Three U.S. universities – that accept multi-million dollar donations from pet food – write and enforce pet food law.

Law in forty-seven U.S. States require the government authority State Department of Agriculture to enforce pet food regulations. These same forty-seven States send government representatives to participate in the Association of American Feed Control Officials (AAFCO) process which writes pet food/animal feed laws and defines all pet food/animal feed ingredients. Forty-seven U.S. States recognize a government authority should be charged with the responsibility of writing and enforcing law.

The three remaining U.S. States – Kentucky, Indiana, and Texas – have provided the significant responsibility of pet food enforcement and law development to universities; University of Kentucky, Purdue University, and Texas A&M University.

Kentucky

Kentucky law states pet food and animal feed regulations “shall be administered by the director of the Kentucky Agricultural Experiment Station of the State of Kentucky”. The ‘Kentucky Agricultural Experiment Station’ – the authority that enforces pet food law in Kentucky – is part of the University of Kentucky. Quoting further Kentucky law “The College of Agriculture of the University of Kentucky shall constitute the Agricultural Experiment Station.”

In other words, a university that accepts donations from the pet food industry is charged with enforcing pet food and animal feed law in Kentucky. In Kentucky, pet food law enforcement is not performed by a government agency (such as the Kentucky Department of Agriculture), in Kentucky pet food law is enforced by University of Kentucky employees.

On the University of Kentucky website, the College of Agriculture “Departments” webpage evidences the University is indeed charged with regulatory authority:

The “Regulatory Services Department” within the University of Kentucky College of Agriculture Mission Statement: “As a part of the Kentucky Agricultural Experiment Station in the UK College of Agriculture, Regulatory Services is committed to service and consumer protection of Kentucky citizens, businesses, and industries.”

Pet food law in Kentucky is not enforced by a government entity…

such as the state’s Department of Agriculture…

Pet food law in Kentucky is enforced by a university.

Of concern, the University of Kentucky College of Agriculture Division of Regulatory Services has a “Advisory Board” that includes a significant number of industry representatives…

Eleven of the thirteen member Kentucky Regulatory Services advisory board are from industry. Griffin Industries – a rendering company part of the largest rendering firm in the US – and Alltech – an animal feed and pet food nutrition company – each have two members on the Kentucky Regulatory advisory board. (More on Alltech below.)

But it gets worse…

Not only do University of Kentucky College of Agriculture employees enforce law…THEY ALSO WRITE LAW.

University of Kentucky College of Agriculture employees – a public university that accepts donations from industry – are active members of the Association of American Feed Control Officials (AAFCO). AAFCO writes pet food and animal feed laws and ingredient definitions.

Kristen Green – a University of Kentucky College of Agriculture employee, is the Chair of AAFCO Pet Food Committee …

and an AAFCO Board of Directors member …

Ms. Green is also a member of the AAFCO Education and Training Committee, and the AAFCO Ingredient Definitions Committee.

Other University of Kentucky College of Agriculture employees also participate in the law writing process at AAFCO…

Jennifer Combs is a member of the AAFCO Current Issues and Outreach Committee.

Jim True is a member of the AAFCO Education and Training Committee.

Alan Harrison is a member of the AAFCO Feed Labeling Committee.

Sharon Webb is a member of the AAFCO Laboratory Methods and Services Committee, AAFCO Proficiency Testing Program Committee.



Frank Sikora is a member of the AAFCO Proficiency Testing Program Committee.

Is there a conflict of interest?

Looking back to the University of Kentucky website for potential conflicts of interest, on the “Industry Sponsor Agreement” page the university proudly states “Industry-funded research and technology transfer at the University of Kentucky have accelerated at an unprecedented pace over the past few years.” However the sponsor information stops there. The University of Kentucky “Sponsored Products Search Portal” is password protected. The public is not provided free access to learn exactly who donates to the university and how much is donated.

On the University of Kentucky College of Agriculture Center for Student Success page we find a promotional video for Purina Pet Food. This page makes it apparent the University of Kentucky has a working relationship with Purina.

(To watch the above video, click here)

Just one example of a pet food manufacturer funding pet food research at University of Kentucky is found on the AVMA website; “In vivo measurement of flatulence and nutrient digestibility in dogs fed poultry by-product meal, conventional soybean meal, and low-oligosaccharide low-phytate soybean meal.” Two University of Kentucky scientists partnered with Hill’s Pet Nutrition to publish this research.



