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Antibiotics are critical tools in human medicine. Medical authorities are warning that these life-saving drugs are losing their effectiveness, and there are few replacement drugs in the pipeline. Bacteria evolve in response to the use of antibiotics both in humans and in animals. Those bacteria that are resistant to antibiotics prosper as antibiotics kill the non-resistant bacteria. Once they emerge, antibiotic-resistant (AR) bacteria can transfer AR traits to other bacteria in animals and the environment. The development of antibiotic resistance is hastened by the use of low doses of antibiotics at industrial farms. The drugs are used routinely not to treat sick animals, but for growth promotion and disease prevention, a practice known as non-therapeutic use.
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Antibiotic Resistance 101: How Antibiotic Misuse on Factory Farms Can Make You Sick
Antibiotics are critical tools in human medicine. Medical authorities are warning that these life-saving drugs are losing their effectiveness, and there are few replacement drugs in the pipeline. Bacteria evolve in response to the use of antibiotics both in humans and in animals. Those bacteria that are resistant to antibiotics prosper as antibiotics kill the non-resistant bacteria. Once they emerge, antibiotic-resistant (AR) bacteria can transfer AR traits to other bacteria in animals and the environment. The development of antibiotic resistance is hastened by the use of low doses of antibiotics at industrial farms. The drugs are used routinely not to treat sick animals, but for growth promotion and disease prevention, a practice known as non-therapeutic use.
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Antibiotics are critical tools in human medicine. Medical authorities are warning that these life-saving drugs are losing their effectiveness, and there are few replacement drugs in the pipeline. Bacteria evolve in response to the use of antibiotics both in humans and in animals. Those bacteria that are resistant to antibiotics prosper as antibiotics kill the non-resistant bacteria. Once they emerge, antibiotic-resistant (AR) bacteria can transfer AR traits to other bacteria in animals and the environment. The development of antibiotic resistance is hastened by the use of low doses of antibiotics at industrial farms. The drugs are used routinely not to treat sick animals, but for growth promotion and disease prevention, a practice known as non-therapeutic use.
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How Antibiotic Misuse on Factory Farms Can Make You Sick
Food & Water Watch works to ensure the food, water
and fsh we consume is safe, accessible and sustainable. So we can all enjoy and trust in what we eat and drink, we help people take charge of where their food comes from, keep clean, afordable, public tap water fowing freely to our homes, protect the environmental quality of oceans, force government to do its job protecting citizens, and educate about the importance of keeping shared resources under public control. Food & Water Watch California Ofce 1616 P St. NW, Ste. 300 25 Stillman St., Ste. 200 Washington, DC 20036 San Francisco, CA 94107 tel: (202) 683-2500 tel: (415) 293-9900 fax: (202) 683-2501 fax: (415) 293-8394 info@fwwatch.org info-ca@fwwatch.org www.foodandwaterwatch.org Copyright February 2014 by Food & Water Watch. All rights reserved. This report can be viewed or downloaded at www.foodandwaterwatch.org. About Food & Water Watch Executive Summary. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 How Industrial Agriculture Makes Antibiotic Resistance Worse . . . . . . . . . . . . . . . 4 Beyond Survival of the Fitest . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 How Antibiotic-Resistant Bacteria Spread . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 From Meat to Consumers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 Antibiotic-Resistant Foodborne Illness . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 From Livestock to Farmers and the Environment . . . . . . . . . . . . . . . . . . . . . . . . . . 9 INFOGRAPHIC: How Antibiotic Misuse on Factory Farms Can Make You Sick . . . . . . . . . . . . . . . 10 Tackling Antibiotic Resistance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 Ending Nontherapeutic Use of Antibiotics . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 How Antibiotics Are Regulated . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 The Food and Drug Administration . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 Tetracyclines and Penicillins . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 Fluoroquinolones . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 Cephalosporins . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 Voluntary Guidance for Judicious Use . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 Congress . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16 Recommendations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 Endnotes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 2 Food & Water Watch - foodandwaterwatch.org Executive Summary Antibiotics are critical tools in human medicine. Medical authorities are warning that these life-saving drugs are losing their efectiveness, and there are few replacement drugs in the pipeline. 1 Bacteria evolve in response to the use of antibiotics both in humans and in animals. Those bacteria that are resistant to antibiotics prosper as anti- biotics kill the non-resistant bacteria. Once they emerge, antibiotic-resistant (AR) bacteria can transfer AR traits to other bacteria in animals and the environment. The development of antibiotic resistance is hastened by the use of low doses of antibiotics at industrial farms. The drugs are used routinely not to treat sick animals, but for growth promotion and disease prevention, a practice known as nontherapeutic use. 2
Both in the United States and worldwide, agriculture uses vastly more antibiotics than human medicine, 3 and agricul- ture uses drugs from every major class of antibiotics used in human medicine. 4 The Food and Drug Administration (FDA) reported in 2011 that 80 percent of antibiotics in the United States are sold for agricultural purposes. 5 AR bacteria can spread from farm animals to humans via food, via animal-to-human transfer on farms and in rural areas, and through contaminated waste entering the environment. The most commonly afected populations are those with under-developed or compromised immune systems pregnant women, children, the elderly and people with certain health conditions but increasingly, AR bacteria have the potential to afect anyone. Antibiotic resistance has become a global problem. 6
People get sicker from these infections, as it takes multiple rounds of increasingly stronger antibiotics to stop the infection, allowing the infection to progress further than it might otherwise. Fewer drug options can make it harder for doctors to treat patients with allergies and make it more likely for patients to require stronger drugs given intravenously. 7
The Centers for Disease Control and Prevention (CDC) estimates that at least 2 million Americans each year experience AR infections, leading to at least 23,000 deaths. 8 Approximately 22 percent of those infections originate from foodborne pathogens. 9 Scientific estimates of the national cost of AR infections are in the billions. 10 Antibi- otic resistance has become such a serious problem that there are few or no treatment options in some cases, and pharmaceutical companies are not producing new treat- ments fast enough to keep up with the need. 11 The livestock industry still asserts that there is not enough scientific evidence to ban nontherapeutic uses of antibi- otics, 12 but the evidence is clear. Several DNA analyses Antlblotlc Peslstance l0l - How Antlblotlc Mlsuse on Pactory Parms Can Make ou Slck 3 of AR bacteria point to livestock as the source. The American Public Health Association, 13 American Medical Association, 14 American Academy of Pediatrics, 15 Infectious Disease Society of America 16 and World Health Organiza- tion 17 have all issued statements calling for restrictions on nontherapeutic uses of antibiotics in livestock. The federal governments National Antimicrobial Resis- tance Monitoring System (NARMS) collects samples of bacteria from chicken breasts, ground turkey, ground beef and pork chops and measures the presence of several drug-susceptible and AR foodborne pathogens. 18 Food & Water Watch has analyzed the 2011 NARMS data to estimate how widespread AR bacteria were as a whole in the retail meat samples collected. Some level of AR bacteria was common in all four meats. AR Salmonella was present in 9 percent of chicken breast samples and 10 percent of ground turkey samples. The presence of AR E. coli in the samples collected varied widely: 66 percent in ground turkey, 53 percent in chicken breasts, 15 percent in pork chops and 9 percent in ground beef. 19
Despite the urgency of this growing public health threat, neither Congress nor the FDA have taken suficient steps to restrict the nontherapeutic use of antibiotics in livestock. On the one hand, the FDA has limited nonthera- peutic uses of a class of antibiotics called cephalosporins and banned all uses of another class called fluoroquino- lones, but it has taken a lawsuit to make the FDA address a proposal to ban these same uses in two other major antibiotic classes, tetracyclines and penicillins. The FDA currently insists that voluntary guidance to industry will solve the problem, citing lack of resources as an impedi- ment to withdrawing current drug approvals for nonthera- peutic uses. 20
