Answers Official Response to AVMA
24 July 2012 (Re-posted with permission.)
American Veterinary Medical Association (AVMA)
Attn: Rene A. Carlson, DVM, President
1931 North Meacham Road, Suite 100
Schaumburg, IL 60173-4360
P: 800.248.2862; F: 847.925.1329
RE: AVMA Council on Public Health and Regulatory Veterinary Medicine recommended creating policy: RESOLUTION #5-2012 Regular Annual Session Submitted by AVMA Executive Board “POLICY ON RAW OR UNDERCOOKED ANIMAL-SOURCE PROTEIN IN CAT AND DOG DIETS”; July 15, 2012 issue of JAVMA (Journal for the American Veterinary Medical Association, Volume 241, no. 2, page 163)
Dear AVMA President Carlson:
We respectfully submit and request consideration of our comments on behalf of ANSWERS PET FOOD, a raw pet food manufacturer regarding AVMA’s recommendation to create policy: RESOLUTION #5-2012 Regular Annual Session Submitted by AVMA Executive Board “POLICY ON RAW OR UNDERCOOKED ANIMAL-SOURCE PROTEIN IN CAT AND DOG DIETS”. In summary as stated in the July 15, 2012 issue of JAVMA (Journal for the American Veterinary Medical Association, Volume 241, no. 2, page 163)
The AVMA Council on Public Health and Regulatory Veterinary Medicine recommended creating policy ‘Raw or Undercooked Animal-Source Protein in Cat and Dog Diets.’ The board forwarded the recommendations to the HOD as a resolution. According to the draft policy:
‘The AVMA discourages the feeding to cats and dogs of any animal source protein that has not first been subjected to a process to eliminate pathogens because of risk of illness to cats and dogs as well as humans.’
The draft policy provides back-ground of raw food in pet diets and recommends precautions to mitigate public health risks.”
Within the draft resolution itself it goes on and states:
Cooking or pasteurization through the application of heat until the protein reaches an internal temperature adequate to destroy pathogenic organisms has been the traditional method used to eliminate pathogens in animal-source protein, although the AVMA recognizes that newer technologies and other methods such as irradiation are constantly being developed and implemented.’
ANSWERS PET FOOD is a member of an informal but joint consortium of U.S. raw pet food manufacturers (“Consortium of Raw Pet Food Manufacturers” or “Consortium”). The Consortium is comprised of manufacturers of raw pet food products. The Consortium represents a significant presence of United States commerce within the industry and has a vital interest in the outcome of the above referenced recommended policy. Due to the short time constraints between learning of the proposed action by AVMA and scheduled vote that would effectuate the policy, there was inadequate time to prepare a joint response by the Consortium as a whole. ANSWERS PET FOOD desires to not only provide the AVMA (their officers, Board Members and Council on Public Health and Regulatory Veterinary Medicine) with review comments, but with recommendations for consideration on mitigating the serious concerns surrounding AVMA’s proposed action and our concerns involving this matter as an active participant in the raw pet food industry, as well as offer to meet, discuss and work with representatives of AVMA’s Council on Public Health and Regulatory Veterinary Medicine to create a more unbiased and scientifically supported recommended policy. Roxanne Stone, ANSWERS Vice President of Research and Development, has a Master’s Degree in Food Science with emphasis in Dairy Science and a Bachelor of Science Degree in Food Science with a Minor in Chemistry and over 12 years’ experience as a Senior Food Scientist in research, product development, project management, consumer research and team leadership roles in the global food industry. She also in the Principal Food Scientist in Cascadia Food Consulting.
Why Consider Raw Pet Food Industry Comments and Participation?
We recognize the proposed Resolution is an AVMA policy and not regulation or law and therefore some individuals or parties may try to argue that the raw pet food companies should not be allowed to provide comments, express concerns, and play a role in working with the AVMA to develop policy surrounding raw diets in pet foods. Such an argument would be counterintuitive and in contrast to AVMA Bylaws, where it states
“… the objective of the Association shall be to advance the science and art of veterinary medicine, including its relationship to public health, biological science, and agriculture.”
…The mission of the Association is to improve animal and human health and advance the veterinary medical profession.”
