Meeting Being Planned to Obtain Public Input for Ensuring the Safety of Pet Food

June 13, 2008 Division of Dockets Management (HFA-305) Food and Drug Administration 5630 Fishers Lane, Room 1061 Rockville, MD 20852 Re: Docket No. 2007-N-0442 – Opportunity for Public Input on Standards for Pet Food and Other Animal Feeds; Notice of Meeting Dear Sir or Madam: The American Veterinary Medical Association (AVMA) is the world's largest veterinary association, representing nearly 85% of our nation's veterinarians. The mission of the AVMA is to advance the science and art of veterinary medicine. As veterinarians, our utmost concern is our nation's public health and the health of our animals. We appreciate the opportunity to provide recommendations on labeling and safety standards for pet foods, as the FDA implements the mandates set forth within the Food and Drug Administration Amendments Act of 2007. The FDA is to be commended on its engagement with stakeholders and the general public on these issues, which are so important for the health of our nation's pets. The AVMA has three specific recommendations for the FDA to consider during its planning and implementation process: 1. Modification of the labels on pet foods with health claims Today's marketplace contains a wide variety of pet foods. Specific pet foods range from regional specialty and private label foods to national corporate brands. They are also provided in a vast array of forms, including raw, frozen, freeze dried, canned, semi-moist and dry foods. Furthermore, these products are sold through a gamut of different retail outlets – supermarkets, feed stores, groomers, boutiques and large format pet stores, as well as veterinary facilities. There is also an ever-increasing trend to include various health claims on pet foods. Clearly these health claims promote that the food does more than just meet nutritional requirements of the healthy animal. For example, a food might be marketed for senior dogs with the claim that it will improve joint health via inclusion of certain specific nutrients. The AVMA also recognizes that by federal mandate, the FDA regulates pet foods, but it has elected to utilize a significant degree of enforcement discretion in its oversight of pet foods with health claims. Many foods with health claims are only available through veterinarians to ensure professional supervision of foods with potent therapeutic effects. Veterinarians are expected to be able to discern whether the claims are substantiated, or not, before recommending them to their clients. This is a real challenge, considering the vast numbers of such pet foods, and the varying levels of available evidence supporting such claims. The AVMA's concern is that veterinarians may not have all the evidence that they need, to verify that such foods do what they purport to do before recommending it for their patients. Therefore, in the interest of pet safety, the AVMA recommends the FDA require all pet food products with implied or explicit health or drug claims to include a prominent statement on the label, indicating that such claims have not been evaluated or verified by the FDA. Requiring such disclaimers on pet foods bearing health claims would enhance transparency and dissemination of accurate and truthful information to veterinarians, pet retailers and consumers. In the absence of this disclaimer, some veterinarians and the majority of consumers will continue to assume that pet food claims are, in fact, substantiated and enforced by the FDA the same as human food health claims. This misconception has far-reaching consequences, including misinformation to consumers, potential licensure liabilities to practicing veterinarians who recommend such foods, and most importantly, the health and well-being of pets. Moreover, animals that are "treated" with foods containing drug claims, in lieu of drugs approved by the FDA for specific diseases, may not receive appropriate medical treatment in a timely manner. 2…