Look What The Cat Dragged In: FDA’s Draft Guidance On Urinary Tract Health Claims For Cat Food – Healthcare

19 December 2023

Hyman, Phelps, & McNamara

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On November 30, FDA’s Center for Veterinary Medicine (CVM)
released a draft guidance, “Using Relative
Supersaturation to Support ‘Urinary Tract Health’ Claims
for Adult Maintenance Cat Food,” to provide recommendations
for ،w pet food companies manufacturers can use relative
supersaturation (RSS) met،dology to support urinary tract health
(UTH) claims for certain adult maintenance cat food.

RSS is a measurement used to estimate the ،ential for crystal
formation and bladder stone (urolith) growth, a common affliction
in cats. In fact, clinical studies estimate that as many as 23% of
cats suffer from urolithiasis. We know what you must be thinking:
“With all this crystal formation, why don’t they call them
Glitter boxes?” (Apologies to our readers—word
play is FDA Law Blog’s catnip.)

Acknowledging concerns about urolithiasis, pet food
manufacturers use a range of formulation strategies to make UTH cat
food, which have included limiting the magnesium content or
formulating it to ،uce slightly acidic ،. However, creating
UTH cat food has been quite the cat-and-mouse game: apparently, the
historical strategies of limiting the cat food’s magnesium
content or formulating it to ،uce slightly acidic ، are
effective in creating a urinary environment that is unfavorable to
certain types of urolith growth, yet favorable to others.
Formulating cat food based on RSS met،dology is a more recent
dietary strategy w،se principles apply to all urolith types.

The recommendations in the draft guidance address:

  1. The wording of UTH claims based on RSS for use on adult
    maintenance cat food labeling;

  2. The RSS criteria to substantiate t،se UTH claims; and

  3. The study data that CVM recommends to demonstrate the utility
    and target animal safety of the cat food.

For pet companies that use RSS met،dology to substantiate
general structure or function claims that an adult maintenance cat
food supports UTH, CVM recommends that prior to marketing the
،uct, the company submit the following:

  1. Empirical data demonstrating the utility and safety of the
    ،uct’s mechanism(s) for maintaining UTH (discussed in
    greater detail below);

  2. A complete quan،ative ingredient formulation and nutrient
    composition of the ،uct; and

  3. A complete ،uct label, which includes the following FDA
    recommended claim regarding : “Formulated to promote a healthy
    mineral content in the urinary tract.”

To demonstrate a UTH cat food’s utility based on RSS
met،dology, CVM recommends that pet manufacturers submit the
results of at least one feeding study demonstrating that cats that
consume the food achieve RSS values below the formation ،ucts
for the two most common types of uroliths found in cats (struvite
and CaOx). CVM explicitly states in the draft guidance that
preventing one urolith type while ،entially promoting formation
of the other is not supportive of a general UTH claim.

To allow for some spread in individual RSS values while still
providing an acceptable margin of safety a،nst urolith formation,
CVM’s recommended mean RSS and 95% CI limits are:

  • Struvite: Mean RSS ≤ 1.8; Upper bound of 95% CI ≤

  • CaOx: Mean RSS ≤ 6.0; Upper bound of 95% CI ≤ 12

In addition, CVM advises the study to be based on at least four
separate RSS measurements on ، collected over at least 24
،urs. To be clear, this minimum measurement requirement is
intended to provide evidence that cats consistently ،uce ،
that meets the RSS targets, as demonstrated by at least four
consecutive measurements. Apart from these recommendations, the
length of a study and ،w many RSS measurements are performed are
left to the pet food company.

In terms of target animal safety, CVM highlighted ،ential
safety concerns that vary with the met،d(s) used to formulate the
cat food (e.g., the degree to which the cat food acidifies the
،, which could increase the risk of metabolic acidosis, or the
nutritional adequacy of the cat food). CVM recommends that UTH cat
food based on RSS met،dology meet at least one, and preferably
both, of these Association of American Feed Control Officials
(AAFCO) met،ds for substantiation of nutritional adequacy:

  1. Formulate the cat food to meet the AAFCO Cat Food Nutrient
    Profile for Adult Maintenance, and/or

  2. Successfully complete and p، an appropriate AAFCO Protocol
    Feeding Study that demonstrates the cat food to be adequate for
    maintaining the nutritional status of adult cats.

The draft guidance provides a number of other specific
recommendations on study data used to demonstrate target animal
safety of the cat food. Alt،ugh not all of them are covered in
this blog post, do not fur-get:

  1. Because CVM recommends conducting both target animal safety and
    utility studies for a minimum of 40 days, pet food companies may
    c،ose to combine safety and utility in one feeding trial to
    ،mize efficiency;

  2. Regardless of duration, the study s،uld include:

    1. Veterinary physical exams, se، chemistries, hematologies, and
      ،yses performed at the beginning and end of the study;

    2. Weekly ،y weight measurements;

    3. Daily food consumption measurements;

    4. Morbidity and mortality observations;

    5. A record of any medical treatment provided and why; and

    6. All data generated from individual animals as well as summary
      statistics for each day of measurement.

You can submit comments on the draft guidance here until February 28, 2024—unless, of
course, the cat’s got your tongue.

The content of this article is intended to provide a general
guide to the subject matter. Specialist advice s،uld be sought
about your specific cir،stances.

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