2003N-0312 - Animal Feed Safety System: Risk Based Safety Program
FDA Comment Number : EC4
Submitter : Dr. Paul Maas Risenhoover Date & Time: 04/19/2004 03:04:01
Organization : Victims of Pedigree Pet Food Mycotoxin Poisoning
Consumer Group
Category :
Issue Areas/Comments
(6) enforce Section 341 of the Federal Food, Drug and Cosmetic Act regarding the quality of pet food, to ensure that products marketed as a quality pet foods do not contain diseased animal meats or bones or skins or feathers, nor mycotoxins or heavy metals.
(7) enforce Section 346 of the Federal Food, Drug and Cosmetic Act by requiring HACCP in the entire pet food chain
from cereal grower field to production and distribution and veterinary clinics to ensure accurate and timely public health biosurveillance epidemiological information and prevent mycotoxins in pet food.
(8) enforce Section 342 of the Federal Food, Drug and Cosmetic Act to forbid adulterated pet food products containing heavy metals or mycotoxins, and impose the duty to test all pet food products in each batch to ensure no poisonous or deleterious substance such as mycotoxin toxic poisons are present, and impose the duty of clinical safety proof on pet food makers to show that any actual substance in their pet foods in its actual quantities in that pet food batch is actually safe for health of both animals and humans who may come into contact with it through normal foreseeable means such as tasting, touching, inhaling, and the like.
(9) enforce Administrative Detentions of pet food products in the US or entering the US or leaving the US, and constructive detention abroad in cooperation with makers and foreign governments or entities of any pet food not shown completely absent of mycotoxins.