If AVMA develops policy behind closed doors without the ability for public and industry comment, how can AVMA advance its relationship to the public, science and animal health and welfare industries? If this is the common practice then how was Delta Society (now Pet Partners) able to bring this issue to the AVMA Council on Public Health and Regulatory Veterinary Medicine (CPHRVM) through the Animal Welfare Division staff? Even more questions arise when looking at the Delta Society much closer. According to Pet Partners website, the Chair of the Board, Brenda Bax, is the Marketing Director of Purina. Also, under the AVMA financial documents there is disclosure that the AVMA receives significant contributions from Hill’s Pet Nutrition, Inc. To our knowledge, neither Purina nor Hill’s Pet Nutrition offer a raw source protein for cat or dog diets. This questioning of Purina’s influence is not new (see 5/24/2010 article by Susan Thixton in Exhibit A – Did Purina Executive Influence Delta Society’s Ban of Raw Feeding?). In addition, the following is reported under “The Domino Effect” written by by Susan Thixton 7-20-2012 posted on www.truthaboutpetfood.com:
“For those unaware, in 2010 The Delta Society – a national charity that trains and organizes pet visitations to the sick and elderly – made a pet food shattering decision to ban all Pet Partners that feed an all raw meat pet food. And then it was discovered…on the executive board of the Delta Society – when the Delta Society made this raw pet food ban – was Brenda Bax…Marketing Director, Purina Pet Foods. It was more than clear to many raw pet food advocates, Purina Pet Food’s Brenda Bax played a significant role in Delta Society’s decision to ban raw pet food fed dogs from participating (further, all participant dogs now volunteering for Delta Society wear a Purina patch on their harness/banner – walking advertisement for Purina Pet Foods).”
Even if as a matter of practice AVMA does not involve the public and industry in developing policy recommendations, AVMA has related responsibilities as a Not-for-Profit entity under Illinois State law. Under Attorney General Lisa Madigan’s Consumer Protection Division website it provides guidance and responsibilities of licensed Not-For-Profit Organizations to avoid conflicts of interest in conducting association business and to protect Illinois consumers and businesses victimized by fraud, deception, and unfair business practices. While AVMA does not implement law directly, AVMA’s position on an animal related subject matter has a huge impact on legislation and regulatory matters, accreditation of medical veterinary colleges and setting of standards for medical veterinary education, setting standards for veterinary practice, educating the public, supporting scientific research, and providing guidance to wellness programs, information and resources as pointed out on your website under AVMA Membership Benefits, Programs, Resources and Services. Such a stated role for a Not-for-Profit organization comes with a huge responsibility of ensuring conduct is not prejudicial; presenting unbiased science research and findings; being fair, honest and balanced in the presentation of all facts and debates; ensuring policies do not become anticompetitive; taking on only those issues that properly serve the stated purpose of the organization and much more.
Obviously this is an important issue to many pet owners, veterinarians, and others (see petition against AVMA’s proposed policy gaining considerable support at http://www.change.org/petitions/american-veterinary-medical-association-avma-protect-pet-owners-rights-to-feed-a-raw-meat-pet-food#). It is hoped AVMA will not close its door on the face of the raw pet food industry and raw pet food feeders who are also customers of AVMA and will not push forward with bad policy. It is hoped the AVMA will provide the raw pet food industry an equal opportunity and seat at the table for discussion; input for creation of policy; presentation of scientific evidence, pet owner and veterinarian testimonials and other demonstrations of the benefits of raw diet to the health and welfare of dogs and cats. After all ANSWERS PET FOOD shares in, and complements AVMA’s objective and mission statement to provide product that is safe for pet consumption and, with proper handling, safe for humans, supported by scientific research and findings through the education and advice of veterinarian professionals ANSWERS’s new tag line on our products is “Integrating Raw Feeding & Science”.
Raw Pet Food Manufacturers Must Comply with the same Regulations as Processed Pet Food Manufacturers
It is unclear why AVMA would single out the raw pet food industry? The raw pet food manufacturers must follow and comply with the same regulations as processed pet food manufacturers. Exhibit B – “Salmonella Infection (salmonellosis) and Animals” is a reference page from The National Center for Disease Control (CDC). This public recommendation report clearly points to DRY, HEAT PROCESSED dog and cat food as sources of contamination and the data from the many recalls support this position. It can be seen there has been more reported recalls associated with processed diet pet foods than raw diet pet foods. (See Exhibit C – “Pet Food Recall Products List”). Exhibit D – “Salmonella from Dry Pet Food and Treats” provides tips to help prevent an infection with Salmonella from handling dry pet food and treats:
An important distinction between raw pet food and raw human food prior to consumption is that the human food manufacturers do not expect humans to consume raw meat or poultry while raw pet food manufacturers do intend for pets to consume their products in a raw state. Thus, some raw pet food manufacturers prepare their raw pet food products with proven effective microbial reduction steps (without cooking, irradiation, and high pressure pasteurization), resulting in product that is safe for pet consumption and, with proper handling, safe for humans.
