This petition mischaracterizes the FDA policy, the way antibiotics are used currently and how they will be used after implementation by January 1, 2017. We urge FDA to reject the petition and continue to focus on the collaborative efforts to implement the new judicious use policy.
AHI and its member companies, along with the producer, veterinary and animal feed communities, are all working to implement FDA’s new policy on antibiotics by the end of this year. By January 1, 2017, FDA’s policy will require that medically important antibiotics used in animal feed and water be used only to fight disease under the supervision of a veterinarian. It will not permit use of these products for the purpose of growth promotion. As FDA has explained, the bulk of these changes will be implemented simultaneously at the end of this year and many member companies have already begun making the necessary changes. This process was the product of a years-long effort to gain a consensus among all stakeholders.
All remaining uses of medically important antibiotics will be therapeutic, or targeted, uses. The FDA-approved label for each product – which must be followed exactly — designates a specific disease or pathogen to be targeted by the use of the antibiotic. Veterinarians will not be able to order these products for growth promotion under the guise of prevention, as the petitioners imply, both because it will be illegal for them to do so and because the doses and duration of therapy are not the same as those that were approved for growth promotion. The ability to both treat and prevent disease is critical to both human and animal health. It is inhumane and unethical to ask producers and veterinarians to allow animals to suffer when it is clear disease threats exist.