Food & Water Watch recommends that: Congress should pass the Preservation of Antibiotics for Medical Treatment Act (PAMTA)/Prevention of Antibiotic Resistance Act (PARA), which would ban nontherapeutic uses of antibiotics in livestock, thereby avoiding the cumbersome drug-by-drug process currently required of the FDA to achieve the same goal. Congress should also pass the Delivering Antimicrobial Transparency in Animals Act (DATA)/Antimicrobial Data Collection Act, which would greatly improve available public data on antibiotic use in livestock. The FDA should assess the impact of its voluntary strategy and start the regulatory process now to withdraw drug approvals for injudicious uses within three years. The FDA should also strongly enforce the existing bans on certain uses of antibiotics. The FDA should address the Government Account- ability Ofices recommendations to improve data collection on the use of antibiotics and the develop- ment of antibiotic resistance. 21 NARMS must be broadened to allow the FDA to identify and respond rapidly to emerging resistance. Government agencies should collaborate to increase research on antibiotic resistance, including the mecha- nisms of resistance emergence, spread and remediation as well as alternative means of preventing illness in livestock. The U.S. Department of Agriculture (USDA) should provide training and technical assistance to livestock producers that are transitioning away from nonthera- peutic antibiotic use. The USDA should address contract stipulations that require livestock producers to use feed with antibiotics already added. 4 Food & Water Watch - foodandwaterwatch.org Introduction Antibiotics are critical tools in human medicine. Medical authorities are warning that these life-saving drugs are losing their efectiveness, and there are few replacement drugs in the pipeline. 22 Over time, bacteria have developed and continue to develop resistance to antibiotics. Far more antibiotics are given to livestock than to people, 23 and the livestock taking them are usually not sick. This practice, designed to prevent infection and promote faster growth, accelerates the development of antibiotic-resistant (AR) bacteria, threatening human health. 24 All species evolve in response to their environment, including bacteria. Bacteria reproduce rapidly, encouraging faster adaptation. Antibiotics kill bacteria, but if a few bacteria withstand the treatment, these bacteria will not only survive, but reproduce and pass on the traits that allow them to resist antibiotics. This process is more commonly known as survival of the fitest. In the case of bacteria and antibiotics, the fitest are those that survive exposure to antibiotics. Thus, any use of antibiotics to some degree leads to resistance. 25 Given this inevitable trend, it is important to maintain the efectiveness of antibiotics for as long as possible. Anti- biotics are a resource that should be used wisely. When your doctor prescribes antibiotics, you are told to take the whole prescription, even if you start to feel beter before you are done. The point is to ensure full treatment and to not leave bacteria behind that develop resistance to that particular drug, which would require even stronger antibi- otics to fight. 26
Similarly, public health campaigns work to educate people about not using antibiotics to treat problems caused by viruses, like a cold or the flu. Because antibiotics dont kill viruses, doctors dont want antibiotics to be used when they have no chance of working and will only increase the threat of resistance in bacteria in the body that happen to be exposed. 27 The livestock industry, however, uses antibi- otics much diferently than human medicine, in a way that contributes to the emergence of AR bacteria. How Industrial Agriculture Makes Antibiotic Resistance Worse Although livestock producers do use antibiotics to treat sick animals, the far more common usage is for nonthera- peutic purposes, including disease prevention and growth promotion. In the 1950s, researchers discovered that a small, constant dose of antibiotics helped animals grow faster. Livestock producers began using feed with antibiotics mixed in, both to promote faster growth and as an atempt to prevent infections in densely packed and unsanitary confined animal feeding operations (CAFOs). 29
These nontherapeutic doses are just a fraction of the amounts typically used to treat infections. Imagine taking a fraction of a regular dose of antibiotics every day even when you are healthy. Does that make sense given the advice we hear from doctors to take the a See infographic on pages 1011, which illustrates the processes described on pages 411. IMAGE COURTESY OF JANICE HANEY / U.S. CENTERS FOR DISEASE CONTROL AND PREVENTION Up to half of antibiotic use in humans and much of the antibiotic use in animals is unnecessary and inappropriate and makes everyone less safe. Stopping even some of the inappropriate and unnecessary use of antibiotics in people and animals would help greatly in slowing down the spread of resistant bacteria. U.S. CENTERS FOR DISEASE CONTROL AND PREVENTION Antlblotlc Peslstance l0l - How Antlblotlc Mlsuse on Pactory Parms Can Make ou Slck 5 full course of antibiotics and to take antibiotics only when needed to treat bacterial infections? Could you imagine including a low dose of antibiotics in your food, taken without even consulting a doctor? Thats essentially what happens in modern livestock production. And it creates conditions that promote the development of AR bacteria. Treatment of sick animals requires just a few animals to receive medicine for a short time and is less likely to contribute to resistance. Nontherapeutic uses mean that an entire herd or flock of animals receives small doses for an extended period. This practice kills bacteria that are susceptible to the drug, leaving the AR bacteria to survive and reproduce. The use of even one antibiotic in this manner can select for resistance to multiple classes of antibiotics because the genetic trait that allows bacteria to survive exposure to one antibiotic is ofen linked to traits allowing it to survive others. 30 Both in the United States and worldwide, agriculture uses vastly more antibiotics than human medicine,
and agricul- ture also uses drugs from every major class of antibiotics used in human medicine. 31 Estimates difer on precisely how many antibiotics are used in agriculture in general and for nontherapeutic purposes in particular. There is no centralized system for collecting such data, as the pharma- ceutical industry is not eager to share business information that it wants to keep confidential, 32 and even some live- stock producers may not know just how much antibiotics is in the pre-mixed feed that their contracts with meat companies require them to use. 33 The best estimates of antibiotic use come from the FDA. The FDA reported in 2011 that 80 percent of antibiotics in the United States are sold for agricultural purposes. 34 The FDA also reports that 74 percent of antibiotics used in live- stock are sold for use in feed, 16 percent for use in water and only 3 percent for use as injection. 35 Although the FDA cautions that the method of delivery does not correlate exactly with the purpose of use, 36 scientific evidence makes clear that puting medicine in feed makes dosing imprecise and not as efective for disease treatment. 37 In other words, the antibiotics used in feed and water are most likely used for nontherapeutic purposes. The mechanisms of AR and its spread are complicated. Many drugs used for nontherapeutic purposes are also used for disease treatment, both in veterinary and human medicine, and many AR genes are already widespread. 38
Evidence tying nontherapeutic antibiotic use in livestock and AR comes in diferent forms. A study comparing strains of Staphyloccocus in poultry from the 1970s and 2006 found much higher levels of resistance to eight antibiotics in the more recent strains. 39 In the United States, Spain and the Netherlands, researchers found eight- to sixteen-fold increases in AR Campylobacter within just three years of the introduction of the antibiotic class fluoroquinolone in poultry. 40
Although evidence tying nontherapeutic antibiotic use in livestock and AR has been largely circumstantial, a 2011 experiment ofered direct evidence. This highly controlled trial took piglets from the same liter and raised them in two groups under the same conditions, except that one group was given low doses of antibiotics in the feed. 41 Afer only two weeks, the treated piglets developed significantly higher levels of AR Escherichia coli. The AR E. coli in the treated piglets carried a higher variety of AR genes, including some that conferred resistance to drugs not used in the study. 42
Beyond Survival of the Fittest Nontherapeutic antibiotic use selects for AR bacteria, but the story doesnt end there. AR bacteria reproduce, becoming more numerous, but they also share genes with other bacteria in the environment and in people. Most AR genes in bacteria are located on mobile pieces of DNA known as plasmids. Bacteria can share plasmids, even across species. So, not only do AR bacteria become more common in response to selective pressure by repro- ducing more copies of themselves, but they also can share the resistance genes with neighboring bacteria. 43 These DNA swaps, known as horizontal gene transfer, allow both faster spread of AR genes and easier acquisition of resistance to multiple drugs by multiple types of bacteria. 44
Our findings underscore the potential public health risks of widespread antibiotic use in food animal production. Staph thrives in crowded and unsanitary conditions. Add antibiotics to that environment and youre going to create a public health problem. 28 DR. LANCE PRICE, DIRECTOR OF THE TRANSLATIONAL GENETICS RESEARCH INSTITUTES CENTER FOR FOOD MICROBIOLOGY AND ENVIRONMENTAL HEALTH 6 Food & Water Watch - foodandwaterwatch.org The gene sharing can occur among the bacteria in animal digestive tracts and then continue as bacteria from the animal spread via waste into the environment. 45 The resistance gene, in a way, takes on a life of its own, no longer tied to a specific species of bacteria but persisting in the larger microbial environment. The collective efect is known as reservoirs of resistance, in which resistance genes are widespread in the environment and can be acquired by bacteria through horizontal gene transfer. 46
Once AR genes have developed and spread, they are exceedingly hard to control. Researchers have gone so far as to call some bacteria highly promiscuous because of how easily they spread AR traits. 47 Eliminating nonthera- peutic uses of antibiotics removes the selective pressure that allows AR bacteria to thrive in livestock operations, but may not stop the spread of already existent AR bacteria. 48
Lets be clear: nontherapeutic antibiotics select for resis- tance genes in bacteria that would not become so preva- lent otherwise, and these AR bacteria make their way into the human population. It is not just that AR bacteria make people sick, although they do, but that through horizontal gene transfer, the resistance genes perpetuate themselves in good bacteria in humans as well.
