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FDA and raw foods


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Posted by Deerhounds on February 12, 2003 at 13:53:32:

From THE ANIMAL COUNCIL, P.O. BOX 168, MILLBRAE CA 94030
Appropriate forwarding is encouraged.

FOOD AND DRUG ADMINISTRATION DRAFT GUIDANCE FOR INDUSTRY ON MANUFACTURE AND LABELING OF RAW MEAT FOODS FOR COMPANION AND CAPTIVE NONCOMPANION CARNIVORES AND OMNIVORES was reported in the Federal Register, Vol. 67
(December 18, 200, Page 77500-77501) Docket No. 02D-0468, CVM 200251. With the increasing interest in and use of raw foods for dogs and cats, it's no wonder that the Center for Veterinary Medicine at the FDA http://www.fda.gov/cvm has taken note and begun to formulate policy to address potential safety concerns. The notice states, "However, the new
trend is toward use of raw meat foods by pet owners and others who may not be as aware of the potential harm. FDA does not believe that raw meat foods are consistent with the goal of protecting the public from significant health risks, particularly when such products are brought into the home and/or used to feed domestic pets."

It is important to understand that this is a "guidance" document and not regulations, i.e. actual rules to be enforced. A general principle of administrative law is that an agency's official policy documents ought to go through the notice and comment process, although this is often a gray area and varies among agencies, subjects and strategies. This notice states:

"This level 1 draft guidance is being issued consistent with FDA's good guidance practices regulation (21 CFR 10.115). The draft guidance, when finalized, will represent the agency's current thinking about the manufacture and labeling of raw meat foods for companion and captive noncompanion carnivores and omnivores. It does not create or confer any rights for or on any person and does not operate to bind FDA or the public.
An alternative approach may be used if such approach satisfies the requirements of the applicable statutes and regulations."

The actual draft Guidance is a pdf document at
www.fda.gov/cvm/guidance/dguide122.pdf

Additional information:

http://www.fda.gov/bbs/topics/ANSWERS/2002/ANS01183.html or contact Dr.William J. Burkholder, Center for Veterinary Medicine, FDA, (301) 827-0179, bburkhol@cvm.fda.gov.

Written or electronic comments must be submitted by March 3, so we suggest that those with an interest in raw foods for pets study the draft and submit any comments, including questions or general concerns. Electronic comments may be submitted on the Internet at http://www.fda.gov/dockets/ecomments; select docket number 02D-0468. For
mailed comments, individuals may submit one copy and others submit 2 copies, identified with the docket number found in brackets in the heading of this document to Dockets Management Branch (HFA-305), Food and Drug Administration, 5630 Fishers Lane, Room 1061, Rockville, MD 20852.




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