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Stan Cook On Why States Are Copyrighting "Regulations"

With the growing concern over public state employees engaged in the privatization, copyright, and sale of official "regulations" for the animal feed (pet food) industry, a call was placed to Stan Cook, who works at the Missouri Department Of Agriculture. 

Mr. Cook has long helped operate the private non-profit corporation "AAFCO". Public employees are currently using a "non-profit" shield to perform their public regulatory work required by their state. Although the work performed at these meetings is for the strict purpose of being adopted by states as official and binding regulations in the states, these meetings are not currently deemed "public" meetings.  The public employees helping to run this private association, "charge" citizens on average $550 simply to attend the "regulatory meetings", where official definitions for pet food are proposed, written, and approved. This "non-profit", which is in reality a collection of public employees, can choose to "refuse access" to anyone they wish. 

On most occasions, public employees are using public funds to attend these private meetings. Public documents have shown state employees using their department funds, or sometimes FDA grant funds, to attend these private meetings. Official state "membership fees" are also paid with public funds. The travel fees to and from the meetings are paid with public funds. In a big twist, the work done by public employees do at these meetings is claimed as "copyrighted." Yes, the same employees who provided "free work" to this private corporation, on their publicly paid time, then uses even more public funds to "purchase" the "copyrighted material" from their own association. The organization then maintains that they receive substantial "revenue" from the sale of their "official publication", the copyrighting of official terms then adopted by states as "official regulations."

Many citizens who have attempted to access  these"regulations" in their home state are most often refused access to those regulations, with public employees stating they are not allowed to provide copies of the regulations due to "copyright law." 

Given his years of involvement with operating this private group in various positions, even in a president position, I called Stan Cook to ask a few questions, mainly why he as a public employee is knowingly and willingly adopting "copyright" material into state law. 

KOHL: I'm just trying to get an understanding of why Missouri adopting "AAFCO regulations" that are copyrighted, into feed regulations?

(10 second pause along with some stuttering)

STAN COOK (MISSOURI): So, your question is...

KOHL: Why are you adopting copyrighted material? Is the question. 

STAN COOK (MISSOURI): Well, for 109 years, uhh, uhh, feed control officials have met and tried to come up with descriptions of feed ingredients that everyone could understand and agree on so they could be traded. Ummm, and...I guess that's the reason why our feed laws over time have referred to those definitions. 

KOHL: Ok, the question being copyright and law. Why? Why that? 

STAN COOK (MISSOURI): Ummm. So, our law refers to and assures that feed ingredients, that are put in feed, ummm, and are traded, ummm, and they're agreed to by other states, and they're assured to be safe with a MOU with the FDA, to assure that they're safe. Ummm, and for one reason is for the protection of livestock and of humans. 

KOHL: Ok, the question again. You didn't answer it. Why is Missouri adopting copyrighted material into law? I can understand commonality and protection. I just don't understand why it's copyrighted, and you then adopt it into law knowing it's copyrighted. 

STAN COOK (MISSOURI): So, so for the feed officials to come together and agree on these descriptions, you know, it requires both the state and...It requires the state to submit that official's time and is a part of the state's investment is that individual. And for the association to historically, it has been able to meet through the sale of the official publication. And this has really been one of the larger income streams for the Association of American Feed Control Officials. And so a large reason why that document has been copied over history, or copyrighted, is to protect it for the sale, so feed officials can do what they have done in the interest of protecting the public, and the interest of common terms in the marketplace. Does that answer your question?

KOHL: Not really, because I know you're a public employee, and you get paid by public funds, so I'm a bit confused  

STAN COOK (MISSOURI): That's true. 

KOHL: Ok. I'm glad to confirm that's true. I appreciate that. So, you use public funds to go to AAFCO meetings. And you're doing the work there on your employee time. 


KOHL: And then you're taking...So, work done on your public employee time, with funds used to get you there, which are public funds. You're then copyrighting...or allowing to be copyrighted, by a private association which you are as a public employee. That's my confusion. The confusion here is, public funds, public funds, public funds. But...private copyright! So, if it really is about the protection of you know, the feed supply and transparency to citizens, why copyright it? Why not offer it to everyone for free? That's the big question for Stan Cook, the lovely administrator for Missouri Department Of Agriculture. 

