I provided evidence at the public hearings into the safety of pet food on Tuesday the 28th of August, 2018 in Sydney. Here you can read my oral and written submissions.
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I went there to put forward the demands of ordinary pet owners. You can be sure that industry was well-represented but what about you? We needed the opinions of ordinary consumers and average Australian pet owners.
Submission by Dr Andrew Spanner
Oral presentation to the inquiry
Earlier this year a dog named Millie was brought into my practice in Adelaide suffering from kidney failure. Our testing showed that she had Fanconi Syndrome, which is a disease that we now mostly see as a result of jerky treats like these.
It’s the existence of products like this that highlights where we stand at the moment. For a pet food to be successful, it doesn’t necessarily have to be safe.
Cases like Millie’s have been happening regularly across Australia since at least 2007 to the point that we as vets only shrug and carry on.
The current state of pet food regulation means that there is nothing anyone can do to change it.
There’s no organisation to which I can report this adverse event in order to collect the data that would prove what’s happening.
Even if we prove it, there’s no way this product can be removed from sale without the agreement of the pet store and manufacturer.
Most importantly, there’s no way pet owners can be warned about products like these.
If I’m tempted to warn pet owners myself, I will be likely to face legal action. It’s happened to vets like me in the past over the same issue.
And this is only one example. Australia has had one of the least regulated pet food industries in the developed world, far behind the UK, Europe, USA, Japan and New Zealand.
We have an entirely trust-based system. Any one of us could start making pet food tomorrow and there would be no way of regulating how we make it or stopping us if needed
This fact shocks Australian pet owners. They expect pet food to be as safe as human food, and in fact, they usually just assume that it is. This inquiry is our best chance to meet their expectations. They aren’t going to do it themselves, but need our help.
The reason is clear. Manufactured pet food remains vital for the health of our pets. Most Australian pet food is already of a good standard. Effective regulation needs to support these manufacturers in making a high-quality product, not marginalise them.
I also want to debunk the myth of needing to know the cause before initiating a recall. The father of this science identified a water supply in London as the source of cholera 30 years before the cause was identified.
All we need is a statistical link between the food and the disease. We don’t need to know why.
If we don’t use science, we risk being prey to scaremongering and social media campaigns that will do untold damage to innocent companies.
In closing, I would like to summarise the six key planks of a successful regulatory framework
The 6 Tenets of Successful Pet Food Regulation
- Labelling to include all ingredients including preservatives
- Declaration of treatments such as irradiation
- Clear distinction between balanced foods and treats
- Minimum standards for pet food ingredients
- Transparent adverse event reporting and investigation
- A body enabled by legislation to enforce recalls as a last resort
Human health implications of pet foods- Salmonella in the USA
Reply to question from senators:
Cause of megaoesophagus
- Any obstruction (e.g. PRAA vascular ring anomaly, foreign body, neoplasia, stricture)
- Dysautonomia (Key-Gaskell syndrome)
- Myasthenia Gravis
- Hypoadrenocorticism & hypothyroidism
- Lead & thallium toxicity
In this case, neurotoxins or induction of autoimmune disease would be in my opinion most likely to explain the Dermocare events.
(I now am less dogmatic about using the Australian standard if the above 6 points are met)
Dr Andrew Spanner BVSc(Hons), MVetStud
121 North East Road
Collinswood SA 5081
Thank you for the opportunity to submit a response to the Senate inquiry. My particular interest as a community veterinarian is to act as an advocate for the average Australian pet owner.
I will address the terms of reference in the order they are presented.
a. the uptake, compliance and efficacy of the Australian Standard for the Manufacturing & Marketing of Pet Food (AS5812:2017);
All pet owners expect that pet food in Australia should be regulated in the same way as human foods. The use of an Australian Standard seems inconsistent with this goal.
I ask that the Australia New Zealand Food Standards Code (ANZFSC) be extended to cover pet foods. The equalisation of pet and human food standards would elevate Australia to a world leader in pet food safety from its current low position.
The pet food industry would have a valid concern over costs. To this, I would assert that the ANZFSC only mirrors the industry’s existing claims for safety. If costs were to affect the affordability of pet foods to all pet owners, then a compromise could be reached where AS5812:2017 could be the lower of a two-tier structure. The higher aim should always be to implement the ANZFSC for pet foods.
Specific benefits that would occur requiring no change in the codes include:
- Effective labelling
- The declaration of preservatives (currently a problem in ‘fresh’ pet meats)
- The regulation of chemical residues (excess thyroid hormone and drugs used for euthanasia are common causes of US pet food recalls)
- Regulation of Salmonella and Listeria monocytogenes contamination
- Mandatory declaration of treatments applied to foods such as irradiation
- Quantification of ‘characterising ingredients’ (e.g. how much salmon is in Dine ‘with salmon’?)