These good bacteria form reservoirs of resistance genes that are available to bacterial pathogens. Even occasional transmission to humans can have a significant negative impact because of how resistance genes spread. 49 It is basically impossible to trace AR bacteria directly from a livestock operation to a sick person, 50 but scientific understanding of bacterial evolu- tion demonstrates that practices driving resistance in livestock have far-reaching efects by increasing the overall reservoir of resistance. Studies of AR bacterial DNA over time indicate that livestock treated with nontherapeutic doses of antibiotics are the likely origin for some AR bacteria in humans. E. coli that is resistant to ciprofloxacin, a drug from the class fluoroquinolones once used nontherapeutically in poultry, is very similar in humans and chickens and more commonly found in chicken than in other meats in which the drug is not used. This evidence points to poultry as the source of the AR bacteria, not medical use of the drugs in humans. 51 Testing of E. coli from urinary tract infections in people across multiple states reveals it to be very similar to AR E. coli in livestock, suggesting that the source was common in food. 52
Genetic analysis of methicillin-resistant Staphylococcus aureus (MRSA) indicates that the strain that is associated with livestock originated in humans, transferred to pigs where it acquired resistance to tetracycline and methicillin, and then jumped back to humans. 53 This research required the participation of 20 institutes studying 89 genomes from humans and animals over 19 countries, a complicated and painstaking efort. 54 Otherwise-healthy people can carry AR bacteria for years without realizing it, and that same AR bacteria can pose grave danger as an infection. 55 Whether it is through a persistent foodborne illness, urinary tract infection or infection in a hospital, AR bacteria make themselves known in patients whose illnesses just do not clear up, leading to round afer round of escalating treatments. Antibiotic resistance has become such a serious problem that there are few or no treatment options in some cases, 56
and pharmaceutical companies are not producing new treatments fast enough to keep up with the need. 57 In the face of such a complex problem, much more efort must be directed at trying to slow the development of resistance at its source. How Antibiotic-Resistant Bacteria Spread Reservoirs of AR bacteria persist in livestock and in the environment around farms. Illness-causing bacteria are relatively common in meat. Consumers encounter these bacteria while handling raw meat and eating it under- cooked. Thats why the government reminds consumers to cook meat to certain temperatures and educates about PHOTO COURTESY OF THE U.S. FOOD AND DRUG ADMINISTRATION Antlblotlc Peslstance l0l - How Antlblotlc Mlsuse on Pactory Parms Can Make ou Slck 7 cross-contamination. 61 Tests of retail meat samples have found antibiotic resistance among the bacteria respon- sible for foodborne illnesses. DNA tests of AR bacteria from sick people and livestock reveal the likelihood of an agricultural source. AR bacteria can spread from livestock not just to humans but to rodents and flies as well. The bacteria fester in waste lagoons, and that waste is then ofen used as fertilizer, potentially contaminating soil, waterways and crops. From Meat to Consumers Multiple studies have found AR bacteria in many types of retail meat and fish products. 62 In other words, when you buy meat at the grocery store, theres a decent chance that it has AR bacteria on it. Whether the bacteria are AR or not, handling raw meat and undercooking can lead to foodborne illness. 63 The FDA stated in 2012, In regard to antimicro- bial drug use in animals, the Agency considers the most significant risk to the public health associated with antimi- crobial resistance to be human exposure to food containing antimicrobial-resistant bacteria resulting from the exposure of food-producing animals to antimicrobials. 64
In 1996, the FDA, CDC and USDA partnered to create the National Antimicrobial Resistance Monitoring System (NARMS). 65 Among other functions, NARMS collects samples of bacteria from chicken breasts, ground turkey, ground beef and pork chops and measures the presence of the drug-susceptible and AR foodborne pathogens Campy- lobacter, Salmonella, Enterococcus and E. coli. 66 Because of the variety of antibiotic classes and species of bacteria, it can be hard to gather an overall picture of the AR problem from the sampling data. Food & Water Watch has analyzed the 2011 NARMS data to estimate how widespread AR bacteria were in the retail meat samples collected. AR Salmonella was present in 9 percent of chicken breast samples and 10 percent of ground turkey samples. The presence of AR E. coli in the samples collected varied widely: 66 percent in ground turkey, 53 percent in chicken breasts, 15 percent in pork chops and 9 percent in ground beef. 67
The vast majority of Enterococcus found in each type of meat contained at least one AR trait. Enterococcus was also highly prevalent in all types of meat tested, leading to a high overall risk of encountering AR Enterococcus. 68 The prevalence of AR traits among Salmonella samples ranged from 44 percent in ground beef to approximately three- quarters in ground turkey, chicken breasts and pork chops. The presence of AR traits in E. coli samples varied widely: 87 percent in ground turkey, 75 percent in chicken breasts, 48 percent in pork chops and 21 percent in ground beef. 69 10% 8% 6% 4% 2% Figure 1. AR Salmonella in NARMS Retail Meat Samples SOURCE FIG. 1: Food & Water Watch analysis of FDA NARMS. 2011 Retail Meat Report. 2013. SOURCE FIG. 2: Food & Water Watch analysis of FDA NARMS. 2010 Retail Meat Report. 2012. Ground Turkey Chicken Breasts 70% 60% 50% 40% 30% 20% 10% Figure 2. AR E. Coli in NARMS Retail Meat Samples Ground Turkey Chicken Breasts Pork Chops Ground Beef 8 Food & Water Watch - foodandwaterwatch.org Among the reports other key findings, nearly half of the Salmonella samples from chicken breasts and half of those from ground turkey were resistant to three or more classes of antibiotics. Salmonella resistance to third-generation cephalosporins has shown a decade-long increase in retail poultry. Between 2002 and 2011, this type of resistance more than tripled from 10 to 33.5 percent in samples from chicken breasts and nearly tripled from 8.1 to 22.4 percent in ground turkey. 70 This increase led the FDA to ban certain nontherapeutic uses of cephalosporins. Among the Entero- coccus samples, there was no resistance to vancomycin and linezolid, two drugs used in human medicine but not agriculture, 71 but the vast majority of Enterococcus samples were resistant to other antimicrobial drugs. 72 The NARMS surveillance system does not include any forms of Staphylococcus, although it has been found in the food supply. MRSA was once considered endemic only to hospitals, but one strain of MRSA, ST398, has been found in food production animals, in people who work with those animals and in retail meat. 73 A study of retail meats in five U.S. cities found S. aureus in just under half of the samples. Nearly all the S. aureus found was resistant to one antibiotic, and half of the S. aureus found was multi-drug resistant. 74 The researchers recommended that multidrug-resistant S. aureus should be added to the list of antimicrobial-resistant pathogens that routinely contami- nate our food supply. 75 Several studies have linked AR bacteria in retail meats to livestock sources. In a study of AR E. coli from diferent types of meat across a wide geographic range, the antibiotic-susceptible and AR E. coli from each type of meat resembled other samples from the same species and varied greatly with samples from other species. 76 This finding indicates that livestock are the likely source of the bacteria, with the AR bacteria developing from drug- susceptible E. coli under selection pressure within each species of livestock. 77
