I didn’t know where to put this. It is from Paulick, but not just about race horses. I thought it might be interesting to all of you. Pets and horses. It is a little dense, but it might be of some help to some of you. I know a lot of you give suppliments.
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Wow. I wonder if that joint supplement is worth it? I wish I could say that supplements that have been around a long time, such as Farrier’s Formula, are reliable, but who knows? So depressing.
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At least the Farrier’s Formula supplement (biotin) was championed after the results of an actual study.
Great article, I thought.
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it was actually over my head, but I don’t have a horse anymore. I know I see a lot of talk on suppliments and I thought you guys wouuld appreciate it.
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My vet agrees with this. I’ve decreased my supplement bill by a lot. They get a vitamin/mineral combo formulated for my area, and the old pony gets an Osphos shot a couple of times a year and that’s it.
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The article goes into great detail about the history of supplement regulation the USA but does not go into detail about the actual supplements. She does not distinguish between vitamin mineral supplements and herbal supplements. Despite being in the feed industry she doesn’t discuss how feed companies do or don’t fortify their bagged feeds with VM. She’s right that there’s a ton of dubious expensive supplements out there for both horses and humans.
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The DSHEA came into being because what was about to happen without it was just plain nuts. (As it stands, the current regulations aren’t particularly well-done, either.)
All herbs were to be regarded as unapproved drugs.
Your grandmother could have been arrested for chamomile tea.
(And it was illegal to sell a book on using herbs in the same store as one that sold herbs.)
Government being what it is, the sledgehammer approach was adopted by both sides, with traditional herbalists and anti-regulation folks on one side and FDA and the pharmaceutical industry on the other.
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Are you referring to one you use? It depends on which one it is, and whether it’s doing your horse any noticeable good
Did I miss something in the article? Or are you talking about a specific study on a specific product?
they’re both unregulated supplements and “supplements” (ie drugs as Ghazzu mentioned)
that’s not the point of the article though. Feed companies ARE held to standards and regulations - AAFCO on a country level, though not truly a formal national regulation, but states do tend to require adhering to AAFCO rules, which she does talk about. Feeds are regularly tested, by state inspectors, to make sure the GA is actually what’s in the bag. And, supplements produced by feed companies tend to be under more scrutiny as well, in terms of what’s in it (nothing is scrutinized for effectiveness, there’s no regulation like that)
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Something I learned recently (and take this with a grain of salt, I heard it from a reputable source but I didn’t fact check further) is that the FDA’s GRAS designation is self-applied for and self-reported. Yes, you need scientific evidence for an ingredient to be recognized as GRAS, but the companies/manufacturers are responsible for producing that evidence themselves and including it in their application. It’s not quite the rigorous, independent process I assumed it to be.
So bottom line: all a company has to do is say, “we found this ingredient to be safe,” and the FDA application panel reviews their application. If they check all the boxes, the additive makes it on the GRAS list.
Maybe someone will have additional insight that restores my faith in the system, but it has been explained as shockingly arbitrary to me.
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Here’s what the FDA has for GRAS:
" * Under sections 201(s) and 409 of the Act, and FDA’s implementing regulations in 21 CFR 170.3 and 21 CFR 170.30, the use of a food substance may be GRAS either through scientific procedures or, for a substance used in food before 1958, through experience based on common use in food Under 21 CFR 170.30(b), general recognition of safety through scientific procedures requires the same quantity and quality of scientific evidence as is required to obtain approval of the substance as a food additive. General recognition of safety through scientific procedures is based upon the application of generally available and accepted scientific data, information, or methods, which ordinarily are published, as well as the application of scientific principles, and may be corroborated by the application of unpublished scientific data, information, or methods.
- Under 21 CFR 170.30© and 170.3(f), general recognition of safety through experience based on common use in foods requires a substantial history of consumption for food use by a significant number of consumers."
https://www.fda.gov/food/food-ingredients-packaging/generally-recognized-safe-gras
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Sorry, just realized that’s for people.
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Yes, but both for both people and animals, I do not see anything disputing that the scientific evidence is “self-reported.” As a matter of fact, if you look in the veterinary procedure, you are self-reporting your scientific data. And it implies the FDA may not even ask to see it:
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Going back to the original article: I still don’t entirely understand why Janicki walked away from a career in the horse feed industry.
