Policy changes for pet food, microchips

The AVMA is advocating for veterinarian involvement in the distribution of pet foods that make health claims.

The AVMA Executive Board approved that position in November 2013 as well as voted to adopt or modify policies on a variety of subjects, including pet microchips, pet health insurance, and aquaculture regulation. AVMA policies are available here.

Policy changes

Board members voted to amend AVMA policy to recommend that the Food and Drug Administration restrict access to cat and dog foods that make health claims but have not gone through the drug approval or efficacy assurance process. The change added the word “therapeutic” to the title of the AVMA policy “Therapeutic Pet Food Health Claims” and added the following sentence to the policy: “In the interest of pet safety, AVMA recommends the FDA require the product to be made available to the public only through licensed veterinarians within the confines of a veterinarian-client-patient relationship.”

In September 2012, the FDA said in a draft policy guide that the agency can regulate, as drugs, dog and cat foods used to diagnose, cure, mitigate, treat, or prevent disease. Even though many such foods are not approved as drugs, the FDA has exercised enforcement discretion on products that provide nutrition, that carry restricted label claims, and that are sold only through veterinarians in a veterinarian-client-patient relationship.

In deciding whether to act against manufacturers of such foods, the FDA will consider those factors as well as such factors as whether the products are available to the public, marketed as alternatives to approved drugs, labeled with a claim regarding a specific disease, or labeled in a false or misleading manner.

The AVMA had responded to the draft policy with a recommendation that the FDA require that pet foods with implied or explicit health or drug claims but no drug approval include statements on their labels that the claims have not been evaluated by the FDA. The comments also indicate the AVMA supports enforcement discretion on marketing of certain pet food additives, such as glucosamine, which is commonly used in managing osteoarthritis, that have not been associated with substantial safety concerns.

The FDA draft policy guide and comments are available here under docket number FDA-2012-D-0755.

The board members also edited the AVMA microchip use policy, which now provides more detail on where transponders should be placed and expresses support for the American Animal Hospital Association microchip database. The policy’s new name is “Microchips: The Objectives and Key Elements Needed for Effective Electronic Identification of Companion Dogs, Cats, Other Small Mammals, Birds, Fish, Reptiles, Amphibians, and Equids.”

The policy no longer expresses opposition to use of microchip registration databases as a source for marketing or referrals for products and services, a change recommended by the AVMA Council on Veterinary Service. The council indicated in a statement to board members that such marketing is a business decision, and animal shelters often receive free microchips in exchange for allowing the provider to market to animal owners.

The AVMA also made the following policy approval and changes:

• Approved the policy “Uniform Jurisdiction for Aquatic Veterinary and Animal Health Programs,” through which AVMA advocates that a single agency, rather than a mix of agriculture and wildlife agencies in state and federal governments, should have jurisdiction over the health of animals in aquaculture.
• Modified the policy “Pet Health Insurance” to state that a veterinarian should help in claims adjudication.
• Revised the policy “Veal Calf Management” to recognize industry progress toward moving calves into group housing at a younger age and to note the importance of attention to gastrointestinal health.
• Edited the policy “Service Animals” to reflect the inclusion of miniature horses in the Americans with Disabilities Act as well as to list more of the tasks performed by service animals.

More changes considered

The Executive Board members considered but decided against rescinding the policy “Controlled Substances Used in Euthanasia,” which says controlled substances that are regulated by the Drug Enforcement Administration and used for euthanasia should be used only under the supervision of a veterinarian.

The AVMA Council on Biologic and Therapeutic Agents, which recommended rescinding the policy, said in its recommendation that some states allow use of such substances without a veterinarian’s supervision, particularly in animal shelters, and noted that the AVMA Guidelines for the Euthanasia of Animals provide guidance on controlled substance use and veterinarians’ roles in euthanasia.

In debate over the policy, Dr. Clark K. Fobian, 2013-2014 AVMA president, said that, even though states are letting nonveterinarians administer such controlled substances, he has no problem with keeping the policy that veterinarians should have authority over controlled substance use.

The Executive Board also voted against implementing a policy that would have said that valid scientific study shows lead from ammunition and fishing tackle can be toxic to animals.

In recommending the policy, the AVMA Committee on Environmental Issues cited studies that indicated such concentrated forms of lead have harmed U.S. wildlife, particularly water birds, raptors, and scavengers. The committee also described public health risks connected with eating game killed with lead ammunition.

The committee further cited legislation recently passed in California as a testament to the seriousness of the issue. In October 2013, state authorities passed a bill that will require use of nonlead ammunition for hunting in the state by July 2019.

The California bill stated that 50 years of research showed lead in the environment threatens public health and wildlife.

The U.S. Environmental Protection Agency also indicates several species of water birds—including ducks, wading birds, and shoreline feeders—are particularly vulnerable to lead poisoning through accidental ingestion of lead fishing sinkers.

Dr. John A. Howe, AVMA board member representing District VII, comprising Iowa, Minnesota, Missouri, Nebraska, North Dakota, and South Dakota, said he did not think the issue was veterinarians’ fight, and he said after the meeting that the issue is handled in other avenues, including through regulatory bodies. Dr. John H. de Jong of District I, who represents New England and New York, said he would prefer that advocacy on the issue be addressed through the AVMA’s “Toxicoses” policy. That policy states that the AVMA “supports education, legislation, regulations, research, and other actions that prevent toxicoses” in animals and humans.

Pending proposals

In January, the board will consider a proposal to rename the policy “Internet Pharmacies” to “Client Requests for Prescriptions” and edit the policy to state that veterinarians must, rather than should, honor client requests to prescribe rather than dispense a drug. The proposal was based on an opinion from the AVMA Clinical Practitioners Advisory Committee that honoring such a request is an ethical duty.

In April, the board will consider a proposal by Dr. de Jong to give stipends to Executive Board members. He said board members were committing increasing amounts of time and money toward service, and yearly stipends of at least $7,500 each would show appreciation and encourage participation by younger members.