The Food and Drug Administration (FDA) approves antimicrobials used in livestock feeds to prevent, control, or treat certain diseases (therapeutic uses); or to promote growth or increase feed efficiency. The availability and effectiveness of antimicrobials are important for maintaining the health and welfare of food producing animals and ensuring human food safety.
The AVMA supports a transparent FDA drug approval process that is rigorous and based on substantial scientific evidence supported by data and that includes an assessment of food safety. The AVMA believes FDA must continue to rely on robust antimicrobial resistance surveillance (e.g., National Antimicrobial Resistance Monitoring System) and on science to evaluate possible public health impacts. Because of the national interest in ensuring food safety and public health and because of the interstate movement of animals and products in modern food production, the AVMA believes that a nationally coordinated effort is the only way to effectively address the issue of antimicrobial resistance.
All regulatory or legislative actions should be transparent and based on scientific risk analysis. Risk analysis should continue to evaluate the risks and benefits to animal health and welfare in addition to the risks and benefits to human health attributed to uses in animals. Risk analysis includes risk assessment, risk communication, and risk management actions that are commensurate with the level of actual risk. Risk management options are not limited to withdrawal of approval for a drug product, but can also include continued approval of use; review by the Veterinary Medicine Advisory Committee; and limitations of use such as use in only certain species or changing to a Veterinary Feed Directive drug.
The AVMA recognizes that more data are needed to complete a risk analysis on the public health significance of many antimicrobial uses in livestock feeds. The AVMA supports access to the data and actions necessary to conduct an accurate scientific risk assessment to facilitate risk-based decisions concerning the appropriate and judicious use of antimicrobials. We urge the FDA and other public health agencies, as well as veterinarians, livestock producers, and pharmaceutical companies to cooperatively support scientific studies needed to close the data gaps. The AVMA seeks input and support for a concerted and coordinated effort to obtain the data necessary to conduct assessments to enable risk-based decisions concerning use.
The AVMA recognizes the importance of antimicrobials that are also used in human medicine. To further safeguard public health and to maintain the long-term effectiveness of antimicrobials, the AVMA supports a science based medical evaluation to determine the appropriate use of such antimicrobials in animals. If determined through a risk analysis, the use of such antimicrobials should be authorized by and under the control and direction of a veterinarian. Veterinarians are professionally educated, trained, and licensed, and should retain primary responsibility for the use of important antimicrobials. The AVMA emphasizes the importance of the role of the veterinarian, the existence of the veterinarian-client-patient relationship, and the appropriate and judicious use of antimicrobials in animals.
The AVMA urges veterinarians to continually assess and critically review the uses of antimicrobials in livestock feed. Veterinarians should also recommend preventive practices to minimize the need for antimicrobials.
The AVMA welcomes stakeholder input and cooperation.