Skip to main content

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


Labels:

Comments

Post a Comment

Popular posts from this blog

FDA Refuses To Speak Via Phone To Veterinarians & Consumers Regarding Ongoing Regulatory Issues With Aflatoxin

Today, FDA confirmed they would not be granting phone call requests in relation to longstanding and ongoing regulatory issues with aflatoxin in dry pet foods, mainly dry pet foods produced with the ingredient corn.  For years, Dr. Steven Solomon and other federal employees of FDA-CVM (Center for Veterinary Medicine) have continuously refused to speak to consumers, consumer groups, and members of the educational field regarding the myriad of issues surrounding various regulatory actions by FDA-CVM. Why wouldn't the FDA-CVM want to have open, honest, and continuous dialogue with the regulated consumers, or with the veterinary field?  For years, FDA-CVM has been regulating the pet food industry by what they call their "opinion", instead of a properly passed rule. It has also been discovered that employees of FDA-CVM held secret meetings with the major grain and dry pet food lobbying group AFIA, where FDA-CVM actually worked with AFIA to stifle regulations that would have bro...
8 comments
Read more

How To Submit Comment Re: FDA (FDA-CVM) 2023 budget

FDA-CVM is continuing their refusal to properly address various longstanding, and rectifiable issues. In their " 2023   Justification of Estimates for Appropriations Committees ", FDA writes glowingly about FDA-CVM regulatory actions. (FDA-CVM related material starts on page 172 https://www.fda.gov/media/157192/download).  FDA-CVM has continuously stated it can't meet its obligations under FOIA law because of "resources". FDA-CVM has also stated it doesn't have the resources to hold regular, public meetings. In its request for " $43 million in additional investments in food safety modernization, including animal food safety oversight ", FOIA is not mentioned. Public meetings are not mentioned. FDA-CVM does not make it known that there is significant interest from the public in these areas. The agency simply ignores the issues.  Part of my argument over the years is that FDA-CVM doesn't want, nor do they care to fix these issues. I believe part ...
Post a Comment
Read more

Shocked But Not Shocked By Newest FDA-CVM Admission Re: Salmonella

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,...
Post a Comment
Read more