Letter to the FDA

[sweetpea24]

Here is what you get with a Hungry Man Chicken Dinner: http://caloriecount.about.com/calories-swanson-hungry-man-dinner-classic-i115930
I would say the labeling is misleading on the chicken dinner.....you are not getting protein, you are getting fat and carbs. And this is my point, just as mentioned above, human food labeling and quality is only minusculey better than pet foods For me, getting all fired up about this for animals, not understanding the complexities and wanting to write a letter without understanding what each governing body does and how they do it will get Emily nowhere fast. There are people that have dedicated their lives to improving food labels for humans and yet we continue to see deceptive marketing. If Emily really wanted to make a difference, start at the local level, start with volunteering at a shelter and consulting with adopters on pet nutrition. If you want to see big changes, start with small steps, understand where your voice will be heard the loudest and above all else, make sure the voice is accurate. Yes, writing letters to all these agencies sounds exciting but if that is all that is done, what has really been done?
Emily, I realize this is all very frustrating and upsetting to you but step back and take a couple of months to research the problem, understand what is all involved, who is involved and what their level of involvement is. There are numerous researchers, nutritionist and pet-centric scientist that have already spent years and millions of dollars researching and understanding, learn from them, put together a solid letter filled with facts targeted at each individual agency and you will see a much better return on your time investment than you will by simply firing off a half-cocked letter filled with emotions.

^^This...if you really want to make a point educate the pet owners who buy the food. These governing bodies have to please .everyone, the public, the government, the pet food industry... while i applaud your efforts, I think reading a couple of books, though good books, will not give you the scope required to give your letter the power you want.

Emily, your response to my last message - I'm sorry but I did not understand what you were trying to say. But if there was a misunderstanding, I apologize.

 

[emilymaywilcha]

I added Buyer Beware to my Amazon cart. Duh, how did I forget that one?

While looking at books, I found one that is just about the melamine recall five years ago.

 

[minka]

Does this look better?
 

     I respect the AAFCO’s willingness to try to ensure all pets in America are fed healthy and safe foods. However, I have major concerns about how this is done. Many animal lovers strongly agree the AAFCO, whose job is to ensure pets get everything they need and nothing they don’t, does more harm than good.
     I apologize if any of my statements berate or offend you or seem to be inflammatory. They should be taken as a display of how passionate I am about improving the health of cats and dogs everywhere.
     To be clear, I understand not enough is known about nutrition for any kind of food to be perfect. That is not an excuse, however, for intentionally misleading caring pet owners to make them believe they feed a perfect diet to their cats and dogs. If you really care about cats and dogs, you have no reason not to do whatever it takes to make sure they are eating the right foods every day.
     I am not accusing anyone of lying or trying to cause illness. Instead, my complaint is your rules for all pet food labeling directly or indirectly cause many cats and dogs to suffer and sometimes die of diseases by eating nothing but junk food their whole lives. Proven facts learned through scientific research, not my personal experiences alone, back up this complaint. Let me explain further in detail.

I tried to make sure the reader is interested in reading the whole letter and don't know how I can do that better than this.

IMO, the first paragraph is really good; but if I were an official in the AAFCO, I would have stopped reading after the second paragraph. Its my opinion that saying "I'm sorry if this comes off as rude" is unprofessional and would immediately ruin the chances of anyone high up looking at your letter. Try to keep a consistent basis of who you are addressing as well. You start off addressing the letter to the AAFCO as a whole, which is good, but then you switch to 'you' which makes the reader feel more personally attacked, even if the first reader is only going to be a receptionist.

 

[emilymaywilcha]

IMO, the first paragraph is really good; but if I were an official in the AAFCO, I would have stopped reading after the second paragraph. Its my opinion that saying "I'm sorry if this comes off as rude" is unprofessional and would immediately ruin the chances of anyone high up looking at your letter. Try to keep a consistent basis of who you are addressing as well. You start off addressing the letter to the AAFCO as a whole, which is good, but then you switch to 'you' which makes the reader feel more personally attacked, even if the first reader is only going to be a receptionist.

 Thanks for the suggestions Minka. Good thing I let someone else read it.

     I respect the AAFCO’s willingness to try to ensure all pets in America are fed healthy and safe foods. However, I have major concerns about how this is done. Many animal lovers strongly agree the AAFCO, whose job is to ensure pets get everything they need and nothing they don’t, does more harm than good.

     To be clear, I understand not enough is known about nutrition for any kind of food to be perfect. That is not an excuse, however, for intentionally misleading caring pet owners to make them believe they feed a perfect diet to their cats and dogs. If the AAFCO really cares about the health and safety of pets, how it regulates the pet food industry is not justified. Let me explain this in detail.

Fixed it.

