Written by: Louise Calderwood | October 11, 2022
Remember the opening scene from the iconic television series, Star Trek? You know the one, where the Starship Enterprise glides by as the narrator exclaims that her intrepid crew will “boldly go where no man has gone before!” What the average viewer might not know is that the fictional craft USS Enterprise’s inaugural voyage started in 2245 and by the time her third pilot, the illustrious James T. Kirk, manned her helm in 2264, she had been engaged in interplanetary exploration for 19 years. Almost as long as the American Feed Industry Association has been urging the Food and Drug Administration to modernize its approach to the use of marketing claims for innovative animal food additives with proven efficacy and safety!
With the FDA’s listening session scheduled for Oct. 18, we will be able to share our position on the regulation of animal foods and perhaps the United States will soon be able to join the rest of the world and use animal food additives as exciting as the new planets visited by the crew of USS Enterprise during each weekly episode.
While farmers, ranchers and pet owners around the world are able to use animal food additives with attributes as remarkable as a Star Trek teleporter safely beaming Kirk and his crew across the empty stretches of space, animal owners in the United States are stuck in the horse and buggy era, plodding along at a steady trot, with limited ability to use safe and effective additives that improve animal production and well-being, address pre-harvest food safety and reduce the environmental impact of livestock production. Manufacturers of animal food additives are developing new products that act in the digestive tract of animals or on the food animals are digesting. Use of the new products is essential for the United States to keep pace with global developments in animal husbandry.
Without the ability to adopt new and proven approaches to animal management, our animal owners are being left behind as their counterparts streak forward in the development of new approaches to target animal safety, food safety and environmental stewardship.
Since 1998, the FDA’s Center for Veterinary Medicine (CVM) has used an outdated definition of what is considered a “food” and what is a “drug” when reviewing new animal food products, which can legally be considered both. Guide 1240.3605 in the CVM Program Policy and Procedures Manual is less than a full five pages long, but it is as effective as Spock’s Vulcan nerve pinch in limiting permissible marketing claims for animal food ingredient labels.
Guides 1240.3605 states “…while the guidance is intended to assist in consistent or uniform regulation, it is not intended to be inflexible but is to be regarded as guidance to be followed in most instances for uniformity.”
The CVM might not intend to be inflexible, but it sure isn’t keeping up with the scientific advances being adopted by animal owners across the globe. It is time to broaden the regulatory runway for U.S. animal food marketing claims to accommodate the expanded understanding of the physiology of the gastrointestinal tract.
The CVM is long overdue in revisiting its narrow orbit for regulatory approval of animal food ingredients.
On Oct. 18 we will provide comments to CVM with a message as accurately directed as a Star Trek photon torpedo. We believe the truthful use of environmental benefit claims, production claims and claims about effects on the animal well-being and pre-harvest food safety will provide valuable information to animal food customers, incentivize innovation and align U.S. industry with international markets. It is time to allow U.S. scientific advances in animal nutrition to streak into the heavens with the Star Trek theme music playing alongside.