FDA On Why They're Not Researching Obesity And Cancer Epidemics

On December 3, 2020, Ali Kashani and Ashlee Rose Ferguson of the Washington Department Of Agriculture received and email asking about epidemics not being investigated by "regulatory" officials. Mr. Kashani and Ms. Ferguson both communicate directly with various FDA officials on a variety of issues, including FDA's "DCM investigation", and FDA's "zero tolerance" policy targeting raw pet food via "opinion", not law. So, why isn't FDA and states investigating potentially two of the largest epidemics in the pet food industry, obesity and cancer? Could it be that "investigating" the obesity epidemic could lead to agencies having to admit that ingredients such as grains could be a major issue here? And with the cancer epidemic? Is food actually involved here, and if so, does the questionably low quality of ingredients regulatory allows in pet food have anything to do with the industry's high cancer rate?

The email stated, "Hello again, I just wanted to follow up on my email from November 18th. I never heard from you guys on this really important issue. I am trying to figure out what is being done to address the obesity epidemic and cancer epidemic in dogs and cats, in Washington? Do you know of any investigations being done into these issues, that could be related to food being consumed by the animals? I was told by the department of health that the agriculture department regulates food products in the state, and that I would need to write someone at your department, and that you guys may work with the FDA as well. Has FDA brought this issue up to you guys at all? Just let me know if you have any information on this concern."

Mr. Kashani responded, "To address pet obesity through diets, Washington Administrative Code (WAC) 16-252-118 requires label of pet food to include calorie content statement to inform the purchaser of the food product of the energy content of the food. Furthermore, WAC 16-252-106 requires feeding directions on the label of pet foods. The above two regulations are attempts to help pet food purchasers to make informed decision to prevent consumption of extra/excess calories to cause obesity.

In reference to cancer, as I am sure you would agree, we have much less substantiated information on causes of cancer related to food or food ingredients in general. We collect samples of pet food for analysis of contaminants. We also work closely with FDA, the federal agency with much more resources and expertise, to identify if food could be cause of illnesses. However, we are not a research institution/agency and must work within the confine of the regulations. If there are known dietary causes of cancer, and we have reasons to believe the levels in the food may be of concern and we have capability to detect the contaminant quantitatively by validated laboratory methods, we would take samples to determine the level in the food and if necessary take regulatory action."

The same date, the Mr. Kashani received a reply with more questions. "Thank you for the response. I actually do not agree with your information on cancer. It's not a topic of debate that both cancer and obesity are extreme public health issues with dogs and cats, and I'm confused as to why no state and federal agencies are working together to investigate these issues. Obesity and cancer rates in dogs are at estimated 50% rates. My inquiry was to try and figure out what public health officials are doing to address both issues. As I now understand a bit better from your response, WA state is doing nothing, and FDA
doesn't appear to be doing anything either. Obviously the label issue you pointed out is not working otherwise we wouldn't have this health epidemic. Consumers have a choice to feed what they wish, and educate themselves. I just know from my own experience, the labeling of pet food doesn't actually clearly define the amount of sugar in pet foods, and amount of calories. The pet food labeling process requires a lot of math, when AAFCO (you) could simply require pet foods to be labeled with more clear information.

At the federal level, and I'm aware you're not a federal agency, but the FDA launched some form of investigation on "DCM" linked to grain free foods, yet that issue isn't affecting animals nearly at the rate that cancer and obesity are. You state you work closely with the FDA, so I'd like to know how investigations into cancer and obesity epidemics can happen since you work closely with the FDA. If DCM can be investigated, so can pet food's link to the massive percentage of causes for obesity and cancer. This would really help inform consumers and allow us to have more trust in public health officials, where these situations have long gone ignored.

As I see that you work with FDA through your participation at AAFCO, I don't believe it's too far of a stretch for me to expect you to bring this issue to the attention of your federal working partners, since nothing is being done within the state of Washington. It is odd that the FDA wouldn't want to see cancer and obesity rates decrease.