Looking at the AAFCO website for potential conflicts of interest, the Biography page for Kristen Green (University of Kentucky Regulatory Services employee, Chair of the AAFCO Pet Food Committee, and AAFCO Board of Director member)…

She has worked with the University of Kentucky as a Registration Specialist for the Division of Regulatory Services since 2012. She received her B.A. and M.A. from the University of Kentucky. Prior to her position with the Division of Regulatory Services, she worked for 5 years managing international animal feed registrations for Alltech, Inc.

Alltech, Inc. is a pet food and feed ingredient company.

Looking closely…

2012 Ms. Green leaves her employment at Alltech (a pet food and animal feed ingredient company) and is employed by the University of Kentucky Division of Regulatory Services.

August 2012 Ms. Green becomes a member of the AAFCO Pet Food Committee, her first AAFCO meeting as a regulatory authority (all regulatory authorities can become members of AAFCO committees).

Ms. Green becomes a member of the AAFCO Pet Food Committee, her first AAFCO meeting as a regulatory authority (all regulatory authorities can become members of AAFCO committees). January 2013 Five months later, at her second meeting as a regulatory authority Ms. Green becomes “Vice Chair” of the Pet Food Committee.

Five months later, at her second meeting as a regulatory authority Ms. Green becomes “Vice Chair” of the Pet Food Committee. 2016 Ms. Green becomes a member of the AAFCO Board of Directors, staged to become AAFCO President in coming years.

Ms. Green becomes a member of the AAFCO Board of Directors, staged to become AAFCO President in coming years. 2018 Ms. Green’s previous employer, Alltech, Inc., holds two advisory positions to the University of Kentucky Division of Regulatory Services – the division of University of Kentucky College of Agriculture that she currently works for.

Questions to pet owners: Is it a conflict of interest for a university – that clearly has relationships with industry – to write and enforce law? Does industry donations to and research projects with the University of Kentucky, influence the Kentucky Division of Regulatory Services? Do corporate advisors to the Kentucky Regulatory Services influence regulation and enforcement?

Unfortunately, there is more to consider. The University of Kentucky is not the only public university that writes and enforces law…

Indiana

Pet food and animal feed regulations in Indiana are not enforced by the state’s government agency – the Department of Agriculture. Instead, in Indiana pet food and animal feed regulations are enforced by Indiana’s Office of Indiana State Chemist – a division of Purdue University. The Office of Indiana State Chemist homepage states: “The Indiana State Chemist is charged with administering several agricultural laws involving animal feeds, fertilizers, pesticides and seeds. The goals of these laws are to ensure truth-in-labeling, food safety, user safety and the protection of our environment.”

On the Purdue University website, the Agricultural Research and Graduate Education webpage evidences Purdue is charged with regulatory authority:

And just like with the University of Kentucky, Purdue University employees enforce law and write law.

Purdue University Office of Agricultural Research employees – a public university that accepts donations from the pet food industry – are active members of the Association of American Feed Control Officials (AAFCO) who are charged with writing laws governing pet food and animal feed.

Robert Gieger – a Purdue University Office of Agricultural Research employee, is President-elect of AAFCO and a member of the AAFCO Board of Directors…

Mr. Geiger is a member of the AAFCO Education and Training Committee, he is the “Board Liasion” for the AAFCO Feed and Feed Ingredient Manufacturing Committee, and he is the “Board Liasion” for the AAFCO Model Bill and Regulations Committee“.

Other Purdue University Office of Agricultural Research employees also participate in the law writing process at AAFCO…

Mr. Brett Groves is a member of the AAFCO Ingredient Definitions Committee, and the AAFCO Inspection and Sampling Committee.

Mr. Robert Waltz is a former AAFCO President, a member of the AAFCO Finance Committee, and the AAFCO Strategic Affairs Committee.

Also, Halina Inerowicz is a member of the AAFCO Laboratory and Services Committee.

Is there a conflict of interest?

Looking at the Purdue University website for potential conflicts of interest, the Purdue University Vet Tech program homepage provides this information about the director Dr. Bianca Zenor…

Dr. Zenor came to Purdue University directly from “Hill’s Pet Nutrition”.

The Purdue College of Veterinary Medicine posted April 20, 2018:

“Members of the Purdue Veterinary Medicine Class of 2019 reached a major milestone Sunday afternoon (April 15) as they took part in the College’s White Coat Ceremony held in Stewart Center’s Fowler Hall. Sponsored by Elanco Animal Health and Hill’s Pet Nutrition.“

The Purdue College of Veterinary Medicine Funding Opportunities page provides this list of “External Funding Sources”.

