U.S. Food and Drug Administration recently received more than 180,000 hand-delivered letters from citizens concerned about proposed FDA action on antibiotic use in animals. These concerned citizens represent people who see a connection between the use of antibiotics in animal agriculture and an increase in human resistance to the same life-saving drugs.  The letters were delivered on the eve of the Aug. 27 cut-off date for public comment on the issue.

A broad coalition of organizations encouraging new FDA regulatory guidelines collected and delivered the letters. The groups include the Center for Food Safety; Center for Science in the Public Interest; CREDO Action; FamilyFarmed.org; Farm Aid; Food & Water Watch; Food Democracy Now!; The Humane Society of the United States; Organic Consumers Association; and Union of Concerned Scientists.  A press release from the Center for Food Safety describes these organizations as “committed to saving antibiotics as pillars of public health in the United States.”

Many consumer advocates and health professionals agree that the widespread use of antibiotics in animals intended for human consumption may have contributed to a spike in human antibiotic resistance.  In mid July, Dr. Joshua Sharfstein, Deputy Commissioner of the FDA, testified before Congress on the issue of antimicrobial resistance.

“FDA concludes that the overall weight of evidence available to date supports the conclusion that using medically important antimicrobial drugs for production purposes is not in the interest of protecting and promoting the public health,” he explained. “Developing strategies for reducing antimicrobial resistance is critically important for protecting both public and animal health.”

Though Sharfstein’s testimony expressed a hard-line approach to the issue on behalf of the FDA, the coalition of concerned organizations believes that the Administration may be on the brink of taking a big step backward in regards to antimicrobial resistance. The comment period requested by the FDA regards two recently proposed actions. The first is the agency’s intention to alter the Veterinary Feed Directive (VFD) guidelines, which govern the role of veterinarians in prescribing antibiotics for animal use.  The second possible action is a measure that asks the animal agricultural industry to voluntarily decrease antibiotic use.

“Reflecting the view of leading scientific and health experts, the citizen comments express concern that the planned revisions to VFD guidelines could weaken veterinary oversight and controls on antibiotic use on industrial farms and that the FDA guidance on non-judicious use does not sufficiently curtail the misuse and overuse of antibiotics in animals that are not sick,” the groups explained in a press release.  The groups want mandatory, rather than voluntary,  federal guidelines to ensure that antibiotics can only be used under veterinary supervision to treat sick animals.

The organizations shared parts of some of the 180,000 letters sent to the FDA by concerned Americans:

–  “My healthy and gorgeous dream boy of a son, Simon, died within 16 hours of his first symptoms.  The cause: antibiotic resistance.  Simon contracted an antibiotic resistant bacterium, MRSA (methicillin-resistant Staphylococcus aureus).  His infection could
 have been prevented years ago when bacteria actually succumbed to antibiotics.”

–  “Take this opportunity to protect our food supply, our population, and the future of medicine with a meaningful regulation that helps to solve a dangerous current situation.”

–  “Antibiotics in agriculture should be used under direct supervision of a veterinarian on individual animals.”

–  “I am an infectious disease specialist, and well aware of the progressively increasing problem of resistant bacteria, now not only a problem in hospitalized patients, but in many individuals acquiring hard to treat infections in the community. Scientific research has established that the widespread non-therapeutic use of antibiotics in the raising of food animals has contributed greatly to this problem. I strongly support new regulations to ban the use of antibiotics in feed, and restriction of antibiotics to treatment for infection, carried out by licensed veterinarians.”

These letters will be joined by others expressing opposing viewpoints.  Hoosier Ag Today, a radio and Internet based Indiana news service, reported that the Competitive Enterprise Institute (CEI) has also submitted comments to the FDA about its proposed actions. The Institute is a public policy think-tank advocating free markets and limited government.  The group warns that a ban “could unintentionally increase the threat of foodborne illness in the United States.”

“Whether you’re talking about human or animal use, banning beneficial uses today can have negative impacts on human and animal health just as surely as a lack of long-term drug efficacy can,” said Gregory Conko, CEI’s Director of Food and Drug Policy. “Instead, we need to balance the current benefits of antimicrobial use against the inevitable development of resistance, and this can include using antibiotics for livestock growth promotion purposes.”

The widespread debate around this issue is further complicated when analyzing the results of bans on antibiotics in animal feed in other nations such as Canada, North Korea, and the European Union. Some reports claim that these bans did nothing to improve human health. Other studies show that the bans may have done a lot to improve human health.  Denmark passed some of the first such bans back in 1997, and CBS news reported on the country’s results.

“According to one study, when different countries introduced certain antibiotics on farms, a surge occurred in people contracting antibiotic-resistant intestinal infections one to two years later. One infection, Campylobacter, increased 20 percent in Denmark and 70 percent in Spain,” reported CBS news. “After the ban, a Danish study confirmed that removing antibiotics from farms drastically reduced antibiotic-resistant bacteria in animals and food.”

A bill introduced by Representative Louise Slaughter (D-NY) is called the “Preservation of Antibiotics for Medical Treatment Act” (PAMPTA).  Slaughter’s Website explains that the measure would: “phase out the non-therapeutic use in livestock of medically important antibiotics; Require this same tough standard of new applications for approval of animal antibiotics; Does not restrict use of antibiotics to treat sick animals or to treat pets and other animals not used for food.”  The bill was introduced in 2009 and has been referred to committee.

Though there is debate about what will solve the problem, farmers, health experts, congressmen and FDA officials agree that the current situation in the United States is unacceptable.

In Sharfstein’s July testimony before Congress he explained, “Resistant pathogens lead to higher health care costs because they often require more expensive drugs and extended hospital stays.  The problem is not limited to hospitals.  Clinicians practicing in every field of medicine, including my own field of pediatrics, encounter resistant infections frequently.  So, too,
do veterinarians.”

The Infectious Diseases Society of America noted in a 2004 report that, “About two million people acquire bacterial infections in U.S. hospitals each year, and 90,000 die as a result.  About 70 percent of those infections are resistant to at least one drug.