Stop the FDA from Killing More Pets


Do you know that the FDA is partially responsible for countless deaths of dogs and cats during the 2007 pet food recall?

This is not a feeling or hunch, this is FACT.  The Office Of Inspector General recently released its review of the FDAs handling of the 2007 Pet Food Recall, the deadliest Pet Food Recall in history.  Their findings blatantly state the FDA was lax in following their own procedures to remove deadly, contaminated pet food from store shelves. 

The result of this lax behavior? 

Perhaps thousands more dog and cat deaths in the United States and Canada.  Countless thousands of families with holes in their hearts.  Perhaps cumulatively millions of dollars spent on veterinary bills trying to save the life of a beloved pet. 

Here are quotes from The Office of Inspector General report...

  • FDA has developed procedures for monitoring recalls and assessing a firms recall effectiveness.  However, FDA did not always follow its procedures in overseeing three of the five recalls that we reviewed.  Furthermore, FDAs procedures were not always adequate for monitoring large recalls.  FDAs lack of authority, coupled with its sometimes lax adherence to its recall guidance and internal procedures and the inadequacy of some of those procedures, limited FDAs ability to ensure that contaminated pet food was promptly removed from retailers shelves.
  • Because FDA did not perform a detailed reconciliation of Menu Foods production records and raw material lists at the time of the March 2007 inspection, FDA was unaware that the production records did not document the transfer of 11,000 pounds of contaminated wheat gluten to a Canadian plant before the recalls began.  FDA remained unaware of the transferred wheat gluten until April 9, 2007, when FDA learned that the University of California at Davis had traced the death of a pet to a brand of Menu Foods pet food that was not on the recall list.  On April 11, 2007, FDA began an in depth reconciliation of Menu Foods%u2019 records and confirmed that the Canadian plant had produced melamine-contaminated pet food that was not on the recall list.
  • During the first round (of pet store inspections), FDA did not always adhere to its procedures when conducting audit checks at the 64 retail stores:
       Of the 64 store visit forms, 40 were missing one or more pieces of required information, such as the amount of product that the store had removed from its shelves and the amount still remaining on its shelves.
       FDA did not tabulate the results of the 64 store visits and therefore could not adequately assess the effectiveness of the recall effort as required.  Our tabulation of the first round of audit checks, based on the information available on the store visit forms, indicated that 20 percent of the stores visited still had recalled products on their shelves.
  • In addition, some of the 1,195 store visit forms that inspectors submitted did not contain all requested information or contained misclassified results.  For example, the store visit forms for 31 stores classified the recalls as effective even though the stores (1) had not received notice of the recalls or (2) said that they had received notice of the recalls but had not removed the products from their shelves.
  • According to FDA officials, FDA had specified during recall strategy discussions that Menu Foods should conduct effectiveness checks at 100 percent of its affected distributors and retailers, which FDA estimated to total more than 10,000.  Thus, Menu Foods conducted effectiveness checks at fewer than 30 percent of its distributors and retailers.  We found no evidence that FDA had followed up with Menu Foods to determine why the firm had not promptly initiated and completed the specified level of effectiveness checks.

 

In September, 2007, just months after the Deadliest Pet Food Recall in History, Congress mandated the FDA to initiate an improved Recall Notification System for pet food (required by law to be accomplished by September 2008).  http://www.truthaboutpetfood.com/articles/62/1/FDA-says-Dog-Ate-Homework/Page1.html

This has NOT been done.

The same laws required that the FDA properly define pet food ingredients, update pet food processing standards, and provide updated labeling standards (required by law to be accomplished by September 2009).  http://www.truthaboutpetfood.com/articles/62/1/FDA-says-Dog-Ate-Homework/Page1.html

This has NOT been done.

Despite Federal Food, Drug, and Cosmetic Act Law, an FDA policy allows pet food to contain diseased animals and euthanized animals; ground up and packaged as Healthy, Premium Dog Food or Cat Food. http://www.truthaboutpetfood.com/articles/137/1/Undeniable-Proof-the-FDA-allows-Pet-Food-to-Break-the-Law/Page1.html

FDA policy does NOT override Federal Law; yet no one in Congress Seems to Care.  http://www.truthaboutpetfood.com/articles/161/1/Congress-Doesnt-Care-the-FDA-is-Violating-Federal-Law/Page1.html

 

Enough is Enough!

 

Attention 74 Million U.S. Pet Owners

Are we going to sit around and wait for the next deadly pet food recall?

Or Are we going to do something to prevent it?

Please READ and sign the Petition to the 111th Congress of the United States (its their job to regulate the FDA).