 

[just mike]

Mike, because implies the food is chicken (or beef, or tuna, or whatever protein they are marketing) , when it isn't - when some have only 3% of chicken (or said protein) in it..... That to me is being deceptive. Specially when the 95%,25% and 3% rules make it possible to label the food so closely. I am sorry, but I do think to say "Why on earth would you care what the name of the can of food is?" is an attitude that is completely off here IMHO - if the food says chicken in it, it is giving the understanding that the food is made of chicken..... Then the majority of it is meat by-products, corn, flour, and 3% is chicken? Sorry, if you don't care, I am sure plenty do.
Furthermore..... If you got that same banquet Hungry Dinner - one that said "Chicken Dinner" on it, and took a bite only to find out that was a big mess of meat by-products or spam..... How would you like that? Would you care? I bet you would.

Carolina I understand what you are saying and I'm not here to argue with you.  We will always have differing opinions on probably everything under the sun and that's okay.  I'm trying to give Emily some advice here.  What I would like and not like is not the issue.  Emily is writing a letter and I am telling her for the letter to have more impact, the word "deceptive" implies intended fraud and will not get her anywhere.  You can point out a million examples of what *you* think deceptive means but it will not help Emily in her endeavor. 

A name is a name Carolina. I'm not sure why you get all bent over the name on the bag of food.  Seriously.    You are discussing marketing practices which is completely different that labeling practices.  Two completely different areas of the pet food industry as well and food for human consumption.    Emily is concerned with the content on labeling if I am not mistaken.  Not the name on the bag.  Which is what I was addressing, labeling content.

 

[just mike]

Mike, maybe you're not aware of the pet food labeling regulations?

Chicken Cat food. A food with this label means that at least 95% of the product consist of the named ingredient (not counting water added for processing).
Chicken Dinner. A food with this label means that just 25% of the product consist of the named ingredient.
Chicken Formula with chicken. A food using "with" means that just 3% of the product consist of the named ingredient.
If a consumer doesn't know this (and who does?

) do they think there's a difference? They think they're getting a chicken cat food.

Of course I am aware of the labeling regulations Laurie.  The problem I am having here is trying to determine exactly what Emily's complaint is about?  From what I've been reading she finds fault with the pet food industry at all levels as well as AAFCO.  Writing a letter saying all of this is deceptive will not get her anywhere.  Kind of like, pick a topic, get to know it and then write about it.

 

[carolina]

Carolina I understand what you are saying and I'm not here to argue with you.  We will always have differing opinions on probably everything under the sun and that's okay.  I'm trying to give Emily some advice here.  What I would like and not like is not the issue.  Emily is writing a letter and I am telling her for the letter to have more impact, the word "deceptive" implies intended fraud and will not get her anywhere.  You can point out a million examples of what *you* think deceptive means but it will not help Emily in her endeavor. 

A name is a name Carolina. I'm not sure why you get all bent over the name on the bag of food.  Seriously.    You are discussing marketing practices which is completely different that labeling practices.  Two completely different areas of the pet food industry as well and food for human consumption.    Emily is concerned with the content on labeling if I am not mistaken.  Not the name on the bag.  Which is what I was addressing, labeling content.

Mike - I give up getting a message through to you. Sorry, but not spending anymore time on it.... Whatever.
For the others, I already explained. More than once actually... and will be happy to spend more time, if asked....
Besides, Emily is already way beyond that.... So... I really don't see a point on going back to this :dk:

 

[emilymaywilcha]

Mike: To answer your question, I see no difference between naming a product "Chicken Dinner" and listing chicken as the first ingredient when both uses of the word chicken refer to little muscle and a lot of bone. So I was going to complain about both sides of the bag. I learned in school the name of a product is part of the labeling for human food. Shouldn't it be that way for pet food too?

 

[ldg]

Of course I am aware of the labeling regulations Laurie.  The problem I am having here is trying to determine exactly what Emily's complaint is about?  From what I've been reading she finds fault with the pet food industry at all levels as well as AAFCO.  Writing a letter saying all of this is deceptive will not get her anywhere.  Kind of like, pick a topic, get to know it and then write about it.

Of course you do. :lol3: Gotcha. Yes, good advice.

 

[kittylover23]

Emily, I found a link where Susan Thixton replies to a video by the FDA: http://www.truthaboutpetfood.com/articles/feedback-to-fda-on-pet-food-safety-video.html Thought this might help you write your letter!

"pet foods are truthfully labeled"
Again, no.  Pet food labels and advertisements are as misleading as it gets.  Images of choice cuts of meats, fresh vegetables on the label - turn the bag or can over and you see nothing that comes close to choice cuts of meat in the ingredient panel.  Again, it could be stated 'pet foods should be truthfully labeled' - certainly you know many of them are not.