The “Canine Health Foundation” listed on the Purdue University website as an “External Funding Source” is a foundation affiliated with the American Kennel Club. Provided on the Canine Health Foundation ” Our Partners“ webpage is this…

Purina Pet Food is a ‘Partner’ of Canine Health Foundation who is an ‘External Funding Source’ for Purdue University Veterinary research.

Unfortunately, there is still more to consider. The University of Kentucky and Purdue University are not alone, one more public university writes and enforces law…

Texas

Just as in Kentucky and Indiana, pet food and animal feed regulations in Texas are not enforced by the state’s Department of Agriculture. Pet food and animal feed regulations are enforced in Texas by the the “Office of the Texas State Chemist” a division of “Texas A&M University AgriLife Research Extension”. Texas A&M University does not appear to be as transparent about the regulatory division being part of the university as Kentucky and Purdue were. The only confirmation found to connect the regulatory agency to the university was the AgriLife Research logo found on both the regulatory agency webpage and the Texas AgriLife webpage…

Texas A&M University not only enforces pet food and animal feed law, the university also writes law.

Ricky Schroeder – a Texas A&M University employee – is a former AAFCO President.

Other Texas A&M University employees also participate in the law writing process at AAFCO…

Mr. Ben Jones is another former AAFCO President. Mr. Jones is a member of the AAFCO Enforcement Issues Committee, the AAFCO Feed and Feed Ingredient Manufacturing Committee, and the AAFCO Model Bills and Regulations Committee.

Mr. James Embry is a member of the AAFCO Ingredient Definitions Committee and the AAFCO Pet Food Committee.

Ms. Mary Sasser is a member of the AAFCO Inspection and Sampling Committee.

Is there a conflict of interest?

The Texas A&M University Veterinary Medicine website provides this advice for pet food consumers:

“Choosing the right kind of pet food is important for your pet’s health and quality of life. The Pet Nutrition Alliance has developed a website with resources for veterinarians and pet owners, including a nutritional calculator, frequently asked questions, and how to understand pet food labels. This website can be found here.”

This Texas A&M University Veterinary School webpage directs readers to Pet Nutrition Alliance where we find these “Educational Sponsors“…

On the Texas A&M University AgriLife Research (same division of Texas A&M regulatory authority is housed) “About Corporate Relations” page we find some potential conflict of interest language…

And in searching the Texas A&M University Office of the Texas State Chemist (regulatory authority for pet food and animal feed) website we find this division of the university also has an Advisory Board with a large number of industry representatives.

The Advisory Board meets “not less than once a year” with Texas A&M University regulatory authorities to – in part – “answer questions concerning the programs and to receive suggestions from the committee relating to improvements in the administration of the laws.”

Members of the current Texas A&M University Office of the Texas State Chemist Advisory Board include:

Petco Animal Supplies, Inc.

Darling Ingredients Inc. (rending company)

Texas Association of Dairymen

Texas Cattle Feeders Association

Concerning

State law in Kentucky, Indiana, and Texas provide these universities with the liberty to write and enforce pet food law. It is legal.

But is it ethical?

Forty-seven U.S. State Department of Agriculture government agencies charged with enforcement of pet food law are prohibited to accept financial gifts from the pet food industry. But in Kentucky, Indiana, and Texas – things are very different. State law provided these universities the authority to enforce pet food law, and to participate in AAFCO giving them the ability to write pet food law…but State law did not prohibit these universities from accepting donations from the industries they regulate.

Question: If Pet Food Brand A donated $5 million dollars to the Veterinary School at Purdue University, could authorities of the Indiana State Chemist Office – a division of Purdue University – remain unbiased in regulating Pet Food Brand A?

Maybe yes, maybe no. Research tells us no.

Though the quote below was in consideration of conflict of interest issues surrounding the human medical industry, it applies to the concern here as well. Published in the Journal of American Medical Association in 2006 is the publication “Health Industry Practices That Create Conflicts of Interest“…

Social science research demonstrates that the impulse to reciprocate for even small gifts is a powerful influence on people’s behavior. Individuals receiving gifts are often unable to remain objective; they reweigh information and choices in light of the gift. So too, those people who give or accept gifts with no explicit “strings attached” still carry an expectation of some kind of reciprocity. Indeed, researchers suggest that the expectation of reciprocity may be the primary motive for gift-giving. Researchers have specifically studied industry gifts to physicians. Receiving gifts is associated with positive physician attitudes toward pharmaceutical representatives. Physicians who request additions to hospital drug formularies are far more likely to have accepted free meals or travel funds from drug manufacturers. The rate of drug prescriptions by physicians increases substantially after they see sales representatives, attend company-supported symposia, or accept samples. The systematic review of the medical literature on gifting by Wazana found that an overwhelming majority of interactions had negative results on clinical care.

