Before we get all warm and fuzzy about the fact that the FDA is making a public display of ratcheting down antibiotic use in livestock agriculture, a reality check is in order. Yes, it's official: Three years from now, in a perfect world, most producers and pharmaceutical companies will be compliant with FDA guidances 209 and 213. But those guidelines were written a couple of years ago. There is nothing new here, folks, except that FDA is now making noises as if something special has happened.
What is to be emphasized here is that these guidances are voluntary. Not mandatory. Not law. They also happen to be quite loosely written. Saying that antibiotics will no longer be given as a matter of course for growth promotion or other "production purposes" sounds really good. Some pharmaceutical companies have already begun to change how they label their drugs, no longer selling for "growth promotion." But the reality is that producers can now say that those same antibiotics are given for "disease prevention." A neat trick, which will presumably assuage the current consumer concerns, but will probably not result in any substantial reduction in the actual use of these drugs.
Sure, more veterinary oversight will be required in order to obtain a prescription for "disease prevention." However, even the livestock industry concedes that there aren't anywhere near enough large animal vets around to actually monitor the health of a herd. Thus blanket prescriptions with no actual oversight are all too likely, given the fact that there is no possible way that the few large animal vets in the field will have the opportunity or the time to inspect all the livestock in this country.
The debate would appear to be coming to a head, with all this press around the "new" guidances. In fact, it is really just business as usual, though certainly encouraging that the issues are being addressed publicly by the principal players, rather than the decades-long stonewalling of the past.
As a bit of background, I can offer this. In November, I attended the National Institute of Animal Agriculture Symposium on antibiotics, titled Bridging the Gap -- that gap being more like the yawning chasm between public health and animal health. At the symposium, which lasted three days, there was a formidable assembly of talent in the shape of veterinarians, microbiologists, public health officials from the Center for Disease Control and Prevention and scientists from the USDA and from numerous land grant universities.
On day one, public health officials laid out the case of how antibiotic resistance is rising and how more needs to be done in the human medicine sector to grapple with this problem. Early on in the proceedings, Dr. Terry Dwelle, North Dakota's state health officer, startled me with this gem: "Maybe it's time we started talking together about how human medicine and vet medicine can work to develop a comprehensive program to reduce antibiotic resistance." Seriously? After all, antibiotic resistance has been an ongoing concern since the first dose of penicillin squirted out of a needle. Certainly the FDA has been sparring to no avail with the livestock industry since the 1970s on the overuse of antibiotics in animal agriculture. So in 2013, is it really possible that we are only now getting around to this dialogue?
Consider this nugget of information delivered by Dr. Steven Solomon from the CDC: "There have been 2 million plus illnesses from antibiotic resistance and 23,000 deaths. This is a conservative estimate." Dr. Solomon went on to say that "antibiotic resistance is the most complex problem in public health." This raises the question of why the CDC has not been a more active participant in sounding the alarm. It wasn't until this November that they finally published a comprehensive report on the rise of multidrug-resistant pathogens.
The second day of the symposium was devoted to the science of antibiotic resistance, and whether or not it was sufficiently proven that the routine use of antibiotics in livestock feed as a "growth promotant" had contributed to the numbers of resistant pathogens in our food supply. Never mind that we have all sorts of new strains of salmonella, campylobacter and listeriosis, common food-borne illnesses, which are multidrug-resistant, and could only have developed from the livestock sector. Despite the emergence of these new pathogens and the damning evidence of many studies demonstrating this very fact, apparently none of this information is sufficiently persuasive to compel belief in these particular scientists, many of whom toil away in university labs funded by pharmaceutical and meat companies.
Master of ceremonies at this event was Dr. Richard Raymond, a retired medical doctor and former director of the Food Safety and Inspection Services at USDA. A consultant to Merck and Elanco, he has been a vocal defender of the livestock industry and their use of antibiotics. Dr. Raymond vigorously disputed the oft-quoted statistic of 80 percent of antibiotics produced in the U.S. being directed into livestock, making the point that one entire class of drugs doesn't even enter human medicine. Threading the needle, he managed to whittle that statistic down to about 17 percent, with the apparent implication being that if it's only 17 percent, it can't possibly be having an impact on human health. My jaw literally dropped when he pronounced that "as long as one of the antibiotics still works, it doesn't matter if five others do not."
According to Dr. Raymond and many other participants, the blame for our diminished medical arsenal seems to be resting on doctors who have over prescribed. And that may well be true, but the medical profession is working hard on developing much stricter oversight, while the livestock sector has been issued "voluntary guidances" by the FDA. Meanwhile, animal agriculture consumes many millions of pounds more of antibiotics, (there is no oversight in animal medicine of dosage, frequency or duration) than human medicine does. And while the overlap of what is used in treating humans and animals is not huge, it remains very significant in the development of multidrug-resistant disease. Ten of the most commonly prescribed antibiotics in human medicine are also routinely used in large animal veterinary practices.
While we can all appreciate the baby steps that these guidelines (which can be read here), represent, this is hardly the magic bullet we need to stave off the moment when a routine infection can become life-threatening.
What has to happen in livestock agriculture is nothing less than a paradigm shift in production practices. Following the example set in Europe, using better hygiene and housing, probiotics and vaccines, would shift much of the burden off of antibiotics. Americans have historically demanded and been supplied with cheap meat; we must now make corrections to our sense of entitlement as consumers. Farmers and ranchers cannot be expected to make these changes if we cannot make our own adjustments to what we are willing to spend. The burden must be shared if we are to protect our medical defenses as well as our agricultural sector. Ultimately it is up to consumers to force the issue through their purchases. We can neither wait nor hope for the government or the industry to act responsibly to address this all important issue of public health.
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