The Federal Trade Commission, in submitting a Request For Public Comment Concerning Guides For The Dog And Cat Food Industry, is asking the American Public to assess guidelines for monitoring the pet food industry that have been in place since 1969. Since the basic thrust of the original guidelines was to control misrepresentation in the industry, it is hard to imagine that the public would disagree with the original intent of the guidelines. It would also be prudent to assess whether a review of such sound guidelines would be either necessary or worth the cost of carrying out the assessment. On the other hand, it has been thirty years since the original guidelines were implemented, giving the public and the industry time to see if the guidelines have done their job in a cost-effective manner and whether or not they need to be retooled for an industry that has gone through considerable technological and economic changes. Therefore, it would seem reasonable to conduct a survey that would target key areas, such as any overlapping of the guidelines with federal, state, and local laws, the integrity of industry self-regulation in a new era of economic and technological advances, and whether or not the guidelines have imposed undue cost to both the industry and the public.
Few would argue with the points of the original guidelines, whether it is monitoring misleading claims in advertising, or monitoring the quality of the products themselves. Despite economic and technological advances that have taken place in the industry since 1969, the guidelines still hold up as sound. There are also federal, state, and local laws that attempt to insure the same integrity in the pet food industry. The pet food industry also closely monitors itself. Given all these factors, it would seem best to question the necessity of such a survey, or, at least, to limit its scope and cost. What could be unseen motives for initiating such a reassessment? The American pet food industry would certainly want to keep pressure on the government to regulate foreign competition, insisting that competitors meet the same stringent standards set for American manufacturers.
The FTC would also stand to gain from the number of its workers that would be paid for conducting the reassessment and the power and prestige that such guidelines tend to give the FTC It might be useful to assess how much cost the original guidelines have imposed on the industry and the consumer in increased prices for pet foods and if the guidelines have added anything to federal, state, and local laws that already monitor the industry. Querying the public on these issues seems more reasonable than rehashing guidelines that already do a thorough job of addressing reasonable concerns about misrepresentation. Fiscal concerns and social concerns are valid at the same time and should be kept n balance. In a decade that has seen a continual debate about the limits and scope of government versus the role of government in protecting its citizenry, it is probably a good idea to let the public weigh in on the effectiveness of the original 1969 guidelines in a way that limits the cost of the survey, while assessing the effectiveness of the original guidelines, over and above already existing federal, state, and local laws.