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Institute for Agriculture and Trade Policy, Food Animal Concerns Trust, Humane Society of the United States, Union of Concerned Scientists and Keep Antibiotics Working

Comments submitted to the FDA on the Ferm Solutions, Inc. Food Additive Petition (Animal Use) for Virginiamycin, Docket No. FDA–2010–F–0510. The Ferm Solutions petition asks that the Food and Drug Administration (FDA) approve the feeding of distiller grains, a by-product of ethanol production, to food producing animals even when the distiller grains contain the medically important antibiotic virginiamycin. Granting this petition would signal that the FDA is not serious in its stated intent to address antimicrobial resistance by reducing the inappropriate use of antimicrobials in food producing animals.

Allowing the feeding of virginiamycin to potentially billions of animals for no medical purpose as proposed in this petition is not in the interest of public health. This petition, if approved, because it is so clearly inconsistent with the risk management framework set out in GFI152, would undermine the guidance and undermine the FDA’s entire approach to managing resistance related antimicrobial use in livestock. The feeding of large numbers of animals with low doses of medically important antimicrobials for non-medical purposes contradicts the FDA’s own policy statements and guidance on addressing the problem of antimicrobial resistance.

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