A study of ground meats in three grocery stores from three diferent chains in the Washington, D.C., area found that 20 percent of the samples contained Salmonella. Eighty- four percent of the bacteria were resistant to one anti- biotic, and just over half were resistant to three or more antibiotics. 78 The findings included a particularly virulent strain that has been the culprit of previous outbreaks of foodborne illness. 79 The commonality of AR bacteria in all the types of ground meats indicates the presence of a reservoir that can afect people. 80
Not all livestock are raised using nontherapeutic antibi- otics. U.S. organic standards require that livestock not be treated with antibiotics, 81 and some companies market meat raised without antibiotics. 82 Because AR bacteria are so widespread in the environment, it is possible for livestock raised without antibiotics to carry AR bacteria. Studies have found that Enterococcus faecium and Campy- lobacter were less likely to be antibiotic resistant in organic chicken and chicken raised without antibiotics compared to conventional chicken. 83
A study of retail meats in five U.S. cities found S. aureus in just under half of the samples. Nearly all the S. aureus found was resistant to one antibiotic; half of the S. aureus found was multi-drug resistant. How Do I Find Antibiotic-Free Meat? 1. Buy organic. Organic livestock in the United States must be raised without antibiotics. 58 2. Look for a label stating that the meat has been raised without antibiotics. The USDA allows companies to use the label if they provide documentation of their practices. 59 Labels that also say "USDA Process verifed" or that list a certifcation from another independent body ofer another level of assurance. A "natural" label claim does not necessarily mean that antibiotics were not used. 60 3. Buy directly from the farmer, which allows you to ask the farmer directly about his or her practices. Buying meat raised without antibiotics is no guarantee that the meat will be free of AR bacteria, and consumers should still follow good food safety practices when preparing any meat product. But making the efort to buy products produced without antibiotics helps prevent the further emergence of AR bacteria by supporting producers who do not use nontherapeutic antibiotics. Antlblotlc Peslstance l0l - How Antlblotlc Mlsuse on Pactory Parms Can Make ou Slck 9 Studies of MRSA have found mixed results, with some studies finding a diference between MRSA levels in conven- tional meat and meat raised without antibiotics and one study finding no diference. That study, however, cited the possibility that processing equipment or workers carrying MRSA contaminated the meat raised without antibiotics. 84
It is clear, however, that raising livestock without antibiotics does not add to the reservoir of resistance. Antibiotic-Resistant Foodborne Illness The CDC estimates that at least 2 million Americans each year experience AR infections, leading to at least 23,000 deaths. 85 Approximately 22 percent of those AR infections originate from foodborne pathogens. 86 Foodborne illnesses from AR bacteria have been tracked back as far as the 1970s and 1980s. There were 38 known outbreaks of AR foodborne illnesses between 1973 and 2011, resulting in more than 20,000 illnesses, over 3,000 hospitalizations and nearly 30 deaths. The estimate is undoubtedly low, however, as health oficials do not always test for AR, and the CDC does not track all outbreaks of AR pathogens. 87 In 2011, the United States experienced two major food recalls due to illness outbreaks from AR bacteria. In the face of an illness outbreak caused by AR Salmonella, Cargill voluntarily recalled 36 million pounds of ground turkey in August 2011, and an additional 185,000 pounds the next month. 88 This recall, the third largest meat recall in the USDAs records, represented several months worth of production from one plant in Arkansas. It took several months for the cluster of illnesses to be traced back to the plant. 89 In total, 136 people across 34 states were infected, yielding 37 hospitalizations and one death. 90 A dispropor- tionate number of people infected were hospitalized due to the bacterias antibiotic resistance. 91 Although Salmonella can run its course without treatment, it also can cause severe complications, especially in the very young, elderly and immune-compromised. It is those vulnerable to more complicated infections that particularly need efective treatment options. 92
The second illness outbreak involved another AR Salmonella strain, this time tied to ground beef from the Hannaford grocery store chain in New England. This outbreak was smaller, with 20 infections and eight hospitalizations reported. 93 The strain causing the outbreak was resistant to multiple classes of drugs, including cephalosporins, the drugs of choice to treat Salmonella infections in children. 94
The nature of our concentrated food system is such that meat is aggregated from many sources through a tight processing stream before distribution to retailers and consumers across the country, ofering more points for potential cross-contamination. 95 In the Hannaford outbreak, limited records kept by the retailer prevented the USDA from tracing the contamination back to the supplier, although Hannaford oficials claim that they followed industry standards. 96 Clearly, strong food safety practices are particularly important to prevent AR bacteria outbreaks, which cause more serious illnesses. But it is also critical to prevent the emergence and spread of AR bacteria among livestock to minimize AR bacterias entry into the food supply. From Livestock to Farmers and the Environment AR bacteria in livestock do not just remain there, but spread to farmers, farmworkers and rural residents. 97 As early as 1976, researchers found that AR bacteria spread rapidly in the intestines of chickens raised using nonthera- peutic antibiotics. Farmers on the same poultry operations developed higher levels of AR bacteria in their intestinal tracts as well, compared to their neighbors. 98 Multiple studies have identified the similar strains of AR bacteria in farmers and their livestock. 99 This trend has continued as new strains of AR bacteria threaten the human population. Strains of MRSA, for instance, have now been found not only in pigs but also in the people that raise them. 100
One strain of MRSA has been found in both pigs and the people that raise them, but not in neighbors who do not raise pigs. 101 Researchers have found strong evidence that this strain of MRSA originated in humans, migrated to pigs where it acquired antibiotic resistance, and now is infecting humans again. 102 Another study has found farmworkers and pigs carrying the same strains of MRSA on conventional pig farms, but not on farms that do not use antibiotics in raising pigs. 103
