The FDA’s Center for Veterinary Medicine (CVM) is no stranger to public scrutiny, particularly when it comes to the transparency and inclusiveness of its regulatory processes. Recently, the FDA responded to calls for regular public rulemaking meetings by pointing to its "listening sessions" as evidence of public engagement. However, this response is deeply flawed and raises concerns about whether the FDA-CVM truly understands—or values—the distinction between listening sessions and public rulemaking meetings . What’s the Difference? Let’s be clear: listening sessions and public rulemaking meetings are fundamentally different in purpose, structure, and impact. Listening Sessions: Designed to collect public feedback on specific issues. Informal by nature, often involving pre-determined topics and limited discussion opportunities. Do not include deliberation, decision-making, or procedural steps leading directly to new rules or regulations. Provide no ongoing platform f
A recent FOIA request has forced FDA-CVM to admit facts many already suspected. In 2020, records were requested from FDA-CVM for "all records from FDA for cases where dogs or cats are confirmed to have died from salmonella after eating raw dog or raw cat food." The date range for the request for records was January 2017 through December 2019. Three years later in May 2023, FDA responded stating, "The Center For Veterinary Medicine has conducted a search and did not locate any records responsive to your request." Shocking. FDA-CVM has conducted an outright war against the raw pet food sector over the past five years. There are several issues with FDA-CVM's approach with a "zero tolerance policy." First, FDA-CVM considers even "non pathogenic" salmonella to be an "adulterant" for pet food. This means that even if the salmonella serotype is benign or known to be a serotype that will likely never cause a health issue to humans or pets,