Regulatory approaches to ensure the safety of pet food Sentient Submission

Regulatory approaches to ensure the safety of pet food Sentient Submission

The Veterinary Institute for Animal Ethics PO Box 223, Oatley NSW, 2223 www.sentient.org.au contactus@sentient.org.au Regulatory approaches to ensure the safety of pet food Sentient Submission 27 July 27 2018 Executive Summary Sentient, The Veterinary Institute for Animal Ethics, is an independent national association of veterinarians, veterinary students and associate members that is solely dedicated to promoting animal welfare and ethics. Sentient recognises that current safeguards for the safety of pet food are inadequate. Companion animals play an important role in our community with approximately 62% of households in Australia having a pet1. Pets are considered a vital part of the family and for many people may be a sole companion providing security and a sense of well-being. Thus, ensuring the health and welfare of Australian pets is a vital role for government. Currently, the pet food market is unregulated which has led to a number of adverse impacts, with some resulting in tragic outcomes where pets have suffered serious illness or death. This situation is unacceptable and cannot continue. Reliance on the self-regulation by the industry is not an option. Sentient has identified the following key strategies to address this situation: National oversight  Establish a national independent body to oversee the development, review, implementation and compliance of mandatory pet food standards; coordinate investigation of adverse events relating to pet food products including recalls; provide advice on relevant matters pertaining to pet food safety; investigate and assess overseas regulatory models for pet food safety.

 This could be achieved through extending the remit of Food Standards Australia New Zealand Mandatory standards  For all pet food products (including treats) sold in Australia (including imported food products) to meet mandatory standards (i.e. review and mandate Australian Standard for the Manufacturing and Marketing of Pet Food (AS5812:2017)  For all pet food meat  Investigate most appropriate legal mechanism for mandatory standards to be introduced pertaining to pet food safety at state/territory level  Investigate mandatory requirements for products containing sulphites regarding adequate thiamine content  Prohibit irradiation of any pet food products or treats 1 http://kb.rspca.org.au/how-many-pets-are-there-in-australia_58.html Regulatory approaches to ensure the safety of pet food Submission 113

The Veterinary Institute for Animal Ethics PO Box 223, Oatley NSW, 2223 www.sentient.org.au contactus@sentient.org.au Compliance and enforcement  Periodic auditing of pet food manufacturers against mandatory standards Reporting and response mechanisms  Support expansion of current PetFAST reporting system for veterinarians including requirement for annual reporting  Consider options for consumer reporting mechanisms for adverse events  Explore options for national mandatory pet food recalls 1. Introduction It is estimated that over 24 million pets are living in Australia, with the most commonly owned pets by household being dogs, followed by cats1. The human-animal bond is highly valued by our culture and is the subject of ongoing research into the physical and emotional benefits afforded to pet owners. Any negative and potentially tragic consequences of unsafe pet food have both animal welfare implications and financial and emotional implications for owners. Those of low socioeconomic status or whose only companions are their pets are especially vulnerable if faced by unaffordable veterinary expenses or the sudden loss of their companion animals.

Pet safety incidents associated with unsafe food have included the following:  In 2005, several cases reported of thiamine deficiency associated with sulphite preservative in pet meat were reported in cats and dogs2  In 2008, an incident involving Orijen cat food caused paralysis, seizures and deaths in a number of cats3  In 2009, a case was reported of neurological disorder in a cat due to imported irradiated commercial food4  In 2017, a recall of Weruva BFF cat food was necessary following widespread illness in cats5  In 2018, a recall of Mars Dermocare dog food was necessary following an outbreak of megaoesophagus6 2 Malik R and Sibraa D (2005) Thiamine deficiency due to sulphur dioxide preservative in ‘pet meat’ – a case of déjà vu. Australian Veterinary Journal 83(7): 408-411.

3 AVA (2009) Orijen cat food. Australian Veterinary Association. Available from: https://www.ava.com.au/node/1067 4 Child et al (2009) Ataxia and paralysis in cats in Australia associated with exposure to an imported gamma-irradiated commercial dry pet food. Australian Veterinary Journal 87(9): 349-351. 5 Ibrahim T (2017) Best Feline Friend cat food recall after widespread illness. Choice. Available from: https://www.choice.com.au/outdoor/pets/products/articles/weruva-cat-food-re called- 170508 Regulatory approaches to ensure the safety of pet food Submission 113

The Veterinary Institute for Animal Ethics PO Box 223, Oatley NSW, 2223 www.sentient.org.au contactus@sentient.org.au 2. National oversight TOR (d) – The feasibility of an independent body to regulate pet food standards, or an extension of Food Standards Australia New Zealand’s remit To ensure national consistency, there is a need for national independent oversight of the regulation of pet food standards. Extending the remit of Food Standards Australia New Zealand would be an appropriate mechanism, rather than establishing a new body.

