Committee view and recommendations
With over 24 million pets in Australia today, Australian households have
one of the highest rates of pet ownership in the world. As pets become an
increasing part of our lives, consumer demands for quality pet food and
guarantees regarding its safety have risen. However, recent adverse events have
demonstrated the extent to which the current self-regulatory framework no
longer meets community expectations.
Publication and public oversight of the Australian Standard
As a first and fundamental step, the committee strongly advocates for
free and uninhibited access to the Australian Standard (AS5812:2017). Currently
the standard can be purchased at a cost of approximately $128.19. The committee
contends that this financial barrier has not only hampered pet owners' trust in
the regulatory system, but has also made it difficult for pet owners to
scrutinise the standards to which pet food is held.
The committee holds the view that transparency, brought about by the
publication of the standard, will encourage greater accountability on the part
of the pet food industry and improve its performance. Furthermore, publication
and knowledge of the standard will enable consumers, otherwise unable to access
and share it for reasons of expense and copyright, to hold the industry to
account. It will also enable consumers to scrutinise the standard's labelling
requirements, which should be transparent and informative for the buyer. It is
fundamentally important, therefore, that the Australian Standard be made
accessible to the public at no cost.
The committee recommends that the Australian Standard for the
Manufacturing and Marketing of Pet Food (AS5812:2017) be made publically
available on the Department of Agriculture and Water Resources' website for download
During the inquiry, the prospect of establishing an independent
regulatory body, on the basis of a recommendation from the committee, was
widely supported. However, the manufacture of pet food falls within the
responsibility of states and territories. Given the federal nature of the
Australian Constitution, any such suggestion of establishing an independent
regulatory body would require the enactment of legislation by state and
The Minister for Agriculture and Water Resources, the Hon David
Littleproud has already secured the support of his state and territory counterparts
for an independent review into the safety and regulation of pet food. The
committee recognises this initiative as a key pathway to achieve a stronger,
nationally consistent regulatory regime for pet food in Australia.
Noting the considerable effort made by many submitters, the committee
encourages the working group given responsibility for reviewing the regulation
of pet food, to take into account the evidence provided to the inquiry, with
particular focus on the evidence regarding the need for a stronger regulatory
While the committee does not hold a view on the precise framework that
should be pursued, it is clear that self-regulation of the pet food industry is
no longer acceptable by community standards. Therefore, the committee strongly
encourages the states and territories to engage with the Minister for
Agriculture and Water Resources and the respective working group to strengthen
the regulatory regime for pet food in Australia.
The committee recommends that, as part of its review into the safety and
regulation of pet food, the working group focus on mechanisms to mandate pet
food standards and labelling requirements in Australia. In particular, it
should give serious consideration to amending the Food Standards Australia
New Zealand Act 1991 to expand the responsibilities of Food Standards
Australia New Zealand (FSANZ) to include pet food standards and labelling
The committee further recommends that the working group draft a national
pet food manufacturing and safety policy framework for the consideration and
endorsement of an appropriate forum such as the Australia and New Zealand
Ministerial Forum on Food Regulation.
To inform its deliberations, the committee recommends that the working
group take into account the evidence provided to this inquiry.
Improving the Australian Standard
The committee acknowledges the substantive work undertaken by the pet
food industry over many years to develop and review the Australian Standard.
However, that there are a number of improvements that must be made.
First of all, the conduct of feeding trials in relation to target animals must
be undertaken alongside extensive testing of pet food prior to sale. Feeding
trials allow the detection of issues that may develop over a longer period of
time and enable the exclusion of potential toxicities. Furthermore, if pet food
manufacturers are to make health claims about their products, such claims
should be scientifically tested and assessed in the target population.
With regard to labelling requirements, alongside the full disclosure of
ingredients, including preservatives and additives, the committee also
recommends that the Australian Standard require a declaration of heat
treatments, such as irradiation, on all labels. The committee acknowledges that
changes have been made since the recall of imported cat food in 2008 to ensure
that pet owners are instructed not to feed irradiated foods to cats. However,
this information should be displayed on both dog and cat food more explicitly,
so as to avoid future incidents relating to thiamine deficiency.
Given the anticipated independent review of pet food, the committee
recommends that the proposed working group focus in particular on pet food
labelling, the declaration of heat treatments such as irradiation, as well as
the inclusion of feeding trials and scientific testing.
The committee recommends that the independent review working group
identify specific measures to improve the efficacy of the Australian Standard
for the Manufacturing and Marketing of Pet Food (AS5812:2017). These measures
should include specific requirements with regard to feeding trials and other
testing prior to pet food sale as well as mandatory labelling standards that detail
all ingredients including preservatives, additives, and which disclose heat,
irradiation or other treatments to the product.
Pet food product recall and reporting framework
Throughout the inquiry, the committee consistently heard that there is a
need for a mandatory pet food recall and reporting framework.
However, the committee recognises that there is already a system in
place for voluntary recalls under Australian Consumer Law. In addition, there
are offences and penalties applicable to suppliers and manufacturers, including
pet food processors, which act as an incentive for them to comply with the
general prohibitions and the consumer guarantees that are set out in Australian
The committee recognises that the use of the ACCC's Australian Product Safety
website will meet the needs of pet owners for a centralised information system
on pet food recalls and the reasons for them. As is the case with human
consumer products, the communication of safety information regarding pet food is
essential to prevent or minimise the impact of future adverse incidents.