"everything used to make the food must be listed on the label"
No again.  Additives to ingredients added by the ingredient supplier do not have to be listed on the label.  The perfect (and dangerous) example is ethoxyquin added to fish meals and fish oils.  Fish meal suppliers add ethoxyquin prior to the meal becoming a pet food ingredient - 'e' is not listed on the label.

This part, especially, applies to deceptive labeling.

 

[emilymaywilcha]

Kitty, ethoxiquin actually is listed on some pet food labels. They don't all hide it. Weurva specifies its chicken is "boneless, skinless white chicken breast" on the label. So there are some exceptions.

I will read that article, but she tells a lot more on the subject in her book Buyer Beware.

 

[Willowy]

The thing about ethoxyquin is that it isn't put on the label unless they add it to the pet food as a preservative. But if it's added to one of the ingredients they put in the pet food (usually fish meal), it's not in the ingredient list. Some companies will say "only ethoxyquin-free fish meal used" elsewhere on the label, some companies you have to contact them to ask. Honestly, even if the company wanted to say that they use fish meal with ethoxyquin added, I don't think they'd be ALLOWED to put it in the ingredient list since they didn't add it.

I don't know if it's commonly added to "fish" or only "fish meal" and "fish oil".

 

[emilymaywilcha]

The thing about ethoxyquin is that it isn't put on the label unless they add it to the pet food as a preservative. But if it's added to one of the ingredients they put in the pet food (usually fish meal), it's not in the ingredient list. Some companies will say "only ethoxyquin-free fish meal used" elsewhere on the label, some companies you have to contact them to ask. Honestly, even if the company wanted to say that they use fish meal with ethoxyquin added, I don't think they'd be ALLOWED to put it in the ingredient list since they didn't add it.
I don't know if it's commonly added to "fish" or only "fish meal" and "fish oil".

So it would be a good idea to avoid fish oil because you don't know if it has ethoxiquin.

 

[Willowy]

Not really. Fish oil is an excellent source of omega 3 fats, which are fairly necessary unless you feed only grass-fed meats to your cat. But contacting the company to ask if they use an ethoxyquin-free source would be a good idea .

 

[kittylover23]

http://www.mousabilities.com/nutrition/carbaafco.html Another website with information regarding pet food labeling and the FDA. :nod:

 

[just mike]

Mike: To answer your question, I see no difference between naming a product "Chicken Dinner" and listing chicken as the first ingredient when both uses of the word chicken refer to little muscle and a lot of bone. So I was going to complain about both sides of the bag. I learned in school the name of a product is part of the labeling for human food. Shouldn't it be that way for pet food too?

It is to a certain extent Emily.  I have forgotten the regulations on it but for it to say "Chicken Dinner" it had to have x amount of meat, "Chicken Meal" etc. The differently named products  all had to have a certain abount of <insert part of chicken here> to be named that particular name.  I'll have to go through my old notes to find the exact names and percentages.  But I feel that the names of pet food have gone well beyond what was originally intended compared to the actual ingredients inside of the bag.  Your effort is a good one Emily.  Just be specific.

 

[emilymaywilcha]

It is to a certain extent Emily.  I have forgotten the regulations on it but for it to say "Chicken Dinner" it had to have x amount of meat, "Chicken Meal" etc. The differently named products  all had to have a certain abount of <insert part of chicken here> to be named that particular name.  I'll have to go through my old notes to find the exact names and percentages.  But I feel that the names of pet food have gone well beyond what was originally intended compared to the actual ingredients inside of the bag.  Your effort is a good one Emily.  Just be specific.

But as the authors of Feed Your Pet Right explain, 95% chicken is really only 70% chicken and 25% chicken is really only 10% chicken if your cat is eating wet food. Read that book if you want to know why Carolina is so upset about the 95% and 25% rules.

 

[emilymaywilcha]

BTW I have now read all about marketing for less poop volume ("premium"), age groups (kitten/puppy and senior dog/cat), medical conditions (hairball control, skin and coat, clean teeth, allergies, CRF, UTI, and struvite stones). I also read about the words "natural" and "organic." Next I will learn all about the weight control claims. So far Marion Nestle and Maldon Nesheim are only saying all differences are too little to be any more than brilliant marketing techniques that would not be allowed if the AAFCO and FDA were not lazy when trying to regulate them.

 

[fair2middling]

Andrea,I have read all 3 pages of this thread, and IMHO it would appear that you might be tilting at windmills.Pick your battles wisely, stay on task.

 

[emilymaywilcha]

I am almost done with the book Feed Your Pet Right. The authors stated repeatedly they were unable to get information because the pet food insustry is very secretive and no reliable studies were done but they were able to explain everything about labeling pet foods and industry regulation.