The Statement about the Resolution indicates the CPHRVM reviewed the available scientific literature and determined that an AVMA policy was needed to address public health risks associated with raw protein diets in companion animals. Did the CPHRVM balance the scientific literature with findings of raw diets and is all this scientific literature supported with real, un-debatable statistics? Did the AVMA recommend creating policy addressing the handling and risks associated with processed pet foods? With the numerous Salmonella recalls for kibble and treats and most recently the Diamond dry food recall that sickened numerous people, it would be appropriate for the AVMA to develop a safe handling recommendation for all pet foods, raw, kibble, canned and treats instead of unfairly singling out only raw pet food. By singling out raw pet food the AVMA creates the unsafe assumption that processed food does not contain pathogens which historically is proven to be not true.
All Ready In-Place Recognized Guidance
Data demonstrates that canine and feline pets can benefit from a raw food diet. USDA’s Food Safety and Inspection Service (FSIS) has shown in its regulation of poultry and meat industries that proper labeling, safe handling instructions, and consumer education can dramatically reduce the potential of cross-contamination and any related risk to human health from this pathogen. Moreover, it is well established that Salmonella does not present to animals the same safety hazard that it presents to humans. In addition, implementation of manufacturing best practices can reduce the level of pathogens and further reduce risk to animals and humans.
In 2004, FDA issued Guidance for Industry – Manufacture and Labeling of Raw Meat Foods for Companion and Captive Noncompanion Carnivores and Omnivores. This Guidance document included direction to the industry to incorporate good manufacturing practices to reduce the presence of Salmonella, and the raw pet food industry has accepted and implemented many of the principles outlined in the 2004 Guidance. Except for a few minor exceptions to certain statements in the 2004 Guidance, the raw pet food industry has embraced the 2004 Guidance and has successfully adjusted its manufacturing to produce safe and wholesome raw pet food products.
Clarify that Irradiation and Pasteurization Does Not Apply to Raw Pet Food
Many view irradiation and pasteurization as a potential kill step for raw pet food. Irradiation and pasteurization essentially changes and “cooks” raw meat and would be inconsistent with the principles of serving raw meat/poultry to animals. Moreover, ANSWERS PET FOOD disagrees that the use of irradiation is a safe and effective method for controlling pathogens in commercial pet food due to the disturbing epidemiological evidence that resulted in the recall of a particular brand of irradiated dry cat food in Australia between June 2008 and March 2009. There was also additional evidence from the follow up studies that further investigated the link between irradiated pet food and brain and spinal cord degeneration in cats. Studies showed that varying degrees of Wallerian degeneration in the spinal cord and brain associated with leukoencephalomyelopathy, Para Paresis, and tetra paresis could be induced in cats fed an irradiated diet.
There have been varying opinions within the pet food industry concerning the process of High Pressure Pasteurization (or Processing), often referred to as HPP. ANSWERS PET FOOD reviewed scientific data and established our position regarding HPP on the research and conclusive facts about this technology. It has been shown that HPP negatively affects proteins, enzymes, vitamins and essential fatty acids in foods, especially in meats. Please see Exhibit E for more information on HPP from our website www.answerspetfood.com.
Working with Raw Pet Food Manufacturers and Feeders
If AVMA will work with raw pet food manufacturers and feeders rather than in isolation of them, AVMA will be in a better position to determine what policy recommendations if any are needed. ANSWERS PET FOOD and other interested parties would appreciate the opportunity to take an active, progressive and cooperative role in a relationship with AVMA and the FDA to promote a unified correct message of healthy nutrition and safe practices and provide non-misleading and non-confusing, unbiased educational materials to better serve the pet owner and their pets. Other examples of benefits of working together in an appropriate cooperative environment between the Consortium, AVMA and FDA would be to accelerate development and implementation of industry guidelines and parameters such as adopting a Hazard Analysis Critical Control Points (HACCP) plan for the raw pet food industry, developing more appropriate quantitative analysis testing programs rather than “rapid testing methods” such as polymerase chain reaction (PCR) and probe assays for a better indication of the actual pathogenic loads in the feed product, rather than a simple negative or positive result, and implementing internal manufacturing best practices and consumer best handling practices. Thus, ANSWERS PET FOOD recommends that AVMA develop an appropriate professional relationship with the raw pet food industry in parallel with the processed dry kibble, treats, and canned foods, creating a greater and significant joint effort to promote a safe and healthy industry.
