate under the impression that a certain level of background bacteria is inherent to raw meat products, even those that have been inspected and passed by USDA inspectors. From the FDA’s perspective, even one bacterium is considered an “added” substance. This is another interesting assertion as the preponderance of evidence supports the first definition; however, every uncontested recall supports the FDA’s policy.
Based on the above, when it was all said and done, we had two formal questions for the FDA:
- Please provide the FDA’s consideration regarding Salmonella as an added substance in the processing of raw pet foods.
- Please provide your statutory authority for zero tolerance for Salmonella and other bacteria in a raw pet food product.
The FDA representatives with whom we met said they’ll get back to us (NGPFMA) at the AAFCO meeting in January (assuming government shut down is corrected by then.)
We could take these differences in perspective as a reason to fight; instead, because we were able to communicate regarding the differences, we can create understanding; understanding leads to shift in perception. Nothing will be gained by the trade association making threats of retaliation and lawsuits. What will be gained through conversation is an opportunity to educate and discuss. The conversations have begun; let’s all have more conversations with the appropriate personnel. Through education and understanding we can ultimately impact policy.
Next Gen PFMA advocates for you. Next Gen PFMA will be represented at AAFCO – will you be able to attend this important meeting?
How can Next Gen PFMA help your business succeed?