Antibiotic Resistance 101 - How Antibiotic Misuse on Factory Farms Can Make You Sick 11 10 Food & Water Watch - foodandwaterwatch.org 6 AR bacterial infections have become increasingly common. Doctors are concerned that some antibiotics no longer work to treat sick people. AR bacteria in livestock can spread to farmers, farmworkers, meat plant workers and the general population. 4 5 Consumers encounter AR bacteria while handling raw meat and eating undercooked meat. 3 Waste is stored in lagoons and used as fertilizer. AR bacteria in the waste continue to reproduce and share genes with other bacteria in soil, streams, ponds and groundwater, creating reservoirs of resistance. Factory farms use feed thats pre-mixed with antibiotics to promote faster animal growth and prevent infections. 1 The digestive tract contains many bacteria. Low doses of antibiotics kill some bacteria. AR bacteria survive and reproduce, passing along the resistance genes. AR bacteria also share resistance genes with other bacteria through horizontal gene transfer. antibiotics susceptible bacteria dead susceptible bacteria resistant bacteria Giving low doses of antibiotics to groups of animals over extended time periods fuels the development of antibiotic-resistant (AR) bacteria. 2 HOW ANTIBIOTIC MISUSE ON FACTORY FARMS CAN MAKE YOU SICK 12 Food & Water Watch - foodandwaterwatch.org A study of poultry workers found the presence of a strain of E. coli resistant to gentamicin, an antibiotic commonly used in chickens, to be 32 times higher in the workers compared to other members of the community. Half of the poultry workers carried the AR strain, compared to 3 percent of the neighboring population. 104 Researchers have even found an increased likelihood of rural residents experiencing MRSA skin infections if they live near fields treated with swine manure. 105 In large livestock operations, manure is collected in lagoons. 106 The fecal bacteria also collect in these lagoons and then spread into the environment when the waste is applied to land as fertilizer. Fecal bacteria can survive for weeks or even months outside the animal. 107 With that amount of time to live and reproduce, it is not surprising that AR bacteria spread into the environment. Most of the antibiotics fed to livestock are also excreted in waste, adding an additional low-level exposure to bacteria in the lagoon and in the environment, perpetuating the further development of AR bacteria. 108 Several studies have found DNA matches between AR bacteria in the soil and water and in manure lagoons. 109
Manure storage itself does not constitute a form of treat- ment, and treatment is necessary to reduce bacteria. Unlike chemical pollutants, bacteria reproduce. Thus, treat- ment that only partially eliminates bacterial contamination can be rendered inefective when the bacteria simply grow back. Neither lagoon storage nor anaerobic digestion, a process used to convert livestock waste into energy, significantly decreases the presence of AR genes. 110 Poultry liter has also been found to harbor multiple-drug-resistant E. coli and antibiotic residues. 111
Most livestock waste stored in lagoons is applied to nearby fields as fertilizer, introducing AR bacteria into the local environment. 112 The AR bacteria not only spread, but share genes with naturally occurring bacteria in local fields, streams, ponds and even groundwater. These bacteria are adapted to their environment, just as the fecal bacteria are adapted to living in the digestive tracts of livestock, and may carry on reproducing with these new traits. 113 Thus, AR bacteria from livestock contribute to a reservoir of antibiotic resistance in rural environments. Other opportunities for AR bacteria to spread include wind, transporting livestock, and even flies and other animals. Researchers have found higher concentrations of AR bacteria downwind of hog facilities a few weeks afer hogs received a dose of nontherapeutic antibiotics. 114 Even vehicles carrying livestock leave bacteria, AR and other- wise, in the air behind them. 115 Flies atracted to livestock waste also pick up and may disperse AR bacteria. 116
Tackling Antibiotic Resistance Animals can be raised successfully without nontherapeutic antibiotic use. The European Union (EU) has banned nontherapeutic use of antibiotics for growth promotion. 117
U.S. organic standards require that livestock not be admin- istered antibiotics. 118 Companies such as Chipotle, Niman Ranch and Applegate Farms have made meat raised without antibiotics much more visible in grocery stores and restaurants. 119
Some antibiotics no longer work as growth promoters or yield a result so slight that the additional profit does not cover the cost of the antibiotics, yielding a net loss. 120 Alter- natives to nontherapeutic antibiotic use include vaccina- tions, when available.
Research continues on new vaccines and probiotics, the use of less harmful bacteria to compete with AR bacteria in the digestive tract. 121
Raising livestock without antibiotics requires changes in herd management. Animals crowded into CAFOs may face increased stress and poor hygiene, which facilitates the By far the best way to prevent the spread of AR bacteria is to prevent their development in the first place. It is also more efective to take action when AR bacteria first emerge, rather than wait until the trait becomes widespread and threatens animal or human health. Antlblotlc Peslstance l0l - How Antlblotlc Mlsuse on Pactory Parms Can Make ou Slck 13 spread of pathogens and slows animal growth. In other words, minimizing livestock stress and maximizing hygiene can provide growth-promotion and infection-prevention benefits without the nontherapeutic use of antibiotics. 122 Ending Nontherapeutic Use of Antibiotics By far the best way to prevent the spread of AR bacteria is to prevent their development in the first place. It is also more efective to take action when AR bacteria first emerge, rather than wait until the trait becomes wide- spread and threatens animal or human health. 123 Once AR traits spread via horizontal gene transfer throughout the ecosystem, the AR trait may be virtually impossible to eradicate and may persist for many years. 124 Eliminating nontherapeutic uses of antibiotics, however, can make a diference in reducing the prevalence of AR bacteria. 125
The EU has taken a diferent path than the United States on antibiotics used for growth promotion in livestock. The EU banned the use of medically important antibiotics for growth promotion and established an EU-wide AR monitoring system in 1999, followed by a phase-out of all antibiotics used for growth promotion by 2006. 126 Following these decisions, prevalence of AR bacteria has declined in livestock, meat and people in the EU. 127
In 1986, Sweden became the first EU country to ban the use of antibiotics as growth promoters. Swedens livestock producers faced increases in livestock disease immediately afer the ban, but the government also devoted money to research and extension services for farmers, and its data showed no decrease in production due to the ban. 128
Denmark, the next country to implement such a ban, experienced a brief spike in therapeutic antibiotic use in swine. 129 Between 1992 and 2008, pig farmers in Denmark increased production by nearly 40 percent, while their use of antibiotics per pig dropped by 50 percent. 130
In the 1990s, vancomycin-resistant infections were found increasingly in hospital patients in the EU. The finding of the same AR bacteria in meat and manure from farms using growth promoters led to broader restrictions across the EU, instead of just in individual countries. 131 The prevalence of bacteria resistant to vancomycin in people fell once the EU eliminated the drugs use as a livestock growth promoter. The United States never approved vancomycin for nontherapeutic uses in livestock, and, while resistance to the drugs does exist in Enterococcus infections in U.S. hospitals, the problem has never been as great as the point reached in the EU. 132 But the EUs experi- ence with vancomycin ofers important lessons about the consequences of nontherapeutic use of antibiotics in livestock and outcomes when such use ends. How Antibiotics Are Regulated The Food and Drug Administration Federal government recognition of antibiotic resistance goes back decades, but action to address the problem has been intermitent and slow.A 1970 FDA Task Force on the use of antibiotics in animal feed recommended limiting those uses for medically important antibiotics. In 1977, the FDA proposed withdrawing approval for nontherapeutic uses of penicillins and multiple tetracyclines, as both of those drugs play an important role in human medicine. Congress ordered studies before the withdrawal could be considered, and the National Academies of Science concluded that the evidence of the need for drug withdrawal was very limited. 133