STAN COOK (MISSOURI): Well, we couldn't operate the association if we didn't have an income stream. 

KOHL: Stan, how could you guys not get together with public funds? You're getting together with public funds. You could still use public funds to get together, and offer the information publicly. 

STAN COOK (MISSOURI): But we also, it would take a lot more public funds ummm, you know, ummm, to be able to do what we do 

KOHL: I don't know what that means. To do what you're able to do. You're doing a public job. What are you doing beyond your public job at AAFCO meetings, then?

STAN COOK (MISSOURI): I think you know what we do...

KOHL: I actually don't. So, could you tell me?

STAN COOK (MISSOURI): If you've been to meetings, I think you know what is in the official publication. I think you know those discussions that take place. 

KOHL: Hold on, let's dial it back. I've been to one meeting. You voted to have me banned from other meetings. I know that. I know what happens at the meetings is that official definitions are proposed, written, and passed and then adopted back at the state (as regulation). This question of public funds. You use public funds to get there. You use public funds to be a member. You actually purchase the OP with public funds. You do work for the OP, that's then copyrighted, and you then use public funds to purchase that...

STAN COOK (MISSOURI): Hey Kohl, what time is it?

KOHL: No "hey Kohl", I'm asking a question. So please just let me finish. 

STAN COOK (MISSOURI): What time is it? What time it is?

KOHL: Are you refusing to have a conversation with me all of a sudden?

STAN COOK (MISSOURI): I'm just asking you a question. 

KOHL: And my questions got uncomfortable for you?

STAN COOK (MISSOURI): You know what I'm doing here?

KOHL: You don't want to answer what you're really doing. 

STAN COOK (MISSOURI): It's after state hours .

KOHL: Ok. Actually, that's an interesting question. All of the AAFCO business you do, you don't do it voluntarily. Does the AAFCO business you do, is that only on state time? Or do you do it voluntarily? I'm confused by that. AAFCO says you're a volunteer. I don't see any volunteer time on your own personal time. I see state department of agriculture time. 

STAN COOK (MISSOURI): Can you answer me what time it is?

KOHL: I wanted to finish asking my question, but you continue to cut me off. I know at AAFCO meetings, you propose, write, pass regulations, for feed definitions you adopt at your department of agriculture. And it's all with public funds you say you couldn't operate AAFCO without those public funds. Why? What other stuff do you do there? I just don't understand how this is for the public when it's privatized essentially through copyright. That's the question you don't want to answer, that you're trying to skirt around now. What time is it? Well, it's time for you to tell the truth. 

STAN COOK (MISSOURI): I've told you why historically, it's been copyrighted. 

KOHL: You're a department of agriculture employee, getting paid publicly, and you're copyrighting it. So, you're essentially keeping that away from the public with your participation in that. That's why I'm calling you. Why are you as a public employee allowing for your work to be copyrighted? You're not using your personal funds to do this work. You're using public funds, and you're allowing it to be copyrighted. That's the big question. 

STAN COOK (MISSOURI): I think I've answered your question. 

KOHL: You actually didn't. Why are you involved in an association, you're essentially doing regulatory work to be copyrighted, and privatized. Why are you doing that? You could do it publicly, or do you disagree with that? Are you saying you can't do this stuff publicly? 


KOHL: Ha, ha? Can you do it publicly? I think the answer is yes, but you're not willing to do it publicly. But prove me wrong. 

STAN COOK (MISSOURI): I think your attended a meeting. 

KOHL: I attended one meeting. What I can see is that you can do it publicly (without charging citizens $550) but you're doing it privately (and charging citizens to attend regulatory meetings). That's my question. Can you do it all "publicly"? Or are you saying no? You can't develop regulations for animal feed (pet food) publicly? 

[25 second pause, no response from STAN COOK]

KOHL: No answer?

STAN COOK (MISSOURI): I think I've answered your question. 

STAN cook hangs up phone. 



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