Reflecting on evidence from witnesses, the committee is of the view that
pet food manufacturers should take a precautionary approach to pet food safety.
If there is even a slight risk that a pet food product may cause negative
health impacts, recall procedures should be immediately undertaken. Thereafter,
investigations can be conducted to identify the exact cause, and compensation
provided to consumers. However, the period during which the investigation is
taking place should not allow the opportunity for more animals to contract
In addition to utilising Australian Consumer Law recall arrangements,
which would enable the publication of recall details on the Australian Safety Product
website for pet owners to read and understand, the committee strongly
encourages consideration of mandating the Australian Standard under Australian
When considering whether to introduce a mandatory standard, the
Australian Government conducts research and consults with industry and
consumers to develop a regulation impact statement. As a first step, however,
the committee suggests that the ACCC review the proposal to make the Australian
Standard mandatory under Australian Consumer Law. The ACCC should produce a
published report, or make public its findings and any recommendations to inform
the independent review working group in its consideration of methods to mandate
and enforce the Australian Standard.
To this end, the committee recommends that the ACCC consider this
proposal, and the process by which the Australian Standard could provide the
basis of a mandatory standard.
The committee recommends that the Australian Competition and Consumer
Commission review the process by which the Australian Standard for the
Manufacturing and Marketing of Pet Food (AS5812:2017) could become a mandatory
standard under Australian Consumer Law and make public its review findings and any
Adverse event reporting
The committee acknowledges that the current system for reporting adverse
pet food events has not been effective in detecting adverse trends relating to
pet food. The evidence to the committee revealed that the Australian Pet Food
Adverse Event System of Tracking (PetFAST) played almost no role in the
detection of megaesophagus in dogs consuming Advance Dermocare dry dog food, as
the majority of cases were logged only after the recall was announced.
The committee heard that the PetFAST system was underutilised. Evidence
indicated that an estimated 40 per cent of all veterinarians in Australia are
not members of the AVA and are, therefore, probably not aware of PetFAST's
existence. In addition, not all AVA members are aware that they can use the
I am an ex-AVA president and I am an ex-AVA member, and I did
not know that the PetFAST system existed. We need communication, education and
reporting even if a self-regulation system is maintained.
Whilst the committee recognises that the PetFAST system was intended to
gather veterinary advice, rather than individual pet owner reports, the system
cannot be effective if it is not utilised across the veterinary community. In
addition, consideration should be given to updating the system to ensure that
it is user-friendly and utilises better monitoring tools to detect trends.
The committee recommends, therefore, that as a first step, the
Australian Veterinarian Association (AVA) review and update the reporting
requirements of the PetFAST system. To this end, the committee strongly encourages
the AVA to work with the ACCC to strengthen and streamline the PetFAST system
and to enable its operation in complementarity to a consumer complaints
mechanism for pet food.
The committee recommends that the Australian Veterinary Association, in
cooperation with the Australian Competition and Consumer Commission explore
measures to improve data capture in the PetFAST system.
Consumer complaints and reporting mechanism
The committee recognises that consumers should be given the opportunity to
share their concerns, and report to an appropriate authority when issues with
pet food arise.
The committee recognises that the US Food and Drug Administration's
Safety Reporting Portal is an example of industry best practice. The central
site allows consumers to report issues in relation to human food, animal food,
drugs, tobacco and therapeutic biologics. The committee suggests that a similar
reporting system in Australia would ensure that consumers can raise their
concerns about pet food quickly and easily.
As a comparable mechanism is already available for ordinary consumer
goods through the ACCC's Product Safety Australia website, the committee
recommends that the ACCC provide a system of consumer reporting with regard to
pet food on the same website.
It is envisaged that the proposed consumer complaints process will
complement the PetFAST tracking system.
The committee recommends that the Australian Competition and Consumer
Commission establish a system for consumer reporting on its Product Safety
Australia website, to enable members of the public to lodge complaints and
concerns associated with pet food.
Investigation and education
The committee is also cognisant
of the need for a transparent and resourced mechanism to investigate reports
made on PetFAST as well as consumer complaints of adverse pet food events.
Furthermore, the committee appreciates that consumers, veterinarians and the
wider industry should be informed of the proposed pet food product reporting,
investigation and recall systems.
To this end, the committee
encourages the Australian Government to work with the states and territories to
establish an adverse pet food investigation mechanism and to develop a
complementary education campaign to inform consumers and the industry about the
product reporting, investigation and recall regime.
The committee recommends that the Australian Government work with the states
and territories to establish a mechanism to investigate adverse pet food events
and develop a complementary education campaign to raise awareness of the
adverse pet food reporting, investigation and recall regime.
The committee holds the view that these recommendations provide for
cost-effective measures that can be agreed to and implemented within a short
period of time. The committee believes that these measures will provide for
greater transparency and oversight of pet food manufacturing in Australia.
Alongside publication of the Australian Standard, the committee has
focused on key practical and fundamental steps that would improve consumer
oversight of the pet food industry. With this objective in mind, the committee has
recommended a suite of measures to raise the standard of pet food, implement
stronger safeguards to respond to adverse pet food incidents, and provide
greater transparency and oversight of the pet food standard in Australia.
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