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FDA Finally To Hold Public Meeting About Their Involvement In Private Corporation "AAFCO"

After years and a growing amount of citizen petitions from members of the public, FDA is holding a "virtual public meeting" on February 9, 2023 to discuss their ongoing relationship with AAFCO. As we know, AAFCO is a collection of public regulators who FDA refers to as their "regulatory partners". These public regulators are creating regulations and law in private, and those regulations are specifically designed for products in FDA regulatory jurisdiction. In addition to holding the public meeting, FDA is accepting electronic or written comments through March 9, 2023. To electronically submit comments to the docket, visit regulations.gov and type “FDA-2022-N-3122” in the search box. While calendar records reveal FDA-CVM employees found an abundance of time to personally meet with lobbying groups over the years, many citizens have reported that FDA-CVM has completely ignored dozens (or possibly hundreds) of their questions over the past few years. For those that have
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FOIA Request Reveals Severe Lack Of FDA-CVM Records On HPP

Years ago, I had a back and forth with FDA where the media department refused to specific whether "raw" pet food that had been subjected to HPP (high pressure pasteurization) had been subjected to a kill step or not. The FDA stated "HPP can be a kill step when effectively done, however, it must be properly validated to confirm the effectiveness in a pet food product. " I then asked FDA: Please define or provide me documents on "when effectively done" means as per FDA.  What does FDA deem to be properly validated to confirm the effectiveness in a pet food product? Does FDA approve a pet food company's use as HPP as effective or non effective before they implement this in their foods? After FDA-CVM refused to provide me further information, I filed a FOIA request with the agency for records on this matter. I eventually had to sue the agency under FOIA law, and force the agency to comply with my FOIA request. Years later, I finally have what FDA-CVM is st

My Senate Testimony RE: 2023 Budget Request By FDA-CVM For Additional $48 Million

April 12, 2022 To: United States Senate Committee On Appropriations  Re: the U.S. Food and Drug Administration's fiscal year 2023 budget (the following was submitted to agri@appro.senate.gov, and Angela_Caalim@appro.senate.gov was cc'd.) Daily, I am attempting to be a proactive citizen and exercise the right all Americans are told we should be proud of...which include our being a government "by the people". While I don't disagree that democracy is "messy", what democracy shouldn't be is government against the people.  In my experience over the years, that is what I have faced. I and what appears to be many others, are still facing FDA-CVM battle against us in completely unnecessary ways. I wish to testify about this regarding FDA asking for billions in their new budget.  FDA-Center for Veterinary Medicine (FDA-CVM) holds no regular public meetings when it comes to promulgating regulations for the pet food industry. FDA-CVM instead "sits on the b

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

Pissy Email From FDA-CVM Simply More Evidence Of Agency's Ongoing Anti-Citizen & Anti Democracy Campaigns

It seems like many more citizens other than myself are now experiencing first hand, what I've been reporting on for more than 10 years now. A federal agency, FDA-CVM (Center For Veterinary Medicine), ill equipped to actually regulate, leading to a highly unregulated pet food industry . On top of that, years long FOIA delays, FDA-CVM employees engages in promulgating regulations in private, FDA-CVM employees regulating by "opinion" instead of law, while refusing to enforce federal law when it comes to many circumstances surrounding big dry pet food. Most disturbingly, FDA-CVM employees telling citizens their only opportunity to engage in rule making is to petition the government by filing citizen petitions, then the agency's failure to provide final answers on citizen petitions, and additional refusals to commit to a date in which the agency will be providing a final response.  FDA-CVM's latest email to me on March 16, 2022 from their anonymous ASK CVM email addres

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

Democracy Comes After FDA-CVM

People have power. Ordinary people, you and I , have power ! That is an INCREDIBLE aspect of our country, but sadly it's not exercised by almost all citizens. I can understand. It's difficult to juggle it all. You have to wake up, go to work. Most people have kids, bills, and are probably only scraping by. Playing an active role as a proactive citizen is difficult. It takes serious work and focus, and you have to figure out how to keep plowing through when all the cards are stacked against you.  The regulatory officials at FDA-CVM and most states know this as well, and they know it first hand. For almost their entire existence, they've been able to get away with regulating by their "opinion", making regulations in private, and respectfully, misleading the public on a variety of issues relating to human and animal health. One thing I've analyzed over the past decade is how some of these "pet food" topics are very nuanced and complicated, and how FDA-C