To understand animal drug use, estimates are better than nothing, but actual data are needed
The FDA is announcing this morning that it plans to collect more estimates from animal drug manufacturers about how much of the antibiotics sold are for use in particular species, i.e. whether the drugs are being sold for use on cows, pigs, chicken, or other animals. This is a modest improvement over FDA's current data collection, and it's good to see FDA taking this step, but more and better data is needed. As FDA acknowledges, "more detailed information is needed about on-farm use practices to adequately understand links between usage patterns and trends in resistance." More information is also needed to assess progress in reducing the overuse and misuse of antibiotics in livestock that is contributing to growing crisis of antibiotic resistance which threatens the efficacy of these life-saving drugs. That's why we support Rep. Slaughter's Delivering Antimicrobial Transparency in Animals (DATA) Act, which was also introduced today.
Why is data on on-farm use needed? Because better information about on-farm use is essential for tackling the rise of antibiotic resistance. First, drug manufacturers can only provide a guess-timate of antibiotic use in meat and poultry production. Second, information on the purposes for which the antibiotics are being used (e.g. to promote growth, to treat disease, etc.) is essential for measuring progress under FDA's Guidance 213. Guidance 213 relies on voluntary action from drug manufacturers to stop certain routine, prolonged uses of antibiotics on large numbers of animals when used to speed up animal growth, but turns a blind eye to such uses when they are used to compensate for crowded, dirty, and stressful conditions in which the animals are often housed. Data on the purpose of use is vital for assessing whether use is shifting in response to FDA's guidance, if use is shifting to other justifications for use, and to understand links between use patterns and resistance trends.
The DATA Act would get actual livestock antibiotic use information from large meat and poultry producers on both the amount of antibiotics being used in different species of livestock and on the use for different purposes. Actual use numbers and a breakout by the justification for use is what the FDA should be aiming for, along with information on geographical and seasonal variations. FDA should require such reporting as part of its Veterinary Feed Directive (VFD) rulemaking as we and others have long requested, and--particularly if FDA believes that it doesn't have the authority to collect that data--it should be supporting Rep. Slaughter's bill.