Thank you, Mister Chairman and members of the Committee, for giving the American Veterinary Medical Association the opportunity to speak to you today. I am Dr. Lyle Vogel, Assistant Executive Vice President of the AVMA.
Because veterinarians are ethically charged with promoting public health in addition to protecting animal health and welfare, we participate in the prevention and control of both human and animal disease.
Antimicrobial resistance is a complex issue that is not going to be solved by seemingly simple solutions such as bans on certain labeled uses of antimicrobials without performance of a risk assessment on individual drugs or drug classes. Let me first say that not all antimicrobials are equal in their probability of creating a risk to human health. As a result, non-risk based bans of approved uses of antimicrobials will negatively impact animal health and welfare without predictably improving public health and may even harm public health.
The AVMA believes that the current science-based FDA approval process for new antibiotics and review of previously approved antibiotics under Guidance for Industry #152, provide sufficient safeguards for public health.
The AVMA advocates for improved monitoring systems for foodborne disease and antimicrobial resistance such as FoodNet and the National Antimicrobial Resistance Monitoring System sometimes called NARMS.
Since 1996, NARMS has provided a great deal of useful information. NARMS data, when combined with FoodNet data, demonstrates that the case rate of human illness with multidrug resistant Salmonella species has decreased 49% since 1996. And NARMS data also show that Salmonella from humans are one-half as likely to be resistant in 2004 as they were in 1996. Also resistance of Enterococcus to Synercid in the United States is 10 times less than in Denmark where the drug equivalent has been banned for almost a decade. This information indicates that there is not a public health crisis related to human pathogens that are thought to originate in animals.
In the late 1990s, Denmark began to ban antimicrobials used for growth promotion. The use of antimicrobials in feed and water for prevention, control and treatment of disease was not banned. The results in humans and animals have been very mixed. For example, resistance to vancomycin in Enterococcus from humans stayed at 0% from 1997 to 2006 but there have been dramatic increases in resistance to tetracyclines in Salmonella from humans. And as I mentioned, resistance to Synercid is ten times greater in Denmark than in the U.S.
While the total quantity of antimicrobials used in food animals in Denmark has decreased by 27%, the increase in disease has resulted in a 143% increase in the quantity of antimicrobials used for therapeutic purposes. And the antimicrobials now used more frequently are in classes which are also used in humans, such as tetracyclines.
Even though the results of the Danish ban are very mixed, proposals within the United States go beyond the Danish example by proposing to ban uses for the prevention and control of disease in addition to uses to promote growth.
Several risk assessments have been performed that demonstrate a very low risk to human health from the use of antimicrobials in food animals, and some of the models predict an increased human health burden if the use is withdrawn. Inappropriate reactions to the potential problem could have unintended consequences that negatively affect animal health and welfare, and, ultimately, could create public health risks.
The AVMA does not believe that the Food and Drug Administration needs new authority to regulate the human safety of animal drugs. Instead, the FDA needs additional resources to fulfill its existing mission.
Improved surveillance (and timelier reporting) of resistance, research to better understand the causality of resistance, decisions based on risk, and continued compliance with judicious use guidelines by veterinarians and producers; are sufficient to protect human health against the current small risks associated with veterinary medicine and animal agriculture without compromising the health of food animals or public health.
Thank you for the opportunity to appear before you today and speak about this important issue. Additional information is provided in the written testimony that has been submitted.
2017 American Veterinary Medical Association