Amid rising cases of highly pathogenic avian influenza (HPAI) – particularly the poultry virus crossing species and infecting cattle, AAFCO recently made a public statement defending the safety of a controversial legally defined feed ingredient – poultry litter (chicken poop).
On May 2, 2024, AAFCO said:
“There are several news articles indicating that poultry farms may be the culprit behind the spread of HPAI in US dairy cattle. Although this is theoretically possible, it is likely that the disease was spread by eating the animal.”
AAFCO’s statement – telling the public that the organization believes chicken manure feed ingredients are safe – crosses a very delicate line. Regulation that forms an opinion and acts on that opinion – can easily result in a failed investigation.
The individuals that make up AAFCO’s membership are employees of State Departments of Agriculture and FDA. So, the regulator makes the decision/forms the opinion that a substance is safe BEFORE a full investigation is completed. This action on regulatory opinions is a big problem, this attitude prevents proper investigations to be carried out.
Regulators at AAFCO have developed legal definitions with the objective of manufacturers complying with safety requirements. BUT…without a full investigation, regulators don’t know if safety requirements have been met. By forming a public opinion that a substance is safe based on legal safety requirements – without knowing whether a manufacturer has actually complied with those safety requirements…blocks a proper investigation.
By forming an opinion like this, regulators can decide the outcome of an investigation before it is completed.
We see the same problematic attitude in the current pet food investigation. Several State Department of Agriculture agencies have issued an opinion that pet food is safe – expressing that opinion to the pet owner. When a regulatory representative collected pet food samples directly from a pet owner whose pet had died – the regulatory officer told the grieving pet owner “You have no chance of proving that there is a pet food problem.”
Do regulatory opinions result in failed or delayed investigations?
It certainly can – and perhaps is a problem with the current concern over pet food and the spread of HPAI.
And in case you didn’t know…
AAFCO has legal definitions of many waste ingredients. This includes:
Dry Poultry Litter
Dried Poultry Waste is NPN extracted
Dried Chicken Spread
Dry Ruminant Waste
Dry Pig Litter
Undried Processed Animal Waste Products
Processed Animal Derivatives
Sad but true, all of the above ingredients are legally allowed to be used in animal feed, which is often used in animal feed.
Personal opinion (I’m not regulatory, I can have an opinion): Of course there is a problem with feeding animals processed waste. You can cook it, grind it, color it…but it’s still $#!*.
Wishing you and your pet(s) the best,
Susan Thixton
Pet Food Safety Advocate
Buyer Beware of Author, Co-Author Dinner PAWsible
TruthaboutPetFood.com
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