Urge FDA to Strengthen Measures to End Overuse of Antibiotics on Industrial Farms

Up to 70 percent of all antibiotics sold in the United States go to healthy food animals to offset the effects of overcrowding and poor sanitation, as well as to promote faster growth. But leading medical groups warn that this routine use of antibiotics creates new strains of dangerous, drug-resistant bacteria that threaten human health.

The U.S. Food and Drug Administration (FDA) just issued draft measures to limit the overuse of antibiotics in food animal production. While this move is a welcome step forward, the documents fall short in many areas.

Please join us in asking the FDA to close the loopholes so that life-saving antibiotics are no longer misused on industrial farms.
Subject: FDA: Close the Loopholes to End Overuse of Antibiotics on Industrial Farms

Dear Commissioner Hamburg,

I am a concerned citizen writing to ask the U.S. Food and Drug Administration (FDA) to take action and protect human health by finalizing Guidance 209 (Docket No. FDA-2010-D-0094) and improving draft Guidance 213 (Docket No. FDA-2011-D-0889) and Veterinary Feed Directive; Draft Text for Proposed Regulation (Docket No. FDA-2010-N-0155).

[Your personal comments will be added here.]

I am pleased that FDA released these documents. This is an important step to help protect the public's health from antibiotic-resistant bacteria linked to the overuse of antibiotics in food animal production. Thanks to the action you have taken, antibiotic-resistant bacteria should become less of a threat to human health. However, several important improvements are needed, and while these guidance and draft rule text are important initial actions, ultimately comprehensive and mandatory measures will be needed to fully ensure long-term public health protections.

Most notably, the agency has failed to adequately address the massive overuse of the drugs to compensate for the effects of overcrowded and unsanitary conditions -- uses sometimes referred to by the pharmaceutical and agricultural industries as "disease prevention." In order to fulfill its mandate to protect public health, FDA must significantly limit use of life-saving antibiotics for disease prevention purposes. These uses should be a last resort, when all other options have failed. FDA should work in partnership with the U.S. Department of Agriculture to ensure food animal producers first solve crowding and sanitation problems by changing practices before resorting to antibiotics.

In addition, it is unclear how FDA will monitor antibiotic use and resistance rates to measure the effectiveness of its action. The agency must let the public know what its plans are. If these measures do not significantly reduce antibiotic use and drug-resistant bacteria, then FDA should detail how and when it will take additional steps to put stronger measures in place.

Again, I would like to thank you for taking action on this very important issue. By eliminating the overuse and misuse of antibiotics in food animal production and reducing the prevalence of antibiotic resistance, we are saving antibiotics and allowing them to remain effective for treating sick people and animals. I look forward to seeing how the agency improves its plans to protect our health.
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