ANSWERS PET FOOD has serious concerns about the draft of AVMA’s recommended policy on raw animal-source protein in cat and dog food diets and impact if approved and adopted as written. Such a policy does not consider the benefits of a raw diet and the impact on the raw pet food industry, consumers, and veterinarians that currently recommend raw diets. The policy also does not reflect the low risk presented to animals and humans by raw pet food, and does not acknowledge that the risk to pets and humans can be significantly reduced by proper education and safe handling instructions.
Accordingly, ANSWERS PET FOOD respectfully recommends the following to AVMA:
Table a vote on RESOLUTION #5-2012 Regular Annual Session Submitted by AVMA Executive Board “POLICY ON RAW OR UNDERCOOKED ANIMAL-SOURCE PROTEIN IN CAT AND DOG DIETS indefinitely or until the following actions are considered:
1. Follow AVMA’s Bylaws and responsibilities and have the Judicial Council investigate (or better yet perhaps oversee an outside independent investigation with findings made available to the public) to:
- (i) Investigate the general professional conditions and all matters pertaining to the relations of the AVMA Councils, Committees and Officers to industry related companies, their personnel and contributors associated with potential policy influence and make recommendations to the Executive Board, House of Delegates, or the organizations represented in the House of Delegates as it deems necessary.
(ii) Investigate conduct considered prejudicial to the best interests of, or inconsistent with, the purposes of the AVMA as defined in Article 1, Section 2 of the Association’s Bylaws and other governing documents and guidelines of AVMA.
(iii) Determine if AVMA’s Council on Public Health and Regulatory Veterinary Medicine (CPHRVM) presented balanced unbiased information in creating the proposed policy recommendations.
(iv) Determine if the relationship of Delta Society and members of its Board of Directors presents a conflict of interest in their role and involvement in this matter.
(v) Determine if AVMA is pursuing an action that would violate Illinois State Law under status and certification as a Not-for Profit organizations that is intended to protect Illinois consumers and businesses victimized by fraud, deception, and unfair business practices.
2. Bring balance and develop a proper cooperative working relationship between AVMA and the raw pet food manufacturers with a focus on education and enhanced safe handling labeling to protect humans from cross-contamination and to ensure wholesome, unadulterated product for the animals.
3. Recognize the raw pet food industry in parallel with the dry kibble, treats, and canned foods, creating a significant joint effort between AVMA and the raw pet food industry to promote a safe and healthy industry.
4. Recognize irradiation and pasteurization are not an option for raw pet food as they are inconsistent with providing a nutritious raw pet food diet.
5. Consider the impact of the proposed policy to the raw pet food manufacturers, raw pet food feeders, and veterinarians that currently recommend raw diets in a risk/benefit analysis.
Thank you for the opportunity to provide comments to AVMA for consideration. ANSWERS PET FOOD is eager to further collaborate with AVMA to discuss the draft policy and create a viable industry framework that will allow the continued marketing of safe and healthy raw pet food. Unless otherwise noted, these comments are the sole opinions of ANSWERS PET FOOD who does not speak for any other party. If the AVMA is willing to meet with ANSWERS PET FOOD, raw pet food diet feeders, and veterinarians who recommend and have witnessed the benefits of such diets, please contact me to coordinate the arrangements. Given the size of this document with attachments and since we do not have the e-mail addresses of the parties identified below, ANSWERS would appreciate very much if AVMA arrange to forward a copy of this letter to the parties identified below and others they deem appropriate.
Thank you again and we look forward to hearing from the AVMA.
Lystn, LLC dba/ANSWERS PET FOOD
Keith A. Hill
Roxanne Stone, MS Food Science
Vice President of R&D and Procurement
 Guidance for Industry – Manufacture and Labeling of Raw Meat Foods for Companion and Captive Noncompanion Carnivores and Omnivores (May 18, 2004, revised November 9, 2004) (hereinafter “2004 Guidance”).
 To supply FDA with a complete understanding on the Consortium’s view of the subject matter, the Consortium provided abbreviated comments on the 2004 Guidance in Appendix C of the comments.
 Caulfield, CD, et al. (2009) The Experimental Induction of Leukoencephalomyelopathy in Cats. Vet Pathol 46:1258-1269; Child, G, et al. (2009). Ataxia and paralysis in cats in Australia associated with exposure to an imported gamma-irradiated commercial dry pet food. AVJ 87(9): 349-350.
Exhibit B – Salmonella Infection (salmonellosis) and Animals
Exhibit C – Pet Food Recall Products List
Exhibit D – Salmonella from Dry Pet Food and Treats
Exhibit E – HIGH PRESSURE PASTEURIZATION ≠ RAW
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Page updated 11 August 2014.