Regulatory enforcement aside, how much influence do University of Kentucky, Purdue University, and Texas A&M University have at AAFCO (the law writing private corporation)?

Below is a graph that displays – per the AAFCO website – the committee participation of University of Kentucky, Purdue University and Texas A&M University as compared to committee participation of an example government agency State Department of Agriculture (Florida – my home state). Each of these AAFCO Committees are responsible for writing “Model Bills” that become state law.

As you can see, employees of these three universities are heavily involved in the pet food/animal feed regulatory process. One or more of each of these universities participate in every AAFCO Committee that writes law.

The question remains…

Do pet food manufacturing donations to

University of Kentucky

Purdue University

and Texas A&M University

influence pet food law and enforcement of pet food law?

For Kentucky, Indiana, and Texas resident pet owners that believe their state universities should NOT be writing and enforcing pet food law, write your Governor and or state Legislators.

Example email Kentucky pet owners:

In 47 U.S. States, pet food regulations are enforced and state laws are written by government agencies. In Kentucky, pet food laws are written and enforced by the University of Kentucky College of Agriculture. University of Kentucky College of Agriculture Regulatory Services writes and enforces pet food laws. Donations from pet food manufacturers are common and extensive to University of Kentucky. It is a concern if Regulatory Services can remain unbiased due to the extent of pet food manufacturing donations to University of Kentucky.

Kentucky law must be changed to move the regulation of pet food/animal feed and the participation in AAFCO to Kentucky Department of Agriculture. Pet food and feed laws should not be written and enforced by a university that accepts financial donations from the very industry it regulates.

Example email Indiana pet owners:

In 47 U.S. States, pet food regulations are enforced and state laws are written by government agencies. In Indiana, pet food laws are written and enforced by Purdue University College of Agriculture. Purdue University College of Agriculture Office of the Indiana State Chemist writes and enforces pet food laws. Donations from pet food manufacturers are common and extensive to Purdue University. It is a concern if the Office of the Indiana State Chemist can remain unbiased due to the extent of pet food manufacturing donations to Purdue University.

Indiana law must be changed to move the regulation of pet food/animal feed and the participation in AAFCO to Indiana Department of Agriculture. Pet food and feed laws should not be written and enforced by a University that accepts financial donations from the very industry it regulates.

Example email Texas pet owners:

In 47 U.S. States, pet food regulations are enforced and state laws are written by government agencies. In Texas, pet food laws are written and enforced by Texas A&M University College of Agriculture. Texas A&M University College of Agriculture Office of the Texas State Chemist writes and enforces pet food laws. Donations from pet food manufacturers are common and extensive to Texas A&M University. It is a concern if the Office of the Texas State Chemist can remain unbiased due to the extent of pet food manufacturing donations to Texas A&M University.

Texas law must be changed to move the regulation of pet food/animal feed and the participation in AAFCO to Texas Department of Agriculture. Pet food and feed laws should not be written and enforced by a university that accepts financial donations from the very industry it regulates.

For pet owners that reside in every other state who believe state universities in Kentucky, Indiana, and Texas should NOT be writing and enforcing pet food law, write your State Department of Agriculture.

Example email:

In 47 U.S. States, pet food regulations are enforced and state laws are written by government agencies. In Kentucky, Indiana and Texas pet food laws are written and enforced by universities. Employees of University of Kentucky, Purdue University and Texas A&M University write and enforces pet food laws. Donations from pet food manufacturers are common and extensive to these universities. It is a concern if these university employees would be influenced by pet food manufacturing donations to their respective university, thus influencing the laws that govern pet food in all US States.

Law should only be written and enforced by a government authority. I understand that [your state] cannot influence law in Kentucky, Indiana, or Texas. But [your state] can insist the American Association of Feed Control Officials (AAFCO) only allow government employees the liberty to write law.

Repeating one small section of the publication “Health Industry Practices That Create Conflicts of Interest“…

“Social science research demonstrates that the impulse to reciprocate for even small gifts is a powerful influence on people’s behavior. Individuals receiving gifts are often unable to remain objective; they reweigh information and choices in light of the gift.”

Employees of University of Kentucky, Purdue University, and Texas A&M University might have the best of intentions…but due to the large financial gifts from the pet food industry provided to their respective employers, they should NOT be charged with enforcing and/or writing law.

Wishing you and your pet(s) the best,

Susan Thixton

Pet Food Safety Advocate

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