Regulatory approaches to ensure the safety of pet food Sentient Submission
←
→
Page content transcription
If your browser does not render page correctly, please read the page content below
Regulatory approaches to ensure the safety of pet food
Submission 113
The Veterinary Institute for Animal Ethics
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
PO Box 223, Oatley NSW, 2223 www.sentient.org.au contactus@sentient.org.auRegulatory approaches to ensure the safety of pet food
Submission 113
The Veterinary Institute for Animal Ethics
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-recalled-
170508
PO Box 223, Oatley NSW, 2223 www.sentient.org.au contactus@sentient.org.auRegulatory approaches to ensure the safety of pet food
Submission 113
The Veterinary Institute for Animal Ethics
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-voluntarily-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
PO Box 223, Oatley NSW, 2223 www.sentient.org.au contactus@sentient.org.auRegulatory approaches to ensure the safety of pet food
Submission 113
The Veterinary Institute for Animal Ethics
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
PO Box 223, Oatley NSW, 2223 www.sentient.org.au contactus@sentient.org.auRegulatory approaches to ensure the safety of pet food
Submission 113
The Veterinary Institute for Animal Ethics
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/default.htm
PO Box 223, Oatley NSW, 2223 www.sentient.org.au contactus@sentient.org.auYou can also read