Further reports from government agencies and the World Health Organization drew atention to evidence linking nontherapeutic antibiotic use in livestock and antibiotic resistance. These reports ofen called for further data collection and consideration of human health risks when approving veterinary uses of livestock. 134 In 2004, the Government Accountability Ofice (GAO), the investigative oversight agency that works for Congress, PHOTO COURTESY OF THE U.S. FOOD AND DRUG ADMINISTRATION 14 Food & Water Watch - foodandwaterwatch.org found much amiss in the FDAs and USDAs handling of antibiotic resistance. The FDA tracks antibiotic use data for livestock, but the GAO criticized the system for lacking details including the species receiving the drugs and the purpose for which the drugs were given. Without such specificity, the FDA not only cannot say how much anti- biotics are used for growth promotion, disease prevention or treatment, but cannot measure the efectiveness of its policies designed to curb antibiotic resistance. 135 The GAO also found that the sampling of retail meat to examine the prevalence of AR bacteria is not representative of antibi- otic resistance in food animals and retail meat throughout the United States. 136 The deficiencies prevent examination of trends in antibiotic resistance relative to antibiotic use. 137 The FDA acknowledges that theres a problem, but what has it done to rein it in? On the one hand, the FDA has limited nontherapeutic uses of cephalosporins and banned all uses of fluoroquinolones, but it took a lawsuit by public interest groups to make the FDA address a proposal to ban these same uses in two other major classes, tetracyclines and penicillins. The FDA for years has insisted that industry voluntary eforts will solve the problem, citing lack of resources as an impediment to creating regulations. 138 Tetracyclines and Penicillins In 1977, the FDA proposed withdrawing approval for nontherapeutic uses of penicillins and tetracyclines, as both of those drugs play an important role in human medicine. 139 For 34 years, the FDA kept the proposal open; all the while these drugs, which are commonly used to treat human infections, were added to livestock feed and water, ofen without prescriptions. 140
In 1999, five advocacy organizations 141 filed a citizen petition requesting that the FDA follow through on its proposal. In 2005, an overlapping set of organizations 142 made a similar request, asking for the withdrawal of herdwide and flock- wide uses of several more classes of antibiotics. 143 Having received no response to either petition, the coalition 144
filed suit against the FDA in May 2011 to force the FDA to respond to the 1999 and 2005 citizen petitions. 145 The FDAs eventual response lef much to be desired. Despite acknowledging shared concern, the FDA denied the petitions, citing the dificulty of the formal process of withdrawing a drug approval. 146 In December 2011, the FDA withdrew the 1977 proposal to withdraw approval of nontherapeutic uses of penicillins and tetracyclines altogether. Among the reasons for its decision, the FDA cited other ongoing regulatory options and the focus on voluntary initiatives. The FDA stated that the withdrawal should not be inter- preted as a sign that FDA no longer has safety concerns or that FDA will not consider re-proposing withdrawal proceedings in the future, if necessary. 147 Meanwhile, the most recent NARMS report, covering data from 2011, indicated that resistance to tetracyclines and penicillins is quite common across diferent types of bacteria in retail meats. 148 The plaintif organizations, however, disagreed with that assessment, as did a federal court. 149 In the spring of 2012, federal district court Judge Theodore Katz issued two rulings indicating that the FDAs voluntary approach to regulating nontherapeutic antibiotic use is insuficient. The first ruling compels the FDA to revisit the withdrawal process begun in 1977 for penicillins and tetra- cyclines. According to Judge Katz, The scientific evidence of the risks to human health from the widespread use of antibiotics in livestock has grown, and there is no evidence that the FDA has changed its position that such uses are not shown to be safe. 150
The judges ruling indicates that the FDA should have triggered the withdrawal proceedings to move ahead as soon as the FDA ruled that the practices were no longer shown to be safe. 151 The drug manufacturers may request a hearing to demonstrate that the drugs are safe to use nontherapeutically in livestock. The companies bear the burden of proof at the hearing, and if they cannot prove that the uses are safe, the FDA must formally withdraw its approval of those uses. 152 The FDA appealed this ruling. 153 Judge Katzs second ruling prescribes a broader re-evalua- tion of nontherapeutic uses of antibiotics, calling the FDAs decision to deny the 1999 and 2005 citizen petitions on the basis that they were too time and resource-intensive to be arbitrary and capricious. 154 Antlblotlc Peslstance l0l - How Antlblotlc Mlsuse on Pactory Parms Can Make ou Slck 15 Fluoroquinolones The FDA licensed a new class of antibiotics, fluoroquino- lones, for nontherapeutic uses in the mid-1990s. Prior to the approval, NARMS found no resistance to these drugs in Campylobacter, a common type of bacteria in poultry. By 1999, however, nearly 20 percent of Campylobacter were resistant to these drugs. Scientific modeling esti- mated that more than 150,000 people were infected with fluoroquinolone-resistant Campylobacter from poultry consumption in 1999 alone and that 1.2 billion pounds of boneless chicken were contaminated with this variety of AR bacteria. In the face of such rapid development of resistance, the FDA proposed withdrawal of the approval of all uses of fluoroquinolones in chicken in 2000. The pharmaceutical industry responded with legal action, dragging the final action out until 2005 while resistance continued to increase. 155
The struggle to implement this withdrawal led the FDA to change its approach to new applications to use antibiotics important in human medicine in livestock. 156 In 2003, the FDA released guidance to pharmaceutical companies on how to assess the risk of a new drug causing resistance problems. Depending on the findings, the FDA may require that the new drug may, for instance, be used for treatment only under a veterinarians care, or the agency may simply not approve the drug. This risk assessment is not required, however, but is just one of a few options that companies can use to evaluate the drugs safety. 157 But what about the many drugs approved before 2003? The FDA, citing cost concerns, has not conducted post-approval evaluations and has instead focused on voluntary approaches to change antibiotic use. 158 NARMS tracks two types of Campylobacter in retail chicken breasts. Resistance to ciprofloxacin, a fluoroqui- nolone used commonly in human medicine, among C. coli in retail chicken breasts rose from 10 percent in 2002 to nearly 30 percent in 2005. Since the ban, resistance to ciprofloxacin dropped to 18.1 percent in 2011. 159 Resistance to ciprofloxacin in C. jejuni has increased from 15 percent in 2005 to 22 percent in 2011. 160 Meanwhile, a 2012 study found fluoroquinolones in feather meal, a byproduct of chicken processing made from feathers, suggesting that producers and feed companies may not all be following the ban. 161 Cephalosporins In April 2012, the FDA finalized a ban on specific nonthera- peutic uses of cephalosporins. 162 Cephalosporins play an important role in treating foodborne illnesses in humans, especially children, as well as pneumonia and skin and sof tissue infections. 163 The 2011 Hannaford ground beef recall involved cephalosporin-resistant bacteria. 164 The FDA had issued a similar order in 2008, but revoked it afer receiving a negative reaction, including threats of legal action, from the livestock and pharmaceutical industries. 165 The 2012 ban covers a narrower range of uses, leaving exceptions for older cephalosporins and those used with veterinary prescriptions. 166 The ban prohibits most extralabel uses in major food animals, meaning that the drugs cannot be used at an unapproved dose, frequency or duration and cannot be used for disease prevention. 167