I could be wrong, but in my looking into this issue, your AAFCO group approves ingredients for use in pet foods. So, if dogs and cats are eating foods where you and your colleagues are part of approving the ingredients for, and dogs and cats are suffering from health effects most likely linked to the foods, you're a public health official directly linked to these epidemics. It's confusing as to why you would allow for this. I don't accept the excuse that you have to "work within the confine of the regulations" because you're heavily involved in the animal feed ingredient definition process, that become "regulations" for ingredients allowed to be used in pet food. So you're not a total independent body when it comes to these
regulations.

I am sure you would agree, it would be very irresponsible for you to be so involved in this regulatory process, yet turn a blind eye when you're potentially causing grave harm to so many animals.

Hopefully you can provide me some assurance that you'll raise this topic to the FDA so these epidemics can start to be resolved. That's all I ask."

Now, this is where it gets interesting. 

Mr. Kashani then responded, "Thank you for your response and expression of your position. You can be sure I share your concerns with FDA. Best Regards! Ali."

That's a sort of "writing off" of the consumer, if you will, that regulatory often does. Regulatory is rarely challenged. Yet here, they appear to have been challenged and it seems to have lead somewhere. 

The consumer then questioned, "Thank you! How will you do this exactly?"

Mr. Kashani responded, "How about sharing your email with the agency to begin with? Furthermore, discussing it on either virtual meeting or a telephone call."

The consumer wrote back, "I don't understand what that means exactly. I'm trying to understand

who at FDA you'll report this concern to, and how you'll report it."

Mr. Kashani said, "I already sent a copy of your email to the Director of Division of Animal Feeds, Center for Veterinary Medicine, Office of Surveillance and Compliance, U.S. Food and Drug Administration. This is the most appropriate office, I know, that would review your concerns and information and if need be they will forward it to others."

The consumer then said, "Who is that person? Name?"

Mr. Kashani said, "Here is Dr. David Edwards contact information: David Edwards, PhD

Director, Division of Animal Feeds, Center for Veterinary Medicine, Office of Surveillance and Compliance, U.S. Food and Drug Administration Tel: 240-402-6205, david.edwards@fda.hhs.gov."

The consumer then looped in David Edwards from FDA, cc'ing him on the communication, saying, "I remember seeing his name on the DCM investigation, and I just looked him up and cc'd him here so I can be officially sure that FDA is fully aware of this. I always found it odd that DCM and "grain free pet food" sold at (boutique pet stores) was the identification there. It sounded almost as if Dave Edwards was acting on behalf of the interests of dry grain food. I know with AAFCO, Hills/PFI sits on the panels with FDA etc., and FDA seemed to target raw pet food sales with their compliance policy opinion, and "grainfree" with their DCM "investigation". That's just an outsider's point of view. I would highly argue that Dave Edwards and yourself really do care about health, yet when reviewing the actions, I just don't understand how any connection to high grain pet foods, health issues such as obesity and cancer, is somehow conveniently ignored by FDA-CVM and Dave Edwards. I'm just amazed that public health officials are not

launching investigations on these issues. This is super serious.

Given that obesity and cancer are serious issues, much more of issues than DCM ever was, it will be interesting to see if he ignores the epidemics or agrees that an investigation is then needed. We shall see."

David Edwards of FDA responded, saying, "Thank you for your concern about the health issues that impact our pets.  As federal regulatory officials (and pet lovers), we, too, hold the health of our pets in high regard.  At the FDA we serve as the scientific reviewers for FDA animal food additive and AAFCO feed ingredient definitions.  In these duties we evaluate the hazards posed by new ingredients that are to be introduced into animal (including pet) food.  We have statutory responsibilities to look at the genotoxicity (cancer causing) potential of these ingredients, and we have rejected ingredients over the years that do not meet the necessary standards. 

Fortunately/unfortunately, our pets are living longer lives now, which gives the opportunity for random mutations to occur within their cells as they divide over time.  These may impact certain portions of their DNA, which may impact the predisposition for cancer cells to arise.

We also share concerns about obese pets, as this condition can lead to other health problems down the road.  Many of the labeling provisions for pet foods are contained in the model bills/regulations that are developed by AAFCO and adopted by the states.  The FDA is a member of AAFCO, and we believe it helps promote consistency of regulatory requirements, thus making it easier for consumers to get the information they need to see on labels.  We look to rely on the best science we can find to drive the decisions that are made for the health and well-being of all animals. 

