Who is responsible for the efficacy and safety of pet foods?

Dear Sir,

Dr. Buffington, in his Special Report: Dry foods and the risk of disease in cats, (Can Vet J 2008;49:561–563), presents a biased view of the impact of carbohydrates on the health of cats. A review of scientific articles published over the past 20 years indicates that the cat as an obligate carnivore has no requirement for carbohydrates (1). A growing body of research supports the theory that carbohydrates can have a deleterious effect on the long-term health of cats. The purpose of this letter is not to debate the nutritive value of carbohydrates, but to address a more important issue: Who is responsible for proving the efficacy and safety of pet foods? Dr. Buffington’s article implies that the burden rests with the end users of these products. This is a fallacious argument.

Neither pet food purchasers nor veterinarians are responsible for proving that pet foods are unsafe or contribute to health problems over the lifetime of the pet. In human health, the burden to prove safety and efficacy is on the drug and food product manufacturers. The United States Food and Drug Administration (FDA) and Health Canada are responsible for enforcement. In the United States, the Federal Food Drug and Cosmetic Act (FFDCA) requires that all food and drug product claims be scientifically substantiated prior to marketing, otherwise they are false or misleading.

Dr. Buffington insists that no problem exists because, in his view, no definitive proof is evident that commercial cat foods are unsafe when fed as long-term diets. This is completely irrelevant, even if it were true. The conclusions from short-term research with limited numbers of animals can hardly be extrapolated to the life of a pet, which may span decades. For the industry to apply the results of these trials as proof of their diets being safe over the lifetime of a pet is inappropriate and is illegal under the FFDCA.

In the 2007 CVMA annual report, the CVMA and Hill’s Pet Nutrition partnership is described, involving a nationwide “Pet Health and Nutrition Tool Kit.” The purpose is to “help veterinarians facilitate an open and honest dialogue with clients about nutrition and the crucial role it plays in the overall health and well being of their pets.” This partnership raises several disturbing questions. How can a professional association form a liaison with one of the very companies that would be involved if the CVMA institutes the certification and monitoring of veterinary therapeutic diets? How can a small animal clinician present an honest and unbiased opinion to a client with the Hills logo on all the “tool kit’s” information?

The pet food industry’s use of carbohydrates in dry pet foods is purely a technological and an economic decision without the scientific basis for that formulation as a lifetime diet. In fact, the pet food industry has not met any scientifically valid burden of proof of safety or that they deserve to carry lifetime feeding claims. This is the relevant argument.