In its decision, the FDA reported increased antibiotic resistance to cefiofur, one common cephalosporin. Government monitoring in 2009 found cefiofur-resistant Salmonella in 14.5 percent of samples from catle, 4.2 percent from swine, 12.7 percent from chickens and 12.4 percent from turkeys. In 1997, neither catle nor swine had been found to carry this strain of AR bacteria, and it was present in only 0.5 percent of chicken samples and 3.7 percent of turkey samples. 168
Examining specific strains of Salmonella over the same time period, cefiofur resistance in Salmonella Typhimurium increased from 0 to 33 percent in chickens and from 3 to 28 percent in catle, and cefiofur resis- tance in Salmonella Heidelberg rose from 0 to 18 percent in chicken and from 0 to 33 percent in turkey. 169 Other researchers have noted that broad-spectrum cephalosporin use in livestock promotes the development of MRSA. 170
Voluntary Guidance for Judicious Use In 2012 and 2013, the FDA released two pieces of formal guidance to industry, Guidance 209 and Guidance 213, that address the judicious use of antibiotics in livestock. 171 The FDA defines judicious use of antibiotics as using an anti- microbial drug appropriately and only when necessary. 172
NARMS tracks two types of Campylobacter in retail chicken breasts. Resistance to ciprofloxacin, a fluoroquinolone used commonly in human medicine, among C. coli in retail chicken breasts rose from 10 percent in 2002 to nearly 30 percent in 2005. Since the ban, resistance to ciprofloxacin dropped to 18.1 percent in 2011. 16 Food & Water Watch - foodandwaterwatch.org These documents represent a very limited approach to reducing antibiotic use in livestock. Guidance 209 recommends limiting medically important antimicrobial drugs to uses in food-producing animals that are considered necessary for assuring animal health, a broad definition that requires clarification. 173 Guidance 213 advises pharmaceutical companies on how to apply Guidance 209 to new drug approval applications for antibiotics used in feed or water. 174 The FDA recommends that medically important antibiotics not be used for growth promotion and that antibiotics used in livestock feed require veterinary oversight rather than being sold over-the-counter. 175
For those changes to occur and to be binding, pharmaceu- tical companies will have to resubmit the drug applications to change the allowed uses listed on the drug label. 176
Draf changes to another document, the Veterinary Feed Directive (VFD), instruct veterinarians on the type of oversight required for antibiotics that are no longer labeled for over-the-counter uses. 177 If successful, this efort would yield a significant change in antibiotic use, as currently most antibiotics in feed have been approved for multiple purposes including over-the-counter sales for growth promotion. 178 Using medically important antibiotics for growth promotion is perhaps the most injudicious use of antibiotics in livestock, as is using antibiotics without veterinary oversight. The FDA has declared that it will re-evaluate the situation three years afer the date finalizing Guidance 213 and then determine if the voluntary response has been suficient. At that point, it will determine whether to take further regulatory action. 179 Two major animal pharmaceutical companies, Zoetis and Elanco, have announced their intent to follow the voluntary guidance, although full compliance remains to be seen. 180
The voluntary approach leaves open two crucial loopholes. First, the FDA still approves of the use of antibiotics for disease prevention purposes, even though those practices mirror how antibiotics are used for growth promotion. 181
While one form of nontherapeutic use would be discour- aged, the other would remain unimpeded, other than the requirement for veterinary oversight. Additionally, the guidance does not address the use of non-medically important antibiotics for growth promotion, a practice that also promotes the spread of resistance genes. The bans on nontherapeutic uses of fluoroquinolones and cephalosporins indicate that the FDA can put forth manda- tory regulations on this issue. The FDA should use every tool in its regulatory toolbox to reduce nontherapeutic uses of antibiotics in livestock, and not rely on voluntary industry measures. Congress Congress also could act to reduce nontherapeutic uses of antibiotics in livestock. Since 2003, several members of Congress have introduced legislation to limit the use of medically important antibiotics in healthy livestock: the Preservation of Antibiotics for Medical Treatment Act (PAMTA). As a microbiologist, sponsor Representative Louise Slaughter (D-NY) has relevant expertise on this issue. She has stated: If an animal is sick, then by all means we should make them well, but the routine use of antibiotics on healthy animals in order to promote growth is dangerous. It would be like a mother giving their son or daughter antibiotics every morning in their Cheerios. Were wasting our precious antibiotics. 184
Who Supports PAMTA? 182 More than 300 agricultural, consumer, health and environmental organizations, including: American Academy of Pediatrics American Medical Association American Nurses Association American Public Health Association Infectious Disease Society of America Keep Antibiotics Working Coalition National Catholic Rural Life Conference National Organic Coalition National Sustainable Agriculture Coalition Union of Concerned Scientists Who Opposes PAMTA? 183 American Farm Bureau Federation American Feed Industry Association American Meat Institute American Veterinary Medical Association National Cattlemens Beef Association National Chicken Council National Milk Producers Federation National Pork Producers Council National Turkey Federation United Egg Producers Antlblotlc Peslstance l0l - How Antlblotlc Mlsuse on Pactory Parms Can Make ou Slck 17 As of the end of 2013, PAMTA, now also known as the Prevention of Antibiotic Resistance Act (PARA), had not received a commitee hearing or vote. More than 300 organizations have expressed support for the bill. 185 Over 30 organizations have lobbied on PAMTA over the years, with organizations representing the meat, livestock and pharmaceutical industries all voicing opposition. 186
Recommendations The development and spread of AR bacteria are compli- cated processes, and eforts to reverse these processes are equally dificult. But one thing is abundantly clear: the best way to address the issue of antibiotic resistance is to prevent the development of AR bacteria in the first place, which means ending the nontherapeutic use of antibiotics in livestock. The FDA continues to pursue voluntary initiatives with an industry that has resisted atempts to regulate nonthera- peutic antibiotic use for decades. Relying on industry eforts is simply not enough to address this problem. Food & Water Watch recommends that: Congress should pass the Preservation of Antibiotics for Medical Treatment Act (PAMTA)/Prevention of Antibiotic Resistance Act (PARA), which would ban nontherapeutic uses of antibiotics in livestock, thereby avoiding the cumbersome drug-by-drug process currently required of the FDA to achieve the same goal. Congress should also pass the Delivering Antimicrobial Transparency in Animals Act (DATA)/Antimicrobial Data Collection Act, which would greatly improve available public data on antibiotic use in livestock. The FDA should assess the impact of its voluntary strategy and start the regulatory process now to withdraw drug approvals for injudicious uses within three years. The FDA should also strongly enforce the existing bans on certain uses of antibiotics. The FDA should address the GAOs recommendations to improve data collection on the use of antibiotics and the development of antibiotic resistance. 