- Health claims including the amount of the substance (quantifying ‘with Omega 3” for example)
- Minimum standards of quality for all ingredients
- Prohibition of the use of meats from livestock that fail inspection for human consumption
Suggested pet-specific amendments could be:
- Complete ban on food irradiation (allowed for some human foods but fatal to cats)
- Additional banned foods and additives (alcohol, cocoa, grapes and grape products, macadamia nuts, onion & garlic, xylitol)
- Creation of two prescribed names for foods: “Complete and Balanced
- Food for (species)” and “Treat for (species): Not a complete food”
- Exemption from current (human) declaration of foods such as egg, crustacea, gluten, nuts (except macadamia), lupins, sesame seeds, soybeans, milk (where lactose-free)
- Nutrition Information Panel can be simplified. The existing pet food
- Guaranteed Analysis would be adequate with the addition of energy content, carbohydrates and sodium (currently voluntary and mostly undeclared)
b. the labelling and nutritional requirements for domestically manufactured pet food;
Current labelling requirements for food made or sold in Australia are wholly inadequate for pet safety. Ingredient lists are not legislated, and therefore voluntary and often incomplete. Preservatives and food treatments are commonly not declared. Changes must also apply to ‘treats’, ‘snacks’ and ‘supplements’.
Accurate labelling of ingredients can be easily implemented with minimal negative impact on reputable manufacturers and suppliers. As stated earlier, adoption of the rules governing labelling of foods for human consumption would resolve all outstanding concerns.
Existing guidelines on nutritional standards established by AAFCO appear to be acceptable, but require enforcement.
c. the management, efficacy and promotion of the AVA-PFIAA administered PetFAST tracking system;
The PetFAST system is a well-intentioned response to earlier pet food safety problems. However, as it currently stands, it is ineffective in improving pet food safety. The reasons for this are:
- The lack of awareness by vets as a portal for submission, possibly a result of the low rate of AVA membership among Australian vets
- Veterinarians only being able to make reports
- The likely low number of submissions being made
- The lack of reporting of submissions received
- The voluntary nature of adverse findings or recommendations made to pet food manufacturers
- The secrecy of these findings
- The potential conflict of interest caused by funding of the AVA by the pet food industry
- Few or no recalls initiated through the program since its establishment
An ideal monitoring body should:
- have no affiliations or commercial links with any other stakeholders
- be accessible to all Australians
- produce regular transparent reports
- be able to make mandatory orders where necessary
d. the feasibility of an independent body to regulate pet food standards, or an extension of Food Standards Australia New Zealand’s remit;
I believe that an extension of the remit of FSANZ is the most effective and practical solution but would support any workable proposal. See my comments regarding the Food Standards Code above.
e. the voluntary and/or mandatory recall framework of pet food products;
It is essential that a successful recall framework allow reporting from all sectors of society and not be limited to veterinarians. The APVMA adverse event reporting system is a good example of public access.
Should such a regulator be established, I expect there will initially be a high demand for regulatory oversight in clearing the market of non-complying products. However, in the long term I expect it will follow the USA model where the presence of a watchdog organisation and effective legislation will cause most companies to initiate voluntary recalls before being mandated to do so. The observed ‘laissez faire’ safety culture in our pet food industry is also likely to undergo rapid change in the face of a watchdog with teeth.
PetFAST shows the deficiencies of a voluntary system. The creation of a mandatory system is essential both in raising standards, and encouraging manufacturers to be proactive in initiating their own voluntary recalls.
f. the interaction of state, territory and federal legislation;
No specific comment
g. comparisons with international approaches to the regulation of pet food; and
The Food and Drug Administration of the USA, while not perfect, represents the closest to a successful regulatory model, and administers frequent recalls. It is telling (as stated earlier) that most recalls appear to be voluntary. It is also telling to compare the rate of recalls in the USA with those in Australia (roughly one a week versus one every five years).
My knowledge of international regulation is limited to the influence of the USA system on Australia. An example of the system working well was melamine contamination of pet foods in 2007. This problem was likely worldwide but only detected and recalled in the USA. Australia then saw voluntary recalls of those same food brands recalled in the USA. Others that were not sold in the USA and therefore not subject to US regulation likely escaped detection.
The recent Advance Dermocare deaths and the ongoing chicken jerky poisonings in Australia, show the consequences of lacking a reporting or recall system. A properly functioning pet food regulation, monitoring and recall system will allow consumers to regain faith in the Australian pet food industry. Informed consumers are increasingly choosing foods manufactured in countries with better regulation, or attempting to make their own.
h. any other related matters.
Despite the errors of the past, correctly formulated commercial pet foods remain the safest option for the vast majority of pet owners. It would be a disaster for animal health if the Senate inquiry led to the reputation of pet foods being damaged to the point that pet owners feel compelled to try to construct diets themselves.
Pet owners want the food they buy for their pets to be made with the same standards as their own food. One hopes that this, at last, is their opportunity to be heard.
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