Skip to main content

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 John Dillard. This attorney has long been the same exact attorney for a lobbying group called AFIA. They're the largest grain focused lobbying group in the pet food industry. Literally, the regulators hired the same attorney as some of the regulated industry. 

This raises serious questions re: FDA-CVM regulating by opinion, not law. By FDA-CVM continuing to do this, it stands to benefit AFIA, not the consumer, nor the pet. FDA-CVM continuing to promulgate regulations for interstate commerce animal ingredients in private, instead of via private meetings, stands to benefit AFIA, not the consumer. I have submitted citizen petitions on each issue and FDA-CVM has not provided a final response on either issue. 

I care about my government, and I deeply disagree with these continued actions by the FDA. I found it interesting that new commissioner Califf stated, "I promise each member of the FDA team and the American people my commitment to doing the best I can, relying on the integrity of science and the FDA’s continued application of science in meeting our awe-inspiring responsibilities," as FDA-CVM literally does the opposite, and regulates by opinion and makes regulations as privately as possible. 

While I understand FDA has to deal with competing interests, and while my interests as a citizen may not line up with the interests of AFIA or the "interests of FDA" for that matter, surely we can agree that science and law are important here. FDA-CVM has been showing us all that science and law are not important to their branch, and this needs to change. 

-Kohl Harrington


Labels:

Comments

Post a Comment

Popular posts from this blog

Questions Regarding Answers' Lawsuit Against Kure Pet Food & Independent Farmers

WHY WOULD TWO WOMEN LEAVE THEIR OWN PET FOOD COMPANY? According to court documents, Roxanne Stone and Jacqueline Hill left Lystn and its Companies because Keith Hill was self-dealing by paying himself additional fees and profits through Lystn to his own independent consulting company; Roxanne and Jacqueline would have stayed with Lystn and Companies if Keith would have stepped-down as CEO, which they had requested because of his potential misconduct.  According to court testimony, Roxanne Stone and Jacqueline Hill had multiple meetings and attempted to rectify these serious issues prior to finally disassociating from the company they pioneered .  KEITH HILL AND DERRICK HILL REMAIN SILENCE REGARDING MONETARY MOVES Keith Hill's lawyer currently appears to be trying to make people believe that "all the facts" were reviewed in this case. However, the misconduct allegations of Keith Hill, which appear to be the very heart of why Jacqueline and Roxanne left Answers Pet Food, ha
1 comment
Read more

AAFCO Removes State Regulator Information From Their Website

Earlier this year, any citizen could visit the AAFCO website and find their state feed control official who currently participates in this private corporation. AAFCO has apparently publicly removed the names and contact information of state feed control officials who are involved in and helping to operate this “private corporation.” This private corporation of public regulators isn’t always the most “transparent” group of people, and this recent move is one more display of angst public regulators are having against citizens who are questioning this shadow government organization. In the below photo, you can see the old version of the AAFCO website, which clearly shows that George Ferguson is the main state feed control official contact. In the current version of the AAFCO website, this information has been removed. The main state feed control official contact information is no longer available. The division director information is no longer available. Over the past few years, a growing
1 comment
Read more

FDA Refuses To Speak Via Phone To Veterinarians & Consumers Regarding Ongoing Regulatory Issues With Aflatoxin

Today, FDA confirmed they would not be granting phone call requests in relation to longstanding and ongoing regulatory issues with aflatoxin in dry pet foods, mainly dry pet foods produced with the ingredient corn.  For years, Dr. Steven Solomon and other federal employees of FDA-CVM (Center for Veterinary Medicine) have continuously refused to speak to consumers, consumer groups, and members of the educational field regarding the myriad of issues surrounding various regulatory actions by FDA-CVM. Why wouldn't the FDA-CVM want to have open, honest, and continuous dialogue with the regulated consumers, or with the veterinary field?  For years, FDA-CVM has been regulating the pet food industry by what they call their "opinion", instead of a properly passed rule. It has also been discovered that employees of FDA-CVM held secret meetings with the major grain and dry pet food lobbying group AFIA, where FDA-CVM actually worked with AFIA to stifle regulations that would have bro
8 comments
Read more