FDA/AAFCO Spring Fling
Editorial by Mary Ann Simonds
Equine Behavioral Ecologist

As my three horses (1 TB and 2 ex-wild horses) browsed the plants along my fence, I wondered if they knew the controversy people were having over what kind of plants horses should be allowed to eat. I further thought to myself about whether my horses would stop eating my roses, raspberries and herb garden if I posted a sign that said " THESE PLANTS HAVE NOT BEEN APPROVED BY FDA or AAFCO FOR HORSES TO EAT". I laughed to myself at the absurdity of the truth.

Don't be surprised if you drop in at your local feed store to find your favorite herbs or other nutritional supplement for your horse gone! AAFCO (Association of Animal Feed Control Officials), an organization with no regulatory authority, but lots of influence, has developed an "enforcement strategy" to remove "unapproved animal feed ingredients" from the market. Why is this happening all of a sudden, you may ask? Well, the fact is that the Federal Food, Drug and Cosmetic Act was not updated for animals in 1994 with the new "Dietary Supplement Health and Education Act" (DSHEA). The updated DSHEA Act only applies to human nutritional supplements. Animal feeds are still governed by the original act, which appears to have more approvals and updates relating to adding drugs and animal by-products to animal feeds than it does to the approval of natural plant materials for animals. Perhaps because no one ever thought that a natural plant might need approval by FDA to be fed to an animal, the natural supplement industry has gone their merry way producing products that are in fact "illegal" under current law.

Dr. Bill Burkholder of the FDA stated that FDA would not oppose AAFCO's enforcement strategy recommendations, and would assist in enforcement on an interstate commerce basis. Each state will determine what they consider approved products. However, since AAFCO is formed of state regulatory feed officials, it is likely that most states will adopt whatever AAFCO recommends. AAFCO has gained a respected position and appears to act as the main scientific advisors to FDA on what animals should eat. FDA indicated that they have very little information on any of the "bad novel botanicals" that are on the market today for animals. A "bad novel botanical" by human definitions is simply an unapproved supplement. This same bad novel botanical such as echinacea, white willow bark, red raspberry leaves, or ginseng could be considered a very good botanical by the animal. However, according the law, which has not been challenged or changed for animals in almost 50 years, they are illegal.

In an interview with Dr. Bill Burkholder, he indicated that FDA is interested in good scientific data on the use of currently unapproved ingredients. Most of the natural supplement companies have never requested FDA approval and therefore the way the law is written, they may not be given to animals without approval. I am sure many people think it is ridiculous to seek approval for something their horse eats daily in the pasture. You are probably thinking that FDA should be more concerned about the allowable level of "unidentified products" in animal feeds or the fact that you can feed "recycled animal waste" in animal feed along with "animal by products" to herbivores. However, under the current law these are approved ingredients and the "bad novel botanicals" are not.

I asked FDA what products they had had the most complaints about, and Dr. Burkholder stated that to his knowledge FDA had had no consumer complaints on any of the novel botanicals. However you can check FDA dockets to see the number of consumer complaints that are listed by people concerning "approved" animal feeds. I warn you, however, that once you enter the large and well-organized FDA web site, you may become immersed in the amount of information available and spend many hours reading about unusual and in some cases unbelievable things that are approved for animals to eat. The bottom line is that FDA is doing its job as an enforcement agency. If people want the law to change, then they must follow the public process to change the law.

Because there are two levels of jurisdiction involved in the removal of unapproved feed ingredients, both state and federal governments need to be contacted. You may want to provide comments concerning any unapproved products you have used as well as request that the DSHEA be amended to include animals or a similar law be passed for animals. You may also want to take a look at the current approved ingredients for animals (many of which were "grandfathered" in when the Act was passed) and perhaps indicate your concerns over feeding some of these substances. Many are not in any way a natural diet for a horse, and some in fact have shown to be unsafe. This information needs to be related to FDA and to Congress. Here are several simple things you can do right now:

