Antibiotic use not slowing as Needed

Pre 1996 new animal drugs were dispensed one of two ways, either over-the-counter (OTC) or by prescription. That same year Congress created the Animal Drug Availability Act (ADAA) which gave new drugs faster distribution & entry points into the animal feed market. Contrary to belief ADAA was also used to control & limit the use of medicated feed by moving those controls under the supervision of licensed veterinarians. The intent was to have licensed veterinarians reduce antimicrobial use thereby reducing the likelihood of further drug resistant bacteria. To enforce this change a new category of products was created dubbed the Veterinary Feed Directive (VFD) drugs.

In 2015, the Food and Drug Administration (FDA) published 21 CFR 558.6 a final ruling which revised the VFD regulation. This change linked the VFD with the Small Entity Compliance Guide (SECG), which helped small business to comply with VFD regulations. By aligning the SECG with section 212 of the Small Business Regulatory Enforcement Fairness Act (Public Law 104-121) controls were put in place to limit industry control over drug feed usage, thus moving those controls to licensed veterinarians.

In December 2016 the FDA implemented Guidance #213 which made it illegal to use some antibiotics without the consent of a licensed veterinarian. To go one step further, farmers must have a veterinarian client patient relationship (VCPR) as a requirement to obtaining permission to order & use certain feed drugs. Within the rule guidelines agriculture industry experts and the healthcare industry have concerns that current controls aren’t stringent enough to control antibiotic use in feedstock animals.

As an example some small farmers and all commercial farmers have licensed veterinarians on their staff payrolls, because of this reality the last two decades have shown there are no controls over antibiotic use in the agriculture industry. In a press conference given by FDA Commissioner Dr. Scott Gottlieb when asked isn’t humanity at risk if we don’t control antibiotic use? Dr. Gottlieb allegedly replied, there are 18 drug resistant threats to the U.S., 3 of which are urgent, 12 are serious and 3 are concerning threats.

To overcome these threats and to keep further drugs from becoming drug resistant we’re asking industry experts and companies to please limit their antibiotic use (FDA guidelines aren’t legally enforceable). When a reporter asked why doesn’t the FDA just create laws to control usage instead of guidelines? Dr. Gottlieb further replied, are you insane, only the poor are dying and or will die from having drug resistant bacteria in their food supply & bodies. The rich myself included only eat at organic restaurants & buy our food from small organic farmers, not from commercial farmers that fill supermarket shelfs with that poison, all I ask is that the rest of you folks die on time.

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