Today was the first public hearing on House Bill 2598, which would stop the overuse of antibiotics on farm animals in Oregon. We expect a similar bill in the Senate, SB 920, to have a hearing in a few weeks. As expected, we are already seeing some of what opponents of will be saying.
While the most effective thing for our side is to make our case proactively, I am posting this to help set the record straight about some of the assertions made by the Oregon Veterinary Medicine Association in their written testimony against HB 2598.
(Much thanks to Gail Hansen, the staff veterinarian for the Pew Charitable Trusts’ antibiotics stewardship program, and other smart people at Consumers Union, CALPIRG, Natural Resources Defense Council and the Frontier Group.)
First, a reminder about the problem we are trying to solve, and the specific solution we are putting forward. There is a near scientific consensus we are in danger of losing antibiotics. We know that routinely giving antibiotics to any living being – human or animal – causes bacteria to mutate into stronger strains that are then resistant to the antibiotics. We know that 70% of antibiotics sold in the U.S. are sold for use on farm animals – often to either make the animals grow bigger, or to prevent disease because of unsanitary conditions. We know that the medical community recommends halting the practice of any routine use of antibiotics, using these drugs only when animals or sick, contain outbreaks, or other unique circumstances. This is what HB 2598 and SB 920 do.
Now let’s turn to OVMA’s arguments against HB 2598/SB 920:
Argument #1: “federal legislation” that is about to take effect will make HB 2598 moot.
Clarifier: no federal legislation has or is expected to be passed. Instead, the Food and Drug Administration is expected to finalize voluntary guidelines to promote the more judicious use of antibiotics.
More important, the differences between the FDA’s voluntary guidelines and HB 2598/SB 920 are significant [link to in-depth OSPIRG Foundation report on the topic]. Let’s start with a summary of the FDA guidelines:
- They ask drug companies that supply human-important antibiotics for farm usage to voluntarily agree not to sell antibiotics for growth promotion by the end of 2016, but continue to allow drug companies to sell these drugs for routine disease prevention.
- They require veterinary oversight and supervision for the use of feed antibiotics that are medically important for humans.
- They loosen up the definition of “oversight and supervision” such that vets don’t have to be on the premises or inspect animals before allowing a prescription – unlike how it typically works with humans. The point isn’t whether or not this is a good idea, but rather, to make sure laypeople are not mislead into thinking the level of scrutiny is the same.
In contrast to the FDA guidelines, HB 2598 and SB 920 prohibit giving antibiotics to farm animals for both growth promotion and disease prevention – except in emergency situations to contain outbreaks.
Here’s why the FDA’s approach is flawed: You can’t solve the problem without addressing disease prevention. OVMA’s assertion to the contrary contradicts mainstream medical science. Humans are not supposed to routinely take antibiotics to prevent getting sick; neither should animals. That’s an established, consensus viewpoint in the medical world.
To be clear, it should be OK to give animals antibiotics to prevent disease to contain an outbreak or other unique situations. That is why HB 2598/SB 920 includes a set of exceptions to allow antibiotics to be used to contain outbreaks – precisely to address the “herd health” concern expressed by OVMA.
However, under no circumstances should antibiotics be used on a regular, ongoing basis to prevent disease. Many small farmers tell us that such practice is simply a crutch for poor animal husbandry – unsanitary conditions, bad diet and so forth. This point is so well-established – the latest data on this point just published in the Proceedings of the National Academy of Science – that it is somewhat astonishing that anyone would deny it at this point.
It is this ongoing, regular disease prevention use that is as much, and possibly more, of a problem than growth promotion. The animal drug industry’s own trade group estimates that only 10-15 percent of antibiotics used on animals are for growth promotion alone – leaving an awful lot of antibiotics to be used for routine disease prevention.
Which is why it is not surprising that the following two things are true: a) the major drug companies and feed manufacturers have mostly said they will comply with the guidance by the end of 2016; b) the major drug companies have stated in a number of occasions that they don’t expect the FDA guidance to impact sales.
This isn’t just theory. The Netherlands has been working to limit antibiotic overuse for several decades. They initially began with a ban on antibiotic use for just growth promotion. However, antibiotic sales (and subsequent overuse) didn’t decline until they extended the ban to include disease prevention. The previously mentioned OSPIRG Foundation report tells the story in more detail.
Argument #2: some of the antibiotics in HB 2598, like penicillin, are not being used in human medicine anymore. To be clear, HB 2598’s list of antibiotics is tethered to the World Health Organization’s list of Critically Important Antimicrobials for Human Medicine. That’s right, it is an official list compiled by some of the world’s top medical professionals, periodically updated. I hope it goes without saying that it makes sense to follow the lead of the WHO in defining what types of antibiotics we need to be worried about.
It is also true some antibiotics like are declining in use – largely due to antibiotic resistance, which is exactly why we need to protect them now. For example, according to the Merck Veterinary Manual, there is general cross-resistance among tetracyclines. As for penicillin, according to the Infectious Disease Society of America, penicillin still remains the treatment of choice for strep throat.
Argument #3 isn’t as much an argument as a somewhat passive statement that implies that HB 2598/SB 920 won’t allow vets to prescribe appropriate dosages on animals that truly are sick. This simply is not true. HB 2598/SB 920 give farms a wide berth to give animals antibiotics in critical, non-routine situations to contain outbreaks. In addition, we have offered to amend the bills to clarify that nothing in the bill should be construed to prevent antibiotics, when given to animals, to be given at appropriate treatment levels.
The only other thing worth mentioning is to point out that OVMA is not quite correct when they say that vets have no legal ability to deviate from the indications on a medication’s label, and that all labels are precise in dose, duration, species and disease. In 1994, Congress amended the law to allow vets to deviate from the label in certain circumstances (here's an example of how this plays out in real life). Today, according to the FDA, there are around 100 labels that don’t have a specified duration and/or are not for a specified disease (you can find plenty of examples at this FDA database).