One of the things that has been consuming my time recently is
work on an issue that pertains to my on this list as well.
Nutraceuticals like chondrotin, MSM, etc. and all herbals are in very real
danger of being pulled off the market. I am going to cross-post edited
versions of what I put on another list in reply to this subject coming
up and will put a copy of the most recent Horse Journal articles in the
files for more background.
> > I have been following
this situation for at least 4 years now, > writing about it in Horse
Journal for that long, trying to warn > people this was coming. I'm
glad it's now being taken seriously > because make no mistake about it,
it is serious. > > I'll be as brief as I can in identifying the
major players and giving > some background. Have to say right up
front here though that Dr. > Newell is absolutely 1000% correct that vets
are not the bad guys and > support from vets, which is there, is
going to be important. Here > goes... > > The
regulation of feeds and supplements for use in any animal is > under the
auspices of the FDA - Food and Drug Administration. The > FDA does
not have the power to make laws, it only enforces them. The >
power to make laws lies entirely in Congress. FDA may issue >
"position statements", basically interpretations of existing laws, > and
can take action to enforce existing laws. The FDA has limited >
time and resources though and is far more concerned with drugs, human
> issues and medicated feeds for animals that might enter the human
> food chain than it is with what you give your pets. While we
don't eat horse meat here, many > countries do. 1999 was the
last year for which I could find figures > but at that time 62,813
horses were slaughtered in the U.S. and meat > sold for human
consumption overseas. An additional 24,000 or so > horses
originating in the US were shipped to slaughter houses in > Canada.
It's a small number compared to the estimated 6.9 million > horses in
this country but it's enough to throw a monkey wrench into > our
attempts. > > The sale of unapproved feed or supplement ingredients
is illegal. > Under the currently existing system, an ingredient is
either a food > or a drug (some exceptions like preservatives,
flavorings, etc.). To > be classified as a food, it must be
shown that the ingredient is > important in the diet and serves a
nutritional function. This > includes protein, fiber, fat, carbs
and the major and trace minerals > recognized to have a biological
function. That's it. A drug on the > other hand is
defined as "articles intended for use in the diagnosis, > cure,
mitigation, treatment, or prevention of disease..and articles > (other
than food) intended to affect the structure or any function of > the
body of man or other animals." Joint nutraceuticals, MSM, >
herbals, etc. under this definition are drugs. Don't waste any >
energy getting worked up about this definition, whether it is >
reasonable, whether it is fair, etc, etc. Fact is that this is the
> definition and it's what we have to deal with. > > I can't
go into all the intricacies here so the following explanation > of
what constitutes a food is more for education purposes. To be >
approved as a food ingredient, the substance in question must be > shown
to be safe, must have a documented role in the diet and the > required
levels in the diet of the animal in question must be known. > There must
also be a reliable method to assay for the ingredient so > that checks
can be made on label claims. Vitamin and mineral > supplements fall
under the category of supplements to the diet/food. > Joint
nutraceuticals, MSM, herbals etc. do not. > > The sale of things
like chondroitin, glucosamine, MSM, herbals for > animals is illegal and
always has been illegal. They have not gone > through drug approval
processes and are not currently classified as > foods either.
Again, don't waste any energy getting riled up about > whether this is
sane or reasonable. The point is that it is illegal, > always
has been illegal, and any regulatory body that decides to do > something
about it is well within the law in doing so. Manufacturers >
knew, or should have known, it was illegal but since nothing was ever
> done about it they didn't go to the trouble and expense of having
> these products go through established approval channels. >
> The proliferation in use and sale of things like joint
nutraceuticals > is a relatively recent occurence, dating back 10 or
at the most 15 > years. The FDA knew about it but essentially
practiced benign > neglect. There were rumblings and even an
occasional regulatory > action when an individual or company stepped over
the line in making > medical claims to the point it caught someone's
attention (e.g. Frank > Lampley). By and large though, the FDA
had bigger fish to fry. > Regulatory action can also occur at the
state level. The state > Departments of Agriculture are charged
with upholding state and > federal regulations that pertain to animal
feeds. An unapproved > ingredient in a bag of feed or a supplement
bucket is, by definition, > an adulterant. Strong term, and one
you are likely to hear often in > the coming months, but that's what
it is. Like the FDA though, state > feed officials have more to
worry about than chondroitin and > glucosamine. They have been
granting licenses to manufacturers of > these products for years without
batting an eye. Again, benign > neglect, bigger fish to
fry. > Second half of
Part 1 to follow.