Key recommendations:  Extend the remit of Food Standards Australia New Zealand to act as an independent body to oversee pet food safety  The following responsibilities of a national independent body to include; o development, review, implementation and compliance of mandatory pet food standards; o coordinate investigation of adverse events relating to pet food products including recalls; o provide advice on relevant matters pertaining to pet food safety; o investigate and assess overseas regulatory models for pet food safety. 3. Mandatory standards TOR (a) – The uptake, compliance and efficacy of the Australian Standard for the Manufacturing and Marketing of Pet Food (AS5812:2017) The current 2017 version of this standard is voluntary and has limited availability. Although compliance with these standards is a requirement for membership of the Pet Food Industry Association of Australia (PFIAA), monitoring and compliance activities are not conducted. Given that only PFIAA members are required to comply, it is difficult to obtain evidence of the level of compliance. It is unlikely that non PFIAA members would comply with AS5812:20177.

TOR (b) – The labelling and nutritional requirements for domestically manufactured pet food The AS5812:2017 describes minimal standards for pet food labelling which covers all key nutrient information and content. This is particularly important regarding fresh meat which contains sulphite preservatives due to reduction in thiamine to a level that is potentially dangerous and could result in death. Key recommendations:  Conduct a review of the uptake and compliance with AS5812:2017 6 Rizmal Z (2018) Advance Dermocare dog food voluntarily recalled after megaoesophagus outbreak. ABC news. http://www.abc.net.au/news/2018-03-25/advance-dermocare-dog-food-voluntaril y-recalled- megaoesophagus/9584518 7 Standards Australia (2017) AS 5812:2017 Manufacturing and marketing of pet food. Available from: https://infostore.saiglobal.com/store/Details.aspx?ProductID=1932460 Regulatory approaches to ensure the safety of pet food Submission 113

The Veterinary Institute for Animal Ethics PO Box 223, Oatley NSW, 2223 www.sentient.org.au contactus@sentient.org.au  Review Australian Standard for the Manufacturing and Marketing of Pet Food (AS5812:2017) with view to converting to a mandatory standard including minimum standards for labelling of pet food products  Ensure mandatory standard is freely available 4. Compliance and enforcement TOR (f) – The interaction of state, territory and federal legislation Currently there is no state/territory legislation pertaining to pet food safety, except for the manufacture of fresh pet meat according to the Standard for the Hygienic Production of Pet Meat 2009 (PISC Technical Report 88)8. Sentient is not able to provide advice regarding appropriate mechanisms to facilitate introduction of mandatory requirements but supports the investigation of this. Key recommendations:  Investigate most appropriate legal mechanism for mandatory standards to be introduced pertaining to pet food safety at state/territory level. 5. Reporting and response mechanisms TOR (c) – The management, efficacy and promotion of the AVA-PFIAA administered PetFAST tracking system Although the PetFAST9 system has only been operating since 2012, it has enabled a degree of identification, consultation and response to adverse events on a national level. There are several limitations, however, which require further consideration. These include: o Insufficient details made publicly available regarding recalls o Lack of resources (system is managed largely by veterinarians on a voluntary basis) o Voluntary reporting system o Lack of coverage due to overseeing organisations being membership- based with remit not extending to non-members (pet food industry or veterinarians) o Does not provide an opportunity for pet owners to report adverse events as the system is only available to veterinarians TOR (e) – The voluntary and/or mandatory recall framework of pet food products Currently, there is no national mandatory framework for recalls of pet food products where a safety issue exists. This is unacceptable as reliance upon voluntary recalls is 8 CSIRO (2009) Standard for the Hygienic Production of Pet Meat – PISC Technical Report 88. Available from: https://www.publish.csiro.au/book/6180/ 9 AVA (2018) PetFAST – Pet Food Adverse Event System of Tracking. Available from: https://www.ava.com.au/petfast Regulatory approaches to ensure the safety of pet food Submission 113

The Veterinary Institute for Animal Ethics PO Box 223, Oatley NSW, 2223 www.sentient.org.au contactus@sentient.org.au unlikely to be effective in minimising risks to pets and associated distress to owners. Currently, pet food manufacturers are disinclined to initiate a product recall due to the immense financial and reputational costs. Key recommendations:  Support expansion of current PetFAST reporting system for veterinarians including requirement for annual reporting  Consider options for consumer reporting mechanisms for adverse events  Explore options for national mandatory pet food recalls 6. International approaches TOR (g) – Comparisons with international approaches to the regulation of pet food Sentient is aware of pet food regulatory systems in the EU10 and USA11 but we are not sufficiently familiar with details. It may be worth investigating these systems to consider aspects that could be applied to the Australian situation. Key recommendation  Investigate structure and function of international pet food regulatory systems in relation to the Australian situation.

Contact: Dr Rosemary Elliott, President Rosemary.Elliott@sentient.org.au 10 FEDIAF (2018) The regulation of pet food a warranty for hygiene, safety and quality. Available from: http://www.fediaf.org/self-regulation/legislation.html 11 USFDA (2018) Pet Food. Available from: https://www.fda.gov/animalveterinary/products/animalfoodfeeds/petfood/defau lt.htm Regulatory approaches to ensure the safety of pet food Submission 113

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