March 4, 2016
This blogpost is co-authored by Claire Fitch, Robert Martin, and Keeve Nachman.
Antibiotic resistance is a major public health crisis. Continued misuse of antibiotics will result in these lifesaving drugs no longer being effective in treating even the most routine infections. Data from the Centers for Disease Control and Prevention (CDC) provide support for the need for immediate action to preserve the effectiveness of antibiotics. Each year, at least two million Americans develop these infections, and of those, 23,000 die from them. Antibiotic-resistant infections are more costly to treat, can require lengthier hospital stays, and are more likely to require invasive procedures like surgery.
While clinical overuse is believed to play an important role in the development and propagation of antibiotic resistance, the use of antibiotics in food animal production is widely considered by the CDC and various scientists to be a critically important contributor to antibiotic-resistant infections in people. At the end of last year, the American Academy of Pediatrics published a technical report, detailing the evidence linking antibiotic use in livestock and antibiotic resistance in humans. The authors concluded that these drugs should only be used to treat and control infectious disease in order to prevent the promotion of resistance and harm to human health.
Are the FDA or Congress going to solve the problem?
The Food and Drug Administration has implemented a plan (targeted at drug companies) to eliminate certain uses, but this plan has been widely criticized and it is believed by many that it will not change the nature of antibiotic use in food animals (read our opinion on this in the Scientific American here and here). While legislators like Congresswoman Louise Slaughter (D-NY) have repeatedly introduced legislation that would change the way these drugs are used, these proposals have received paltry support, and as a result, little has changed in terms of federal policy.
What is happening in the state of Maryland?
Given this shortfall of action, the battle has been taken to the states. In CLF’s home state (Maryland), three bills have been introduced this year in the state legislature to address the matter:
- House Bill 1163 proposes to collect data on the use of antibiotics that are considered medically important in human medicine (a topic we’ve written on here).
- House Bill 829 and Senate Bill 607 are parallel bills that aim to collect the same data as HB 1163, but also aim to restrict the nontherapeutic use of medically-important antibiotics in animals, under some conditions.
While we believe that efforts to reduce the misuse of antibiotics and collect data on their use in Maryland are urgently needed, these bills, as written, will neither meaningfully curb agricultural antibiotic misuse nor yield adequate data to characterize antibiotic use in Maryland.
Essential components of antibiotics legislation
We provide here essential components of state legislation that would be needed in order to 1) meaningfully curb antibiotic use in animal agriculture; and 2) collect data that would support a better understanding of the nature of antibiotic use in the state and facilitate future actions to remedy misuse when and where it occurs.
Restrictions on antibiotic use in animal agriculture
Restrictions on the non-therapeutic use of antibiotics in animal agriculture should apply to every species of food animals and to all farms producing food animals, regardless of size. The proposed Maryland legislation contains exemptions that are too broad and arbitrarily exclude dairy cattle from measures to reduce the use of medically-important antibiotics. At a minimum, dairy cattle exemptions should be limited to the treatment of mastitis only. Species-specific exclusions cannot be justified and would compromise the value of legislation, particularly if similar legislation is later adopted in states with different agricultural production profiles.
Collecting actionable data
Antibiotics legislation should incorporate antibiotics use data collection, analysis, and reporting mechanisms in order to assess progress and justify further action–if needed–to curb misuse. Legislation should mandate the collection of all information contained in Veterinary Feed Directives (VFDs), including information on the location of farms where animals are prescribed medically-important antibiotics, as well as the prescribing veterinarian, in order for state agencies to identify problematic patterns of misuse and seek corrective action. This information could be protected by the collecting agency and never made publicly accessible—but to not even collect this information effectively limits any meaningful analysis of antibiotics use in the state, and prevents the state from investigating apparent misuse of these drugs.
It is important that a state health department be tasked with data collection and reporting responsibilities, as drug use and antibiotic resistance are primarily public health issues. At the federal level, issues of antibiotics in agriculture fall under the Food and Drug Administration, which is within the Department of Health and Human Services and not, for example, in the Department of Agriculture. State agriculture departments are tasked, partly, with the promotion of agriculture within their state, so it is not unreasonable to think that there may be conflicts of interest within such a department on limiting the use of antibiotics on farms. Additionally, state public health veterinarians and veterinary licensing boards are often housed within health departments, not agriculture departments. And if the legislation requires the collection of sensitive information like a veterinarian’s information or the location of a farm—information that we believe is essential to curbing antibiotic misuse in the future—then health departments are better-suited to protect this classified information, as they routinely protect human health information.
Analyzing data and reporting results to protect public health
There should be a plan for the analysis and dissemination of this data. Legislation should explicitly fund the state health department to perform the data collection, analysis, and reporting tasks that are necessary to assess antibiotic use trends. Ideally, a de-identified database (i.e. masking the identities of veterinarians and farms) would be made publicly accessible for researchers at universities and external organizations to analyze.
If inadequate antibiotics legislation is passed, people may feel like the antibiotics misuse problem has “been solved,” and it will be harder for additional improvements to be made. In order to obtain adequate data on the use of antibiotics on farms, substantially limit the nontherapeutic use of antibiotics, and prevent the adoption of similarly inadequate legislation in other states, we must pass more comprehensive legislation than the three bills introduced in Maryland.