The Gillings Sustainable Agriculture Project: A Gillings Innovative Laboratory

Urge The FDA To Prohibit Antibiotic Use For Production Purposes In Agriculture

By: J.T. Jobe

Antibiotics lose efficacy with use

• Antibiotics are important, often life-saving, forms of treatment for many human illnesses caused by bacterial infections
• All uses of antibiotics lead to evolutionary selection of antibiotic-resistant bacteria (“superbugs”) (2)(3)(6)
• After extensive use, a particular antibiotic may become less effective or even completely ineffective in treating bacterial infections (9)

Approximately 80% of antibiotics used in the U.S. are administered to animals, rather than humans

• In 2009, 16.4 million kilograms of antibiotics were sold for use in the United States (8)
  • 13.1 million kilograms were sold for use in food-producing animals
  • 3.3 million kilograms were sold for use in humans
• Food-producing animals are given antibiotics for three different purposes: (1)
  • Therapeutic: administered in high doses to treat individual ill animals
  • Prophylactic: administered in moderate to high doses to prevent illness in healthy animals at risk of becoming ill
  • Nontherapeutic: administered in low doses to promote growth rate, increase weight and improve feed efficiency (“production purposes”)

Antibiotics used for production purposes in agriculture unnecessarily put public health at risk

• Antibiotics used for production purposes are administered to entire groups of animals in low doses and on a regular basis, commonly via water or feed
• The nontherapeutic use of antibiotics for production purposes may create greater selective pressure for resistant bacteria than normal therapeutic use (6)
• Studies have directly linked the use of antibiotics in agriculture to increased levels of antibiotic-resistant bacteria in animals (4)
• Furthermore, studies have concluded that antibiotic-resistant bacteria are being transferred from animals to humans and that this poses a significant risk to public health (5)

Why antibiotics are still used for production purposes

• Improvements in “animal husbandry, feed formulation and on-farm hygiene” have been shown to be equally effective in raising healthy animals to market weight (1)
• Antibiotics, however, provide an easier, quicker and less expensive method to forgo such improvements yet still achieve desirable animal products
• Essentially, antibiotics allow poor agriculture practices to persist and in turn help keep the price of animal products low at the expense of public health

The FDA on the issue

• 1949:  The use of antibiotics for production purposes was approved, shortly after the growth promoting effects of low levels of antibiotics in animal feed was discovered (1)
• 1970:  The FDA completed a Task Force Report on the use of antibiotics in agriculture and recommended that antibiotics important to human health be prohibited for production purposes and that necessary therapeutic use be permitted only under the direction of a licensed veterinarian (4)
• 1977:  The FDA attempted to ban the use of penicillin and tetracyclines for productive purposes yet Congress rejected the recommendation, citing a lack of evidence directly linking the practice to an increase in human health risk, and ordered further research (4)
• 2012:  The FDA released an updated position on the issue, including a Guide for Industry entitled “The Judicious Use of Medically Important Antimicrobial Drugs in Food-Producing Animals” (4)
  • The guide contains a summary of notable research on the issue as well as non-binding recommendations for “judicious use” of antibiotics
  • The FDA defines “judicious use” as avoiding unnecessary or inappropriate use

Why the FDA must do more

• The latest effort by the FDA to limit the use of antibiotics in agriculture is non-compulsory and therefore will prove ineffective at reducing the public health risk posed by antibiotics in agriculture
• The alternatives to using antibiotics for production purposes require substantially more investment to achieve the same quality animal product
• The increased investment will require producers of animal products to raise prices and many consumers, perhaps unaware of the public health risks of antibiotics in agriculture, will not be willing to pay higher prices
• As a result, many producers of animal products will continue to use antibiotics for production purposes in order to keep prices low and consumer demand high
• The only method to effectively stop the use of antibiotics for production purposes is for the FDA to completely removal approval and prohibit the practice

References

(1)  Barton, MD. Antibiotic use in animal feed and its impact on human health. Nutrition research reviews 13.2 01 Dec 2000: 279. CABI Publishing. 13 Apr 2012.