I understand her issues with the regulation of supplements or lack thereof. I understand she does not feel like there is enough oversight in the supplement market.
But why can’t she continue working in the feed industry? She says the feed industry is now “irrelevant” and “overtaken” by the supplement industry. But I still don’t entirely understand how. She says while not perfect, that AAFCO guidelines for feed and pet food are upheld at some level. Supplements aren’t regulated, and yes, that’s irresponsible. But how do they have this stranglehold on the feed industry, apart from their insane popularity?
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I also felt like the reason they couldn’t stay in the industry was still coming when the article simply…ended.
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I’ve been downright stingy regarding every single so-called supplement for my own aging, lame self and my relatively younger 17 y.o. TB ever since I heard reporter Jane Marie’s podcast The Dream, season 2 eviscerating the human wellness industry.
As a sometimes too enthusiastic debunker, I think this podcast may have touched my soul.
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Interesting blog piece by an Australian blogger, causing a few waves!
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Very interesting. I like her style.
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I am going to jump in here with both feet…My company has to deal with AAFCO, and we are members of the NASC. Plus we have to conform to the individual states’ Departments of Agriculture. And the FDA.
When you read the AAFCO manual…you might pass out as to what is accepted in animal feed. Frankly it’s appalling (particularly for dogs and chickens).
First of all AAFCO is feed. If a supplement is labeled as a “food” it must meet AAFCO specifications. If a supplement is not labeled as a food then it falls under structure/function labeling set out by NASC. Two totally different labels. AAFCO label must include: protein, fat, fiber, cal/phos/mag etc: what we know as the guaranteed analysis. Structure/function labels do not require this. Structure/function labels require Active and Inactive ingredient listing which supplements labeled “food” do not.
We had a surprise visit from the FDA several years ago…she stayed for three days, going through all our ingredient documentation, adverse event reports, lab testing, procedure manual. Thanks to the NASC requiring and providing training for our production managers get certified in GMP, and ingredient and product testing. The FDA did not write us up for any violations other than we needed to re-seal the floor in production, keep a detailed record of repairs to equipment, have a separate manual for emergency procedures, and label each of our raw material containers with a photo.
We have been through 2 organic certifications, and a yearly inspection by the state’s Department of Agriculture. For the past year we have jumped through hoops for the California Department of Agriculture who has determined that FDA GRAS is not necessarily acceptable in California. Had to provide reams of scientific literature on ingredients we use not listed in AAFCO despite Structure/Function labeling, yet these ingredients were listed in the FDA GRAS database. Then we had to write California a big check to register our products.
The NASC also does audits on members labels, marketing materials, website lingo. One of the reasons so many state Department of Agricultures rely and trust the NASC.
Are there bad-actors out there in the supplement industry?..you bet. I can tell by reading a product label if that company is in compliance.
But compliance is only part of the story…consumers have no idea where raw materials come from (country of origin) or the traceability. As a company with organic certification we have to provide farm to table documentation.
How to gauge quality ingredients by reading a label?..pretty difficult. And in some categories kind of irrelevant. Vitamin C for example: 95% is produced in China as ascorbic acid. It is not from oranges 
In the feed ingredients category, China produces 94% of vitamin B6, 73% of feed grade vitamin A, 62% of feed grade vitamin E, 94% of feed grade B2. Over 78% of all US vitamin imports come from China.
Where relevancy becomes more important is food, and plants. All sources are not alike.
There are some very good supplement companies on the market: ethical, maintaining rigorous production procedures, testing, transparency, and efficacy.
Don’t throw the whole supplement industry under the bus.
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AAFCO is feed AND supplements
NASC is totally voluntary, and you pay to get into the “club”. AFAIK, all NASC does is guarantee that what the label/literature/website/etc says is in the supplement is actually in it, not claiming cure or prevention, that sort of thing. But, that IS the only supplement “governing” body I’m aware of. It’s just 100% voluntary, and still tells you nothing about efficacy.
LOL, not surprised. But not “determined”, they have decided, for reasons that are irrelevant for this purpose
Amen to that, it’s incredibly difficult no matter what label you’re reading. Some of the issue is consumer unwillingness to take on some self-education which, to some degree, is pretty simple. Bigger issues are what’s allowed in the labeling process which makes it difficult to determine thins like “hidden” sources of soy especially in human products.
No, I agree, the problem is it’s a enormous industry and MOST shouldn’t be in the game 
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