Reply to “Simple Solutions Reflect Misunderstanding of Animal Antibiotic Use”

REPLY

We understand and appreciate Dr. Carnevale's interest, as expressed in his letter, in tools that can increase the short-term profitability and efficiency of industrial-scale animal husbandry (1). However, the longer-term societal good in preserving medical effectiveness of antibiotics must prevail.

In arguing against our proposed USDA label for animal products raised without growth-promoting use of antibiotics, he cites a confusing morass of labels on U.S. poultry products. This situation supports the need for a federal label, in keeping with the government's authority and responsibility to protect consumers and prevent unfair competition. Rather than being “one more label,” federal certification and labeling programs have proven repeatedly to provide consumers with a beacon of credibility and standardization to overcome label confusion. (In our commentary, we cited several examples of successful USDA labels. There are additional examples of Federal agencies providing clarity to consumers through certification and labeling programs, such as the EPA Energy Star program [http://www.energystar.gov/; accessed 26 October 2014].) Dr. Carnevale also makes a semantic argument against our proposal by asserting that veterinary medicine uses feed as a vehicle for therapeutic administration of antibiotics, which a “no-feed antibiotics” label would undermine. A deliberative process of choosing the specific label terminology would strike a constructive balance between technical precision and lay accessibility. While the label wording we offered as a suggestion might likely not go on products, the principle that is the basis of our proposal remains.

Our suggestion that antibiotic use in animal herds, poultry flocks, etc., be regulated through the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) is not contrary to the potential scope of the legislation. While FIFRA authority to date has largely been applied to plant products, the legislation in defining use of pesticides specifically notes that “application is to the crop, animal, or site specified on the labeling” (2). The FIFRA does indeed exclude the EPA from regulating substances that are already regulated by the FDA, but that is precisely what is at question with antibiotic use for nontherapeutic purposes in animals. It may even require amendment of existing legislation to clarify a role for the EPA in this arena. Our proposal that the EPA “explore requiring FIFRA registration” would certainly involve cooperation with the FDA, legislators, and the public to reach a tenable solution. Even for FDA-regulated articles, there are issues such as those concerning drug-infused effluents that could lie squarely within within the EPA's mandate.

We attempted to make the distinction between the use of “medically important” antibiotics as currently defined by the FDA and the problem of potential cross-resistance. While coccidiostatic ionophores may not be classified as antibiotics in other countries, as Dr. Carnevale notes, the potential for resistance linked to resistance to other antibiotics requires study. We know that resistance to many antibiotics can hitchhike with a single element that is under selection—an evolutionary phenomenon that will not be governed by regulatory definitions such as “medically important” or what is classified as an antibiotic.

Dr. Carnevale intimates that we “advocate simple solutions” to the problem of antibiotic resistance. On the contrary, in our commentary we stated that “concerted efforts” are necessary and acknowledge throughout the complexity of the issues. In part, the complications that the FDA has faced in establishing decisive regulation of antibiotic use in animals were what stimulated our suggestion that an alternative authority might be exercised.