(2)  Wolfgang Witte, Selective pressure by antibiotic use in livestock, International Journal of Antimicrobial Agents, Volume 16, Supplement 1, November 2000, Pages 19-24, ISSN 0924-8579, 10.1016/S0924-8579(00)00301-0.

(3)  Khachatourians, G.G. Agricultural use of antibiotics and the evolution and transfer of antibiotic-resistant bacteria. Canadian Medical Association Journal, November 3, 1998 159:1129-1136

(4)  USA. FDA. Health and Human Services. Guidance For Industry: The Judicious Use of Medically Important Antimicrobial Drugs in Food-Producing Animals. FDA, 13 Apr. 2012. Web. 13 Apr. 2012.

(5)  USA. Congressional Report. U.S. General Accounting Office. Antibiotic Resistance: Federal Agencies Need to Better Focus Efforts to Address Risk to Humans from Antibiotic Use in Animals. 1 Apr. 2004. Web. 13 Apr. 2012.

(6)  World Health Organization. The Medical Impact of Antimicrobial Use in Food Animals. Publication no. WHO/EMC/ZOO/97.4. World Health Organization, 17 Oct. 1997. Web. 13 Apr. 2012.

(7)  Union of Concerned Scientists. Food & Agriculture. Preservation of Antibiotics for Medical Treatment Act. Union of Concerned Scientists. 24 June 11. Web. 13 Apr. 2012.

(8)  Congresswoman Louise M. Slaughter. U.S. Congress. PAMTA. Congress. Web. 13 Apr. 2012.

(9)  Anomaly, Jonny. “Harm to Others: The Social Cost of Antibiotics in Agriculture.” Journal of Agriculture and Environmental Ethics 22.5 (2009): 423-35. SpringerLink. Web.

(10)  Gustafson, R.H. and Bowen, R.E. (1997), Antibiotic use in animal agriculture. Journal of Applied Microbiology, 83: 531–541. doi: 10.1046/j.1365-2672.1997.00280.x

(11)  McEwen, Scott A., and Paula J. Fedorka-Cray. “Antimicrobial Use and Resistance in Animals.” Clinical Infectious Diseases 33.3 (2002): 93-106. Oxford Journals. Web

(12)  Antibiotics in Agriculture: When Is It Time to Close the Barn Door? Marc Lipsitch, Randall S. Singer and Bruce R. Levin. Proceedings of the National Academy of Sciences of the United States of America , Vol. 99, No. 9 (Apr. 30, 2002), pp. 5752-5754

 

Annotated Bibliography

Anomaly, Jonny. “Harm to Others: The Social Cost of Antibiotics in Agriculture.” Journal of Agriculture and Environmental Ethics 22.5 (2009): 423-35. SpringerLink. Web.

• In this article, Dr. Jonny Anomaly, examines the controversial issue of antibiotics in agriculture from a philosophical, ethical standpoint.  Utilizing the Harm Principle, a common theme in liberalism that states coercion is only justified when necessary to prevent harm to others, he lays out an argument in favor of prohibiting the use of antibiotics in agriculture to protect human health now and in the future.

Gustafson, R.H. and Bowen, R.E. (1997), Antibiotic use in animal agriculture. Journal of Applied Microbiology, 83: 531–541. doi: 10.1046/j.1365-2672.1997.00280.x

• This article is a thorough review on many of the aspects of antibiotic use in agriculture.  The authors examine the history of antibiotic use, the current uses, the benefits to agriculture, and the risks to human and animal health.  They provide a balanced view of the important issues, evaluate regulatory options and, in conclusion, offer suggestions for future research.

McEwen, Scott A., and Paula J. Fedorka-Cray. “Antimicrobial Use and Resistance in Animals.” Clinical Infectious Diseases 33.3 (2002): 93-106. Oxford Journals. Web.

• This article focuses solely on the increased risk of antibiotic-resistant bacteria in animals, not humans.  The authors discuss in detail the history of antibiotics in agriculture and the evidence of increasing levels of antibiotic-resistant bacteria in animals.  Alternatives to antibiotics are discussed as well.