There are 74 Million U.S. Homes with Pets.  Estimating two voting age residents of each home, we as a group are 148 Million Votes Strong.  Together WE HAVE THE POWER TO DEMAND THE FDA ABIDE BY FEDERAL LAW AND POSSIBLY PREVENT THE NEXT DEADLY PET FOOD RECALL!

Please Read and sign the Petition and forward to every pet owner you know.

Respectfully, we the undersigned are Mad as Hell and We are Not Going to Take it Anymore! 

We are Pet Owners.  We are conservatively 148 Million Voting Americans.  We are fed up with the FDAs actions and respectfully, We are demanding changes.

In case you are not aware, The Office of Inspector General Office just released its findings of the FDAs handling of the 2007 pet food recall.  Below is an excerpt.

FDA has developed procedures for monitoring recalls and assessing a firms recall effectiveness.  However, FDA did not always follow its procedures in overseeing three of the five recalls that we reviewed.  Furthermore, FDAs procedures were not always adequate for monitoring large recalls.  FDAs lack of authority, coupled with its sometimes lax adherence to its recall guidance and internal procedures and the inadequacy of some of those procedures, limited FDAs ability to ensure that contaminated pet food was promptly removed from retailers shelves http://oig.hhs.gov/oas/reports/region1/10701503.asp

There is NO excuse.  Countless pets, countless family members died because of FDA lax adherence to its recall guidance and internal procedures. 

In September, 2007, Congress initiated into law FDAAA.  Although you should be aware of the following, we provide it to you as reminder.

Section 1002 (a) of FDAAA requires the FDA to establish pet food ingredient standards and definitions, processing standards for pet food, and provide updated standards for the labeling of pet food that include nutrition and ingredient information.  These new standards and definitions must be established within two years (September 2007-September 2009).

The FDA has NOT completed this task.

FDAAA Section 1002 (b) applies to an early warning system and notification system during a pet food recall. This section regarding to a recall warning and notification system must be in place within one year (September 2007-September 2008). 

Although the deadline is almost a year past, the FDA has NOT completed this task.

Is it acceptable to the 111th Congress to mandate law and the FDA ignore it?

As well, although over 50 members of Congress were alerted to an FDA policy that allows pet food ingredients to violate Federal Law, we remind you:

To give you a complete understanding, here are the applicable quotes from the Food, Drug, and Cosmetic Act laws.   http://www.fda.gov/opacom/laws/fdcact/fdcact3.htm

  • Section 201 (f) provides the definition of food: The term food means (1) articles used for food or drink for man or other animals, (2) chewing gum, and (3) articles used for components of any such article.  
  • Section 301 Prohibited Acts and Penalties: (a) The introduction or delivery for introduction into interstate commerce of any food, drug, device, or cosmetic that is adulterated or misbranded.  (c) The receipt in interstate commerce of any food, drug, device, or cosmetic that is adulterated or misbranded, and the delivery or proffered delivery thereof for pay or otherwise.
  • Section 402 Adulterated food:  A food shall be deemed to be adulterated (a) Poisonous, insanitary, or deleterious ingredients.(a)(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;

Now, here is what the FDA website states about Federal Law 402(a)(5):

201CPet food consisting of material from diseased animals or animals which have died otherwise than by slaughter, which is in violation of 402(a)(5) will not ordinarily be actionable, if it is not otherwise in violation of the law.  It will be considered fit for animal consumption.

http://www.fda.gov/ora/compliance_ref/cpg/cpgvet/cpg690-300.html

Again, this is not acceptable.  Federal Laws have been designed to protect our pets, yet the FDA ignores Federal Law.

Is it acceptable to the 111th Congress that an FDA policy ignores Federal Law?

Pet owners have begun a Powerful and Determined grass roots effort.  Our mission is to gain the attention of the 111th Congress.  We insist the FDA abide by the Federal Food, Drug, and Cosmetic Act.  We insist the FDA be overhauled BEFORE another deadly pet food recall takes another of our furry family.

Respectfully, we insist.

Respectfully, pet owners are conservatively 148 Million Voting Citizens; should you ignore our plea as in the past, our votes will be given to your opponent come re-election time.  Now is the time for Congress to require the FDA to abide by the Federal Laws you developed!

It remains puzzling to each and every one of us; pet food safety issues always seem to be ignored by everyone of Federal authority.  Again, respectfully, we understand there are many pertinent issues on your desk, however, in light of The Office of Inspector General report, we insist pet food safety to be included as a pertinent issue each of you are concerned about and are actively working to change.

Sincerely,

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