Supplemental Cooperation

Since last month's column, a big step forward was taken by some manufacturers in the supplement industry. This step forestalled any "en masse" immediate regulatory action; however, it does not mean state feed regulators can't or won't enforce laws currently on the books regarding supplements. The National Animal Supplement Council (NASC) called a meeting in Chicago on April 3-4, when 25 representatives of supplement companies met to craft a response to the regulatory threat. The result of this gathering of decision-makers was a proposal for a Compliance Plus program to "address the problem of companies marketing unapproved feed ingredients as animal supplements." While the NASC has mainly been concerned with dog and cat interests in the past, it now includes equine representation on its board.

The Compliance Plus plan has many facets, and is a "work in progress," according to NASC president William Bookout. The primary aspects are to:

  1. Develop an adverse event reporting system for animal feed supplements;
  2. Require NASC members to adopt manufacturing/quality controls;
  3. Dictate a mandatory self-policing label claim enforcement standard voluntarily implemented by NASC members;
  4. Create a realistic mechanism for funding research to meet the requirements of the ingredient definition process, with funding commitments from industry to begin this process immediately;
  5. Apply these guidelines only to supplements for animals not intended for human consumption.

NASC has identified its first ingredient for the "ingredient definition process" under the guidelines established by the Association of Animal Feed Control Officials (AAFCO). That ingredient is glucosamine, which is found in many companion animal and horse supplements.

The NASC noted in a letter to AAFCO president John Breitsman, "AAFCO's much-publicized enforcement event has unleashed a great deal of energy by many industry participants, and much has been accomplished in a short period of time."

Breitsman said he considers this proposal "great news" and "a great first step." He said it means the supplement manufacturing industry is being serious about compliance with regulations. However, he added, there are any number of ingredients on the market that still need to be addressed on the regulatory level.

The NASC's Compliance Plus program must be reviewed and approved by the Food and Drug Administration (FDA) before AAFCO can make any recommendations to its members.

"As long as everybody is committed to it, it can work," Breitsman said. "They (NASC) have established a good base to work from."

There is a problem, even if the proposed plan from NASC is approved by the Food and Drug Administration and AAFCO and accepted by state feed regulators--if one or more companies foot the bill to "prove" the ingredient to the satisfaction of state and federal officials, there are other manufacturers who will want a "free ride" out of the deal.

It's like if you and I as neighbors teamed up to pay to have a water line run to our farms. We go through all the paperwork at city hall to get it approved, and deal with the contractors and workers and bad weather. Then the guy who lives across the road--who never raised a hand or contributed a penny--wants access to that water line without paying.

Unfortunately, unlike prescription drugs, most supplements have ingredients that can't be protected by patents. Therefore, the "free riders" might just sit back and wait until everyone else has anted up, then claim all the benefits without spending any money. That's where the consumers come in.

We as horse owners--and pet owners--owe some allegiance to those companies responsible enough to ensure that their products contain what they say on the label, aren't harmful to our horses, and put their money where their mouth is to fund the research to prove safety and efficacy of the ingredient(s) in the regulatory process.

I hope some means is created by state and federal regulators to give these "free riders" one last ride out of town--and off the shelves. Put up, or get out; we don't want you in the horse industry.

About the Author

Kimberly S. Brown

Kimberly S. Brown was the Publisher/Editor of The Horse: Your Guide To Equine Health Care from June 2008 to March 2010, and she served in various positions at Blood-Horse Publications since 1980.

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