FDA issued a press release at this time (March 28, 2022) that Bravo Packing pet meals (not affiliated with Bravo Pet Meals) will now not promote or distribute pet meals – not less than till the corporate comes “into compliance with the Federal Meals, Drug, and Beauty Act (FD&C Act).”
Bravo Packing had been issued a Warning Letter by FDA in 2020, citing harmful circumstances together with “heavy buildup of dried, darkish, crusty meat-like materials” on pet meals processing gear.
This pet meals firm can also be a lifeless animal hauler, for years they’ve been questioned about animal cruelty points.
The FDA press launch acknowledged: “The FDA has taken this motion to guard public well being as a result of, regardless of a number of inspections, notifications of violations, and remembers, this agency continued to function underneath insanitary circumstances and produce pet meals contaminated with dangerous micro organism. We is not going to tolerate corporations that put individuals or animals in danger and can take enforcement actions when wanted.”
The FDA’s concern with Bravo Packing was insanitary manufacturing circumstances and pathogenic micro organism within the pet meals. We agree that these points are severe and FDA took applicable motion with Bravo Packing. Nevertheless…
…the FDA took no motion in opposition to one other pet meals producer that was additionally discovered to supply pet meals underneath insanitary circumstances. In 2016 and in 2017 the FDA inspected the Mars Petcare facility in Columbus, Ohio. This Mars pet meals plant had a big downside with “German cockroach infestation” that was current within the 2016 inspection AND the 2017 inspection. The 2017 FDA inspection report of this Mars Petcare facility cited “thousands and thousands of roaches” stating: “The failure to take enough measure to exclude and forestall pests from the manufacturing and associated areas of the agency poses a big public well being security concern whereas additionally being a regulatory violation.” In contrast to the motion FDA took with Bravo Packing, FDA did completely nothing with Mars Petcare. No consent decree was issued to cease manufacturing of pet meals, no Warning Letter was issued. Within the case of Mars Petcare, FDA simply seemed the opposite means.
Dr. Steven Solomon (director FDA CVM) acknowledged within the press launch relating to Bravo Packing: “The meals we give our pets must be protected for them to eat and protected for individuals to deal with”.
The exact same Dr. Steven Solomon acknowledged this to TruthaboutPetFood.com in response to our Citizen Petition: “we don’t consider that the usage of diseased animals or animals that died in any other case than by slaughter to make animal meals poses a security concern and we intend to proceed to train enforcement discretion the place applicable.”
It’s very obscure how these phrases can come from the identical particular person. How can the veterinarian director of FDA Heart for Veterinary Drugs have concern for protected pet meals in a single second, whereas in one other second state diseased animals as pet meals elements are protected?
The FDA informed Bravo Packing they can’t manufacture or distribute pet meals till they arrive “into compliance with the Federal Meals, Drug, and Beauty Act (FD&C Act)“. That is excellent news. However…
…what about all the opposite pet meals firms that use elements that violate the Federal Meals Drug and Beauty Act? FDA permitting pet meals to supply elements from “diseased animals or animals that died in any other case than by slaughter” is a direct violation of the Federal Meals Drug and Beauty Act. How can FDA permit regulation to be violated by some pet meals producers whereas imposing the VERY SAME LAWS on others?
Definition of hypocrisy: “a pretense of getting a virtuous character, ethical or spiritual beliefs or rules, and many others., that one does not likely possess; a pretense of getting some fascinating or publicly accredited perspective.”
My letter to Dr. Steven Solomon despatched 3/28/22…
FDA’s Anne Norris despatched me discover of the consent decree motion FDA took in opposition to Bravo Packing. I wish to thank FDA for taking motion in opposition to this pet meals producer.
Nevertheless, FDA’s motion with Bravo Packing brings up severe inconsistencies along with your company’s enforcement of regulation. Resembling, how can FDA demand Bravo Packing to come back “into compliance with the Federal Meals, Drug, and Beauty Act (FD&C Act)” whereas on the identical time permitting different pet meals producers to violate the exact same federal legal guidelines with no warning or disclosure to pet homeowners. I remind you of your response to our Citizen Petition: “we don’t consider that the usage of diseased animals or animals that died in any other case than by slaughter to make animal meals poses a security concern and we intend to proceed to train enforcement discretion the place applicable.” As you’re conscious, The Federal Meals, Drug, and Beauty Act prohibits the usage of diseased animals or animals which have died in any other case than by slaughter in any meals – together with pet meals. The FDA acknowledged “we don’t consider…” these unlawful elements pose a security concern, nonetheless the company has not supplied any scientific proof to validate their perception.
The FDA’s press launch relating to the consent decree motion in opposition to Bravo Packing acknowledged “this agency continued to function underneath insanitary circumstances“. We’re conscious of not less than one different agency that continued to function underneath insanitary circumstances that the FDA took no motion on – the Mars Petcare facility in Columbus, Ohio. For 2 years in a row, FDA inspection of the plant discovered insanitary circumstances that posed a big threat. The FDA inspection report from 2017 acknowledged: “Failure to take efficient measures to exclude pests out of your plant and shield in opposition to contamination of animal meals by pests (Dialogue Merchandise from 10/27/2016 EI).” The FDA inspection report of this Mars Petcare facility additionally acknowledged: “The failure to take enough measure to exclude and forestall pests from the manufacturing and associated areas of the agency poses a big public well being security concern whereas additionally being a regulatory violation.” Despite the fact that repeated inspections discovered violations at this pet meals plant, the FDA didn’t search a consent decree to pressure Mars Petcare to abide by the FD&C Act – the FDA didn’t even subject a Warning Letter to this producer.
With all due respect Dr. Solomon, isn’t this hypocritical? Pet meals customers have a really legitimate concern that FDA’s selective enforcement of regulation might be immediately linked to the biggest producers of pet meals and the biggest ingredient suppliers. What else can pet homeowners consider based mostly on FDA’s actions?
There is no such thing as a query, Bravo Packing ought to come into compliance with the FD&C Act. However so ought to each different pet meals producer.
Pet meals customers are requesting by way of this e-mail for the FDA to elucidate why the company continues to permit diseased animals and animals which have died aside from by slaughter in pet meals with no disclosure on the label to ensure that customers to make knowledgeable buying choices. We request FDA to publicly present the science they based mostly their perception this unlawful materials is protected in pet meals. We request a public dialogue on the problem, for customers to offer FDA their enter. As FDA often meets with trade, we request the identical dialogue alternative for pet homeowners. We additionally request an evidence to FDA rationale of when and why regulation is enforced in some situations or not enforced in different situations.
We await your response to our questions, and await additional directions on scheduling for a public assembly with pet homeowners.
Representing pet meals customers,
Ought to pet homeowners want to e-mail FDA – be happy to make use of any a part of my letter to Dr. Solomon. In case you agree, please ask them to carry a public assembly the place pet homeowners can present FDA enter. Additionally please ask them to elucidate why unlawful elements are allowed in pet meals with no disclosure to customers. Emails might be despatched to AskCVM@fda.hhs.gov.
If Dr. Solomon responds to my questions, will probably be shared on this web site.
In no unsure phrases, the FDA took correct motion in opposition to Bravo Packing. The place they fail miserably is uniform enforcement of regulation throughout all pet meals manufacturers.
Wishing you and your pet one of the best –
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