1. Contact by phone, e-mail and/or in writing the following people and let them know your concerns:
- State Senators and Representatives (found in the Government Section of your phone book or )
- State "feed official"
- Governor's office
- Federal Senators and Representatives
2. Access FDA at their web site www.fda.gov and from the home page go to Docket # 95N-0308 for electronic comments. Send in your comments concerning the safety of any products not currently approved. FDA needs to hear about the good these products are doing, as well as any concerns you have. You can also reach them by phone at 1 888-463-6332. Linda Grassie was very helpful in answering questions.
3. Contact AAFCO at their web site www.aafco.org. They have many documents of interest. Go to their "Contact us" section and let them know your concerns about what feed ingredients you would like to see off the list and which ones you want on the list.

Horse people often assume that someone else will take care of everything for them, but this is a time you need to become active and voice your concerns. Congress, FDA, and your local State need to hear from you now! Your horse will "thank you". Give your horse back the food it needs to be healthy and prevent any further "junk food" from being approved.

If you do not have access to the internet, you can contact Natural Horse Offices at 800-660-8923 for more information.


Supplement Ban Letter Writing
By Lisa Ross-Williams

After having Mike Uckele on my radio show to discuss the Ban on Equine Supplements, I thought it was very important to make it easier for horse owners to get the information and voice their opinion.

This Ban is real and very soon the very common nutraceuticals and herbal supplements we use for our horses and other companion animals will no longer be available in stores or mail order. This includes joint formulas like MSM, chondroitin, glucosamine, herbal blends, etc. Keep in mind the sale of these same products for use in humans is protected under the DSHEA of 1994.

If you are not familiar with what's going on, please go to these websites to learn. The internet webcast of the show with Mike Uckele is available at www.naturalhorse.com.

Here are the sites: www.nasc.cc, www.horse-journal.com; click on sample articles and then on "Contraband in the Barn".

It's critical that we all get involved and let the appropriate people and groups know how we feel. Please contact me if you need more information on guidelines for writing, whom to write to, a site for a basic form letter, another in-depth form letter, and a page that includes the Animal Lovers Freedom Act, which if passed will extend the provisions of DSHEA to our horses and companion animals.

1. Don't rant and rave, no references to corporate interests. Stick to the facts and your concerns.
2. Who you are (owner, trainer, vet, etc)
3. How you use these products and why they are important to you. (ie., I have three older horses who rely on a joint nutraceutical to enjoy a good quality of life.)
4. Your experience with the safety of the products, as well as your concerns about the allowable level of "unidentified products" in animal feeds or the fact that you can feed "recycled animal waste" in animal feed along with "animal by-products" to herbivores.
5. A brief statement of the current threat. (AAFCO is spearheading a movement to have state regulatory officials remove these beneficial products from the market because they fall into a grey area between feed and drugs.)
6. Your support for the solution. (I strongly support legislative action to extend the provisions of the 1994 DSHEA-Dietary Supplement Health and Education Act to include our horses and other companion animals.)
7. Add a CC section at the bottom listing all the other people this letter is going to. *VERY IMPORTANT*.
8. Send along a copy of the proposed Animal Lovers Freedom Act with your letter or email.

There are form letters you may use as a basic format if you choose at www.nasc.cc under form letter page.

1. Your Federal Legislators. Find by state and area code at www.aafco.org
2. Food and Drug Administration
Sharon Benz (301) 827-6656
5600 Fishers Lane
Rockville, MD 20857
3. American Horse Council
(202) 296-4031 or www.horse-council.org
4. AAFCO President
John Breitsman
PA Dept of Agriculture
2301 N Cameron St.
Harrisburg, PA 17110-9408
5. State AAFCO Representatives. Find by state at www.aafco.org
6. State Governor
7. These are the people working for us who would appreciate a copy:
National Animal Supplement Council at www.nasc.cc
Mike Uckele from Uckele Health & Nutrition at UCKEMIKE@aol.com

Please get involved and spread the word to every animal lover you know. This is about our right to choose what we can and can't feed to our animals.