We appreciate your interest in these issues.  Best wishes"

The consumer responded, "Mr. Edwards, thank you for the reply. Just to confirm, FDA currently has no investigations into matters of the possible link of certain pet foods being linked to the massive

issues of obesity, and cancer?

FDA has never investigated the potential link regarding either of these matters.

While I appreciate your response and the information you provided, my question that still remains is if FDA will be opening official investigations into these matters? If not, then why? These are really huge issues, especially when compared to DCM, which FDA opened an investigation on."

David Edwards the said, "I would characterize it as that we continuously look for signals that substances added to animal food are safe or are they causing safety issues.  These issues include those directly influenced by contaminants in foods, issues directly because of foods, and other signals that we see related to foods.  We work to ascertain if animal health is being impacted by something in the food according to the signals that we see in the scientific literature or are reported to us.

Food substances that are cancer causing are screened at pre-market review of animal food substances.  Other causes of cancer are not under our purvey.  If scientific evidence of cancer from a food substance has been published, we would be interested in seeing it as it impacts not only our work, but also our pets at home."

The consumer shot back, "Thank you. So, there are no FDA investigations into the potential link

between processed diets and obesity, and no FDA investigations into the potential link between processed diets and cancer? I didn't see that in the last response and just want to make sure I understand what FDA is doing there."

There was then no reply from David Edwards. Four days later on December 8, 2020, the consumer followed up. "I am following up on my email from December 4th. I wanted to get that official clarity from you."

David Edwards said, "The FDA's regulatory authority extends to the individual substances in a diet, unless there is a contaminant present in the complete food.  We do evaluate every ingredient that comes into our agency for its potential link to cancer.  We do rely on animal nutritionists to utilize good feeding practices to account for caloric needs of the animals.  These feeding directions do appear on labels of pet foods."

The consumer responded, "I understand that, although something may be wrong with your

evaluation process, if so many dogs are developing cancer. Why is FDA-CVM looking into DCM as an investigation into a potential link for food, yet FDA is completely ignoring or refusing to look into an estimated 50% cancer epidemic in dogs, potentially linked to food as well? Obesity is a massive epidemic, potentially linked to foods and
the ingredients FDA approved.

Why would FDA-CVM take the stance of ignoring two serious health epidemics, instead of conducting official investigations on the issues and reporting the information and findings to the public? I just want to understand why FDA launches and publicizes an investigation into one issue yet ignores more serious issues. Your responses haven't helped me understand that.

If you want to take the obesity epidemic and say it's the consumer's fault, which you may be alluding to with "feeding directions appear on the labels of foods." Ok, let's toss that to the side for a moment. Why ignore the cancer epidemic and not look into the potential link of dog and cat cancers and their potential link to foods on the market?"

David Edwards again went silent, and two days later on December 10th, 2020, the consumer followed up again. David Edwards then responded, "In all of our investigations, we rely on the scientific literature/scientific studies to evaluate the safety of the food ingredients presented to us.  We carefully review that and then make decisions that are risk- and science-based to protect human and animal health.  Please do pass along the studies and/or literature linking cancer to the food, so that our scientists can review them."

The consumer asked, "Is there any current FDA investigation into the link of cancer and

processed foods on the market? That's the question I keep asking."

David Edwards went silent again. Four days later on December 14, 2020, the consumer wrote David Edwards again. "Hello once again! Is there any current FDA investigation into the link of cancer and processed foods on the market? That's the question I keep asking. Thanks so much." David Edwards responded, "As I have previously outlined, but I will reiterate, our reviews of ingredients prior to going to market include looking for possible carcinogens.  I would propose that means we are looking for links to cancer in every ingredient review we perform (and we perform ingredient reviews daily). We are also always looking for new information to help inform our decisions.  If you can point us to scientific literature linking cancer and processed foods, we would appreciate that."

The final reply in this exchange came from the consumer, who concluded, "I'll take that as a no. If it's a yes, I'll invite you to prove me otherwise. I can't believe I can't get a yes or no, but I'll take your responses as a full force no, FDA-CVM is not conducting any investigations on the matter."