Marc Lipsitch, Randall S. Singer and Bruce R. Levin. Antibiotics in Agriculture: When Is It Time to Close the Barn Door? Proceedings of the National Academy of Sciences of the United States of America , Vol. 99, No. 9 (Apr. 30, 2002), pp. 5752-5754

• This article is a brief commentary on the controversy over antibiotics in agriculture.  The authors provide a summary of research findings that support ending the practice and warn that whatever action the FDA takes, it may be too little too late.

Barton, MD. Antibiotic use in animal feed and its impact on human health. Nutrition Research Reviews 13.2 01 Dec 2000: 279. CABI Publishing. 13 Apr 2012.

• This article addresses the growing concern over the use on antibiotic agriculture at the time of its publication.  It explains common misconceptions on the issue and points out that the majority of antibiotic-resistant bacteria that endanger human health are the result of the misapplication of the drugs in humans, rather than animals.  However, it still maintains that antibiotics in agriculture do potentially pose a risk to human health and identifies specific studies that have come to this conclusion.

Witte, Wolfgang. Selective pressure by antibiotic use in livestock, International Journal of Antimicrobial Agents, Volume 16, Supplement 1, November 2000, Pages 19-24, ISSN 0924-8579, 10.1016/S0924-8579(00)00301-0.

• Witte explains the basic concept of selective evolutionary pressure and explains how the current practice of antibiotic use in agriculture intensifies the effect.  He also discusses the long-term effects of this selective pressure and the prospects for slowing the trend.

Khachatourians, G.G. Agricultural use of antibiotics and the evolution and transfer of antibiotic-resistant bacteria CMAJ November 3, 1998 159:1129-1136

• This article also discusses the process of selective evolutionary pressure as a result of antibiotic use in agriculture.  In addition, the article discusses the potential methods of transference between animals and humans of antibiotic-resistant bacteria and the associated risks of such transference.

USA. FDA. Health and Human Services. Guidance For Industry: The Judicious Use of Medically Important Antimicrobial Drugs in Food-Producing Animals. FDA, 13 Apr. 2012. Web. 13 Apr. 2012.

• This is the official policy statement of the FDA concerning the use of antibiotics in agriculture.  It includes a summary of important research studies and policy proposals on the issue as well as guidance for the “judicious use” of antibiotics in the agricultural industry.

USA. Congressional Report. U.S. General Accounting Office. Antibiotic Resistance: Federal Agencies Need to Better Focus Efforts to Address Risk to Humans from Antibiotic Use in Animals. 1 Apr. 2004. Web. 13 Apr. 2012.

• This report offers a summary of U.S. and international policies regarding antibiotics in agricultural and the relevant political considerations governing the issue.  It also discusses the proper roles of various government organizations on the matter.

World Health Organization. The Medical Impact of Antimicrobial Use in Food Animals. Publication no. WHO/EMC/ZOO/97.4. World Health Organization, 17 Oct. 1997. Web. 13 Apr. 2012.

• This is a report from a World Health Organization meeting on the issue of antibiotics in agriculture.  Similar to the US-GAO report, this report summarizes important research on antibiotics in agriculture, the potential risks to human health and risk management strategies.  The report concludes with a list of priorities for future research and development in the area.

Union of Concerned Scientists. Food & Agriculture. Preservation of Antibiotics for Medical Treatment Act. Union of Concerned Scientists. 24 June 11. Web. 13 Apr. 2012.

• This is an open letter from an organization, The Union of Concerned Scientists, in support of the 2011 PAMTA (Preservation of Antibiotics for Medical Treatment Act) bill in the U.S. House of Representatives.  The letter offers a very brief and simple summary of the issue of antibiotics in agriculture and calls for the FDA to take aggressive action.

Congresswoman Louise M. Slaughter. U.S. Congress. PAMTA. Congress. Web. 13 Apr. 2012.

• This is an issue statement on Congresswoman Slaughter’s official website regarding the PAMTA bill.  Congresswoman Slaughter introduced the bill and defends her position with a summary of the issue and a plea to pass PAMTA for the sake of public health.

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