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My Letter To Former FDA Acting Commissioner, Janet Woodcock

Ms. Woodcock,

I am a proactive citizen who cares about FDA regulations by law, not opinion. FDA-CVM's branch is regulating certain aspects of the pet food/animal feed industry by a compliance policy, otherwise known as an opinion. The compliance policy FDA-CVM created contracts and further interpreted federal law. https://www.fda.gov/regulatory-information/search-fda-guidance-documents/cpg-sec-690800-compliance-policy-guide-salmonella-food-animals.

Additionally, FDA-CVM employees are engaging in rulemaking in PRIVATE, via a non profit corporation called AAFCO. I called Eric Nelson who works at FDA-CVM, and he stated you are the one forcing him to attend AAFCO meetings, develop regulations in private, and cutting us in the public out of the rulemaking process. 

Interestingly as I investigated this privatized regulation process, I came across the fact that public state and federal regulators who are acting under this private corporation shield, hired a private attorney named John Dillard. This attorney has long been the same exact attorney for a lobbying group called AFIA. They're the largest grain focused lobbying group in the pet food industry. Literally, the regulators hired the same attorney as some of the regulated industry. 

This raises serious questions re: FDA-CVM regulating by opinion, not law. By FDA-CVM continuing to do this, it stands to benefit AFIA, not the consumer, nor the pet. FDA-CVM continuing to promulgate regulations for interstate commerce animal ingredients in private, instead of via private meetings, stands to benefit AFIA, not the consumer. I have submitted citizen petitions on each issue and FDA-CVM has not provided a final response on either issue. 

I care about my government, and I deeply disagree with these continued actions by the FDA. I found it interesting that new commissioner Califf stated, "I promise each member of the FDA team and the American people my commitment to doing the best I can, relying on the integrity of science and the FDA’s continued application of science in meeting our awe-inspiring responsibilities," as FDA-CVM literally does the opposite, and regulates by opinion and makes regulations as privately as possible. 

While I understand FDA has to deal with competing interests, and while my interests as a citizen may not line up with the interests of AFIA or the "interests of FDA" for that matter, surely we can agree that science and law are important here. FDA-CVM has been showing us all that science and law are not important to their branch, and this needs to change. 

-Kohl Harrington


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