Here we go again. The FDA announced in late June the availability of a draft guidance entitled “The Judicious Use of Medically Important Antimicrobial Drugs in Food-Producing Animals.” Any draft guidance the FDA issues is intended to inform the public of their current thinking on a particular topic.
Already the title is questionable. “Medically important.” To me that means it is important for the health of the animal. This may be true based on the conditions these animals are raised in. But, read the announcement itself and you’ll see what they are talking about.
The background information given in the announcement seems to point toward a good decision coming regarding the routine use of antibiotics in livestock, citing concerns from the health community and the public. So far, so good. It goes on to say, “Based on a consideration of the available scientific information, FDA is making a number of recommendations regarding the appropriate or judicious use of medically important antimicrobial drugs in food-producing animals. These recommendations include phasing in such measures as follows: (1) Limiting medically important antimicrobial drugs to uses in food-producing animals that are considered necessary for assuring animal health and (2) limiting such drugs to uses in food-producing animals that include veterinary oversight or consultation. Developing strategies for reducing antimicrobial resistance is critically important for protecting both public and animal health. Collaboration involving both the public and animal health communities on the development and implementation of such strategies is needed to assure that the public health is protected while also assuring that the health needs of animals are addressed.”
Again, this sounds good. Many of us refuse to buy meat in the grocery because we know where it comes from and how it’s been grown; crowded, unsanitary conditions combatted by feeding excessive amounts of antibiotics to avoid illness and promote growth. Not only inhumane, but documented as a source of global antibiotic resistence.
So, I decided to search out and read the entire guidance document and references. Within the document, the FDA cites multiple studies that back up what many of us already believe - antibiotics in our feed animals are making their way into our systems and causing us to become resistent to the same antibiotics we need to help save us when we become ill. But Congress has failed to listen and the FDA has failed to act.
The U.S. Perspective
In the “1969 Report of the Joint Committee on the Use of Antibiotics in Animal Husbandry and Veterinary Medicine,” also known as the “Swann Report,” the committee found that giving antimicrobials to food-producing animals is hazardous human health. It also clearly stated that resistent strains of bacteria are a direct result of the use of antibiotics for promoting growth in livestock.
A second document, the 1970 FDA report “The Use of Antibiotics in Animal Feed,” echoed the results of the 1969 report. That report required companies that used antimicrobials in their animal feeds to submit documentation proving their particular antimicrobial did not contribute to antibiotic resistence.
Again, these reports sound wonderful and the actions the FDA took after the 1970 report was promising. Here’s where we run into a problem. In 1977, 1980 and again in 1984 the FDA tried to force producers to stop using penicillin and tetracyclines in animal feed based on the premise they were causing resistance in humans. All three times Congress ordered studies, which they deemed inconclusive, and forced the FDA to withdraw their efforts.
In 1988 the FDA tried again, this time specifically focused on Salmonella. And, once again, the comittee was unable to find “substantial evidence” that the use of antibiotics in animal feeds posed a human health hazard. And the FDA’s efforts were shot down yet again.
The Global Perspective
Then, along came the World Health Organization (WHO). In 1997, the WHO convened a meeting of experts to examine the issue. The conclusion, lo and behold, was not only that all uses of antimicrobials lead to resistent strains of bacteria but that low-level, long term exposure may have a greater detrimental impact than short-term full dose use. The committee urged that the use of antimicrobial drugs in animal feeds be discontinued completely if those same antimicrobials were used against human illnesses or could cause cross-resistence to antibiotics used in humans.
In 1999, the EU commissioned another report that clearly stated the use of antimicrobials should be reduced immediately. They also recommeded that infections should be prevented and resistent organisms contained.
In 2000, the WHO agreed and restated that the use of these drugs in food-producing animals should be used only through veterinary prescription. An even larger joint world expert workshop in 2003 concluded all the same things, in addition to stating there was “clear evidence” of adverse human consequences. The WHO did it again in 2004 and added that “good agricultural practices can reduce the necessity for anitmicrobials.”
Back Home Again
Apparantly unconvinced, our own government commissioned another study two years after the first WHO report to again study the ”benefits and risks” associated with drug use in food-producing animals. The result? A rather whimpy recommendation to establish a national database to track scientific studies on the matter and the creation of a panel of experts to have oversight of further development and use of antibiotics in food animals.
In 2003, the Institute of Medicine issued a report recommending to more finely target the use of antimicrobials and recommended the FDA “ban the use of animicrobials for growth promotion in animals” if those classes were also used in humans. Yet, nothing was done.
In 2004, yet another committee was formed at the request of Congress to, once again, provide further study. Finally, there was a definitive conclusion. The report was extensive but, in a nutshell, the conclusions were not only had antibiotic-resistent bacteria been transferred from animals to humans and posed a significant health risk. It also points out studies that showed evidence of associations between antibiotic uses in animals and development of resistence in humans. Finally, a conclusive report rather than a recommendation for further studies, right? Wait one minute. The recommendation of this report was for the FDA to expedite the “risk assessments” of antibiotics used in animals. As a result, the Department of Health and Human Services pointed out 11 other studies that showed adverse human health consequences related to antibiotic use in agriculture.
At last. The FDA would finally ban the use of antibiotics in our food animals unless there was a proven medical necessity, right? Surely, after all this evidence and the numerous reports from world agencies, Congress would allow the FDA to do their job. Not so fast. In 2005 a Code of Practice was issued, but it did not ban or even require the reduction of antibiotic use in livestock. Instead, it gave guidance and recommendations regarding the the responsible use of antimicrobials. But that’s all it did: recommend. Sigh.
So What Now?
So now, finally, after 40 years of reviewing study after study, report after report, the FDA “believes the overall weight of evidence supports the conclusion that using medically important antimicrobial drugs for production purposes is not in the interest of protecting and promoting public health.” Really? Does this mean they’re actually going to do something about it now?
Oh, no. That would be logical. This draft guidance is suggesting that, since overuse of anitibiotics is rampant in both livestock and humans, it’s important these drugs are used judiciously in both humans and animals. Furthermore, they are saying it’s imperative that “strategies for controlling antimicrobial resistence include consideration of how antimicrobial drugs are being used.”
So, just one more study is what this sounds like. More “risk based” assessments. And, once again, asking for only voluntary efforts from the industry. Why are we still discussing this? It’s been proven time and time again that not only does the use of subtherapeutic antibiotics in livestock increase resistence to those drugs in humans, but it is also not helping keep our food supply safe. Just look at the recent egg recall. How many people have gotten sick from Salmonella because of the conditions those chickens are living in? They eat, sleep, defecate and lay their eggs all in the confines of one area with thousands and thousands of other chickens. And, no matter how many antibiotics you feed them, there are still health risks to both the animals and the people that eat their eggs.
As far as I am concerned there is only one solution. Eliminate the nasty conditions these animals are raised in on factory farms and feedlots and you won’t have a need for the antibiotics anymore. Our food supply and our health would be better off for it.
If you are just as concerned about this as I am, you can give your comments regarding this guidance before they make it permanent. Go to the comment submission page for this docket before Aug. 30. Or, if you want to use a pre-written letter, go to the FarmAid website to use their form. Make your voice heard, over and over if necessary, until we take back control of our national food supply. Until that happens, I will continue to eat only the foods which we grow for ourselves or which I can verify the source of. I encourage you to do the same.
Until next time. ~Karin
