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Showing posts from January, 2021

"Please, Do Not Share, Forward, Discuss Nor Distribute My Previously Emailed Document"- George Ferguson Of North Carolina Department Of Agriculture

In recent files obtained via FOIA, George Ferguson of North Carolina shared his insights about his own state department's involvement in trying to privatize the term "human grade" via the private corporation AAFCO, of which his state would intern "adopt" via reference. In essence, Mr. Ferguson as a public employee involved with other employees in trying to privatize the regulation process for the pet food industry. There are many moral questions surrounding public employees such as George Ferguson of North Carolina Department Of Agriculture. He has personally been involved in calling citizens foul names, and helping to "restrict access" to AAFCO meetings for certain citizens. This could also be called a ban.  In one email, Mr. Ferguson states " I have also added a couple of pages of my own thoughts/comments that I believe the committee and any subsequent workgroup should consider if/when a decision is made to move forward with the AMS partnership

Pet Schooled Challenges FDA's Refusal To Comply With Law & Post DCM Related Records Publicly

Pet Schooled has submitted an official citizen petition to FDA, sending a warning shot to FDA about their refusal to comply with FOIA law and post frequently requested records on the public FDA FOIA reading room. This matter concerns a FOIA (freedom of information act) request for records relating to FDA's "DCM investigation."  FDA originally refused to provide the original requestor for these records, Daniel Shulof, with the records. Mr. Shulof sued and challenged FDA's illegal refusal in federal court. FDA was forced to produce records and have been producing records in "batches" to Mr. Shulof for over a year and a half now.  FDA has also refused to provide Pet Schooled with copies of these records, leading to another FOIA lawsuit in response to FDA's direct violation of FOIA law.  Many other requests for the same records have been submitted to FDA. According to law, more than 3 requests for the same records requires FDA to publicly publish those recor

Conversation With FDA's Eric Nelson, On FDA Regulating By "Opinion"

I have been wishing to speak to Eric Nelson of FDA for quite some time. Over the years, I have asked public state employees why they are regulating based on their opinion. One consistent name has come up time and time again as I have been looking into this legal issue. I'll quote one specific state department of agriculture employee here. "We just follow what FDA tells us to do at the meetings." The "meetings" beings referenced here are private AAFCO meetings, where FDA engages in official rule making functions in a private setting, right next to representatives of Hills, Purina, and other major companies that have long dominated the pet food market. I asked this state employee, "who at the FDA is giving you instructions, which you then follow without question?" After a bit of back and forth, the state employee said, "Eric Nelson."  Over this years, I have also documented how this FDA employee has engaged in attempting to whitewash the entire

John Dillard, AAFCO's "Lawyer", Speaks About Public Employees Copyrighting Regulations

Today (January 4, 2021), I called Mr. John Dillard who acts as a lawyer for "AAFCO", a group of public employees operating as a private corporation. This group of public employees holds meetings twice a year so they can create "official feed definitions" for pet food and animal feed ingredients. Essentially, public rulemaking is being done in "private" at these meetings, and then the public employes ensure their "regulatory work" is copyrighted. FDA has been heavily involved in this private process as well.  When public employees write an "official feed definition", most then "reference" that official feed definition in their state laws. My conversations with various state feed control officials over the past few years has confirmed that once most states adopt "aafco feed definitions" into their state's feed law, those definitions then become law.  Once those definitions become law, citizens are met with a bizarr

Tennessee Department Of Agriculture's Mark Powell On Why They Adopt Copyrighted AAFCO Material Into Their State Law

Below are notes from a September 9th, 2020 phone call I had with Mark Powell of the Tennessee Department Of Agriculture. I called Mr. Powell to get an understanding as to what Tennessee considers to be actual regulations in their state, and if they're adapting copyrighted AAFCO material into their law as well.  Kohl: I'm trying to understand how I can see pet food definitions in the state of Tennessee. I can't find the information on your website. So, I'm trying to see what the feed definitions are for the state of Tennessee for pet food and animal feed.  Mark Powell TN Department Of Agriculture: We have adopted the AAFCO feed ingredients.  Kohl: What does that mean, adopted? Mark Powell TN Department Of Agriculture: Tennessee is a member of the Association Of American Feed Control Officials. They produce an official publication which contains rules and regulations. They go through a lengthy process to adopt feed ingredients and we just adopt those into our feed law.  K