A minimum of 23,000 people die in the United States due to antibiotic resistance, according to the Center for Disease Control. Yet, antibiotic resistance—the rise of so-called “super bugs”—is on the rise because of overuse and abuse of antibiotics in our food system. Eighty percent of antibiotics sold in the U.S. go toward food animal production—mostly for the corporate meat industry that uses it for growth promotion and to keep a large number of animals alive in confined spaces. While doctors, nurse practitioners and pharmacists are required to write prescriptions for antibiotics to treat sick people, anyone can buy them over the counter in animal feed stores. This lack of regulation is creating a public health crisis that is entirely possible to avert.
After years of delay, FDA is finally attempting to address this major gap by requiring animal drug makers to have veterinary supervision of antibiotics in feed. Veterinary supervision is critical to slow the overuse of these drugs and the related spread of antibiotic resistance. However, the FDA (in order avoid resistance from drug companies) is watering down what “veterinary supervison” means, and therefore, undermining the ability of government agencies to effectively track how drugs in animal feed are used.
The existing rule (called the Veterinary Feed Directive, or VFD), which is stronger, only applies to two drugs. But the FDA is weakening this rule in order to apply it to many more antibiotic drugs. While regulating a broad range of antibiotics under the VFD is absolutely critical for public health, the FDA should create a strong and comprehensive rule that requires the drug industry to change its practices.
We are asking you to help make our food system healthy and safe. Take action right now by submitting comments to the FDA before March 12—the deadline for public comments.
Send a personal message and demand that FDA address the following concerns:
Require antibiotic drugs used in feed to be under veterinary supervision and NOT DEPEND ON VOLUNTARY ACTION for the change.
Ask FDA to maintain the existing federal requirement that VFD drugs only be used when the veterinarian has seen the animals to be treated (described as a Veterinarian-Patient-Client-Relationship in the current rule). Doctors or veterinarians must not be able to prescribe drugs to patients outside their care.
The revised rule MUST require veterinarians and feed companies to send copies of orders for VFD feeds to the FDA. Keeping track of how antibiotic drugs are used on farm is important for FDA to control the spread of resistance
The rule should keep the current requirement that veterinarians keep records for 2 years instead of shortening it to one year.
Finally, refills on the feed directives should be time-constrained, keeping veterinarians in the loop on future use of antibiotics.
I am concerned about the spread of antibiotic resistance and its potential devastating effects on the health of my family. Given that the bulk of antibiotics used in the United States are given to animals in feed without any veterinarian supervision, I am encouraged to learn that FDA is trying to at least require that a veterinarian be involved. This is the right thing to do, but I believe that the FDA is going about it in the wrong way. I ask you to strengthen the current FDA rule on VFDs in feed in the following way:
Require that all medically important antibiotics in feeds only be used under veterinary supervision and not wait for voluntary action by drug companies to make the change.
Keep the current federal requirement that a valid relationship (VCPR) is maintained between the veterinarian and his / her animal clients. In other words, veterinarians writing a feed directive should have recently laid eyes upon the animals to be treated, or at least visited the farm where they are kept.
Require veterinarians and feed companies to submit VFD orders to the FDA, so that the Agency can track how these drugs are being used.
Maintain the current two year record keeping requirement.
Don’t allow illegitimate re-ordering of feed antibiotics: Ensure that the VFD expires no later than the actual end of life of the animals it was intended to benefit -- or six months after it is written, or the label directions—whichever is shortest.
Without these improvements, the VFD will not fully ensure that antibiotics which are important to humans—such as penicillins, tetracyclines, erythromycins and steptogramins—remain effective for treating future generations of both sick people and sick animals.
Because of the critical importance to public health, I further urge you to take two important steps that go beyond the purview of the VFD:
On FDA’s books, there are many approvals for livestock antibiotics delivered in feed or water that do not address a specific illness and have no limits on the duration of their use. FDA must discontinue them. So long as these approvals remain, there is little to prevent medically important antibiotics from continuing to be used routinely for non-sick animals.
The public, including public health researchers, must have data granular enough to track whether the Agency’s new rules designed to end routine antibiotic use in food animals are in fact working. Given the nearly 30 million pounds of antibiotics used in food animals today and the growing problem of antibiotic resistance, stewardship of these drugs is vital.