*** Important Update: Please Read Carefully and Pass Along ***
*** IMPORTANT & URGENT—PLEASE READ ***

Dear NASC Members, Retailers, Veterinarians and Pet Owners:

Thank you to everyone who passed along the notice from Andrea Thompson, Section Manager–Feed & Plant Services with the Idaho Department of Agriculture, announcing the department's intention to begin taking regulatory action against hemp products in animal feed and remedies, effective November 1, 2022.

Here is an excerpt from the notice to provide context:

From: Idaho State Department of Agriculture (ISDA)
To: Animal Feed Retailers, Manufacturers, and Distributors
Date: July 20, 2022
Re: Hemp Products in Animal Feed & Remedies

" ... Effective November 1, 2022, ISDA will be inspecting for hemp and hemp-derived animal feeds and remedies. These products are not legal in Idaho, and if found on or after November 1, 2022, will be subject to a stop sale and further action from the department."

From the communication it is unclear, and certainly confusing by the language, whether the department intends to include products that are dosage form animal health products, which are not intended to provide nutritional benefits and have not been regulated as animal food/feed products.

NASC will take a very strong stand for these products, which are positioned exactly the same as many other products for non-nutritional benefits and not regulated as animal food/feed.

We have reached out to Ms. Thompson and we have scheduled a meeting with her and several senior-level individuals within ISDA early next week.

We will provide an update following our meeting with further clarification and direction for all stakeholders, as the unintended consequences of this action will be far-reaching. We are significantly concerned about the potential economic impact, along with negative consequences that may very likely result in harm to the animals we all want to protect.

We also have very robust and supportive data we can utilize to help substantiate that products from responsible suppliers who are following cGMPs and are properly sourcing raw materials with testing verification at multiple levels do not pose high risk to animals for negative health consequences.

These data include:

• A 90-day safety study (this is the timeframe FDA/CVM indicated they wanted to see for CBD, CBD/A, CBD/G, and a control group). The study has shown there would not be safety concerns at the levels used in the study,
• Data from the NASC Adverse Event Reporting System (NAERS®), the most advanced system of post-market surveillance in the world for products similar to human dietary supplements, marketed for dogs, cats and horses. NAERS data for 1,131 products containing hemp/hemp derivatives shows there have been nearly 800 million administrations, with only two adverse events per million administrations, and only 0.01 serious adverse events per million. 

Based on the data, there is simply no justification for this drastic action.

We are hopeful our discussions with ISDA will be productive, and we will keep everyone informed as to where we need your help and action you should take.

Again, we will be very involved in responsibly addressing this issue for the benefit of all stakeholders, not least important the animals themselves. We all know they depend on these products that help maximize their quality of life and help increase the time they have to spend with their families.

Sincerely, 

—Bill Bookout, NASC President