The FDA Needs to Collect Critical Data on Antibiotic Use on Farms
By Madeleine Kleven, Safe and Healthy Food Program Coordinator
Antibiotic use, especially overuse in animal agriculture, is a primary selective force behind the emergence of antibiotic resistant bacteria. In order to combat the spread of resistance, antibiotic stewardship - stopping the overuse of antibiotics - is essential. However, veterinary antibiotic use and stewardship cannot be optimized without measurement. It is impossible to know if efforts to reduce the overuse of antibiotics are effective or creating meaningful change over time, if there is no actual data on how antibiotics are being used.
Largely because of efforts from FACT and our allies, the FDA currently collects data on sales of antibiotics. It reports how much of a certain antibiotic was sold for use in food production and relies on estimates to know which animals are receiving the drug. Though these data are useful to have, they give absolutely no indication of why an antibiotic is being used (what disease it is treating), truly what animal is being given the antibiotic, or when (or how long) an animal is receiving it. Despite the FDA’s consistently touted goal to collect data on how and why antibiotics are being used on farms, here we are 20 years later without a program in place.
After years of FACT and others advocating for use data, the FDA finally released a report last year with a proposal for how to collect antibiotic use data on farms. They proposed a public private partnership where data would be voluntarily submitted by livestock confinement facilities to an industry-controlled data consolidator which would analyze and anonymize the data and then share it with FDA. FDA would then share that data with the public. FACT along with other groups within the Keep Antibiotics Working coalition were interviewed during the development of the initial proposal and we were given the opportunity to provide feedback and input on the completed proposal. After receiving public feedback and private feedback from industry and other stakeholders, the FDA just released another report on their proposed framework for collecting the use data. Unfortunately, public interest voices have been largely ignored in all of the FDA’s proposals and many of our concerns have not even been acknowledged.
This includes our biggest concern - that a framework based on voluntary participation will not be representative of the industry as a whole. As it stands, large scale factory farms who may be overusing antibiotics most egregiously have no incentive to participate since it will likely make them look bad, and they are not interested in addressing the problem of antibiotic resistance. This creates a very skewed view of the industry as a whole. As stated above, stewardship and antibiotic use cannot be optimized without measurement. Without an accurate representation of how antibiotics are being used, we cannot move forward with efforts to improve stewardship and slow the antibiotic resistance crisis.
Rather than a public private partnership, we are asking the FDA to begin collecting available antibiotic use data from feed mills. Existing rules require the feed mills to keep this data and make them available to the FDA for inspection. California already collects some of this data from animals raised in the state and has demonstrated its validity as a data source. At the very least the FDA should use this data to complement other on-farm data being collected.
Please use this link to write to the FDA to tell them to curb antibiotic resistance by gathering representative, national data that will help to improve stewardship and reduce the overuse of antibiotics.
To view FACT’s comments submitted to the docket on behalf of 11 ally groups in the Keep Antibiotics Working Coalition, use this link.