187 NARMS must be broadened to allow the FDA to identify and respond rapidly to emerging resistance. Government agencies should collaborate to increase research on antibiotic resistance, including the mech- anisms of resistance emergence, spread and remedia- tion as well as alternative means of preventing illness in livestock. The USDA should provide training and technical assistance to livestock producers that are transi- tioning away from nontherapeutic antibiotic use. The USDA should address contract stipulations that require livestock producers to use feed with antibi- otics already added. Endnotes 1 Boucher, Helen et al. Bad Bugs, No Drugs: No ESKAPE! An Update from the lnfecuous ulseases SocleLy of Amerlca." cllolcol lofecuoos ulseoses. Vol. 48, lss. 1. 2009 aL 1. 2 Sllbergeld, Craham eL al. lndusLrlal food anlmal producuon, anumlcroblal resls- Lance, and human healLh." Aooool kevlew of lobllc neoltb. vol. 29. 2008 aL 1S1. 3 lblJ. aL 1S1, MelsLer, karen. Supervlsory Congresslonal Aalrs SpeclallsL. u.S. ueparLmenL of PealLh and Puman Servlces, u.S. lood and urug AdmlnlsLra- uon (luA). Leuer Lo 8epresenLauve Loulse SlaughLer. Aprll 19, 2011. 4 Sllbergeld eL al. 2008 aL 1S1. S MelsLer. 2011, Cmce of Congresswoman Loulse SlaughLer. [ress 8elease]. luA 8eporLs Lo SlaughLer: Cver 70 ercenL of Anubloucs AdmlnlsLered Lo Anlmals ln leed." May 13, 2011. 6 Sllbergeld eL al. 2008 aL 1S2. 7 !ohnson, !ames. unlverslLy of MlnnesoLa School of Medlclne. 1esumony on 1he Sclence ls Clear: lnapproprlaLe use of Anubloucs ln Anlmal AgrlculLure 1hreaLens ubllc PealLh." Congresslonal Pearlng sponsored by CenLer for Sclence ln Lhe ubllc lnLeresL and !ohns Popklns unlverslLy CenLer for a Llvable luLure. March 8, 2012. 8 CenLers for ulsease ConLrol and revenuon (CuC). Anublouc 8eslsLance ln Lhe unlLed SLaLes, 2013." 2013 aL 6. 9 lood & WaLer WaLch analysls of CuC, 2013, Murphy, !oan. CuC calls for phase ouL for growLh promoLers." looJ cbemlcol News. SepLember 17, 2013. 10 Alllance for Lhe rudenL use of Anubloucs and Cook CounLy (SLroger) PosplLal. [ress 8elease]. Anublouc-8eslsLanL lnfecuons CosL Lhe u.S. PealLhcare Sys- Lem ln Lxcess of $20 8llllon Annually." CcLober 19, 2009. 18 Food & Water Watch - foodandwaterwatch.org 11 8oucher eL al. 2009 aL 1. 12 Marshall, 8onnle, and SLuarL Levy. lood anlmals and anumlcroblals: lmpacLs on human healLh." cllolcol Mlctobloloqy kevlews. vol. 24, lss. 4. 2011 aL 718. 13 Amerlcan ubllc PealLh Assoclauon. ollcy SLaLemenL: Pelplng reserve Anublouc Lecuveness by Sumulaung uemand for MeaLs roduced WlLhouL Lxcesslve Anubloucs." ollcy number 2004-13. november 9, 2004. Avallable aL hup://www.apha.org/advocacy/pollcy/pollcysearch/defaulL.hLm?ld=1299. Accessed March S, 2012. 14 Amerlcan Medlcal Assoclauon Pouse of uelegaLes. 8eporL of 8eference Com- mluee L." 2008 aL 21. 1S 8radley, !ohn. Amerlcan Academy of edlaLrlcs. 1esumony on Anublouc 8esls- Lance and Lhe lmpacL on Lhe PealLh of Chlldren: 1he need for More Safe and Lecuve Anubloucs and 8euer Anumlcroblal SLewardshlp." Subcommluee on PealLh. Commluee on Lnergy and Commerce. u.S. Pouse of 8epresenLauves. !une 9, 2010. 16 lnfecuous ulsease SocleLy of Amerlca. Summary of Lxlsung ollcy on Lhe use of Anumlcroblal urugs ln lood Anlmals." november 1, 2009. 17 World PealLh Crganlzauon. WPC Clobal SLraLegy for ConLalnmenL of Anuml- croblal 8eslsLance." 2001 aL 37. Avallable aL hup://www.who.lnL/csr/resourc- es/publlcauons/drugreslsL/en/LClobal_SLraL.pdf. Accessed March S, 2012. 18 luA nauonal Anublouc 8eslsLance MonlLorlng SysLem (nA8MS). 2011 8eLall MeaL 8eporL." 2013 aL 6. 19 lood & WaLer WaLch analysls of luA nA8MS, 2013. 20 kux, Leslle. Acung AsslsLanL Commlssloner for ollcy. luA. Leuer of nal response from Lhe luA Lo Cluzen euuon (Crlglnal uockeL no. 0S-0139/C, new uockeL no. luA-200S--0007) submlued on Aprll 7, 200S, on behalf of LnvlronmenLal uefense, Lhe Amerlcan Academy of edlaLrlcs, Lhe Amerlcan ubllc PealLh Assoclauon, lood Anlmal Concerns 1rusL, and Lhe unlon of Concerned SclenusLs. november 7, 2011 aL 3 Lo 4. 21 CovernmenL AccounLablllLy Cmce (CAC). Agencles Pave Made LlmlLed rog- ress Addresslng Anublouc use ln Anlmals." (CAC-11-801). SepLember 2011 aL WhaL CAC 8ecommends. 22 8oucher eL al. 2009 aL 1. 23 Sllbergeld eL al. 2011 aL 1S1, MelsLer, 2011. 24 Marshall and Levy. 2011 aL 718 Lo 719. 2S lblJ. aL 723. 26 Mayo Cllnlc. Anubloucs: Mlsuse puLs you and oLhers aL rlsk." lebruary 4, 2012. Avallable aL hup://www.mayocllnlc.com/healLh/anubloucs/lL0007S. Accessed March 7, 2012. 27 lblJ. 28 1ranslauonal Cenomlcs 8esearch lnsuLuLe. [ress 8elease]. 1Cen-led sLudy suggesLs orlglns of M8SA sLraln ln food anlmals." lebruary 21, 2012. 29 Marshall and Levy. 2011 aL 718. 30 lblJ. aL 719. 31 Sllbergeld eL al. 2008 aL 1S1, MelsLer, 2011. 32 CllchrlsL, M.!. eL al. 1he poLenual role of ConcenLraLed Anlmal leedlng Cp- erauons ln lnfecuous dlsease epldemlcs and anublouc reslsLance." ovltoo- meotol neoltb letspecuves. vol. 11S, lss. 2. 2007 aL 313. 33 SapkoLa, A. eL al. Anublouc-reslsLanL enLerococcl and fecal lndlcaLors ln surface waLer and groundwaLer lmpacLed by a concenLraLed swlne feedlng operauon." ovltoomeotol neoltb letspecuves. vol. 11S, lss. 7. 2007 aL 104S. 34 Cmce of Congresswoman Loulse SlaughLer. May 13, 2011, MelsLer, 2011. 3S MelsLer, 2011. 36 lblJ. 37 Love, u.C. eL al. leaLher Meal: A revlously unrecognlzed 8ouLe for 8eenLry lnLo Lhe lood Supply of Muluple harmaceuucals and ersonal Care roducLs (Cs)." ovltoomeotol 5cleoce & 1ecbooloqy, vol. 46. 2012 aL 3796. 38 Marshall and Levy. 2011 aL 719 and 726. 39 nemau, M. eL al. Anumlcroblal reslsLance of old and recenL 5topbylococcos ooteos lsolaLes from poulLry: rsL deLecuon of llvesLock-assoclaLed meLhlclllln- reslsLanL sLraln S1398." Aoumlctoblol Aqeots ooJ cbemotbetopy, vol. S2, lss. 10. 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(lSlS-8C-100-2011). uecember 1S, 2011, Schnlrrlng, Llsa, and 8oberL 8oos. luA order llmlLs cephalosporln use ln food anlmals." clukAl. !anuary 4, 2012. 9S CuC. Maklng lood Safer Lo LaL: 8educlng conLamlnauon from Lhe farm Lo Lhe Lable." cuc vltol 5lqos. !une 2011 aL 2. Avallable aL hup://www.cdc.gov/ vlLalslgns/loodSafeLy. Accessed March 9, 2012. 96 Conley, Casey. 8egulaLors: Pannaford records 'lnadequaLe,' hlnderlng beef lnvesugauon." 1be lottlooJ uolly 5oo. !anuary 6, 2012. 97 Sllbergeld eL al. 2008 aL 1S9. 98 Levy, S.8. eL al. Changes ln lnLesunal ora of farm personnel afer lnLroduc- uon of a LeLracycllne-supplemenLed feed on a farm." 1be New oqlooJ Iootool of MeJlcloe. vol. 29S. 1976 aL S83. 99 CllchrlsL eL al. 2007 aL 314. 100 khanna, 1. eL al. MeLhlclllln-reslsLanL 5topbylococcos ooteos colonlzauon ln plgs and plg farmers." vetetlooty Mlctobloloqy, vol. 128. 2008 aL 298, ley, aul eL al. 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Murphy, !oan. luA closes dockeLs on wlLhdraw- lng LeLracycllne, penlclllln ln anlmal feeds." looJ cbemlcol News. uecember 23, 2011. 142 1he organlzauons llng Lhe 200S cluzen peuuon were Lul, lAC1, uCS, Lhe Amerlcan Academy of edlaLrlcs and Lhe Amerlcan ubllc PealLh Assoclauon. Murphy, 2011. 143 Murphy, 2011. 144 naLural 8esources uefense Councll, CSl, lAC1, ubllc Cluzen and uCS. 14S llynn, uanlel. Croups Sue Cver Ag Anublouc use." looJ 5ofety News. May 26, 2011. 146 8ouemlller, Pelena. luA uenles euuon Lo 8an CerLaln Anubloucs." looJ 5ofety News. november 10, 2011. 147 Murphy, 2011. 148 luA nA8MS. 2013 aL 23, 41, 47 and 60. 149 Ll8oghdady, ulna. CourL orders luA Lo examlne anubloucs use on anlmals." 1be wosbloqtoo lost. March 22, 2012. 1S0 lblJ. 1S1 Murphy, !oan. luA ordered Lo relssue wlLhdrawal proceedlngs for penlclllln, LeLracycllnes ln feed." looJ cbemlcol News. March 23, 2012. 1S2 Ll8oghdady, 2012. 1S3 Murphy, !oan. luA ordered Lo revlew anlmal drug safeLy, crluclzed for relylng on volunLary program." looJ cbemlcol News. !une 8, 2012. 1S4 lblJ. 1SS nelson, !.M. eL al. lluoroqulnolone-reslsLanL compyloboctet specles and Lhe wlLhdrawal of uoroqulnolones from use ln poulLry: A publlc healLh success sLory." cllolcol lofecuoos ulseoses. vol. 44. 2007 aL 978 Lo 979. 1S6 lblJ. aL 979 Lo 980. 1S7 luA. luA lssues Culdance on Lvaluaung Lhe SafeLy of Anumlcroblal new Anlmal urugs. luA veLerlnarlan newsleuer. vol. 18, lss. 6. november/uecember 2003. 1S8 CAC. 2011 aL WhaL CAC lound. 1S9 luA nA8MS. 2013 aL 8. 160 lblJ. at 8 and 41. 161 Love, u.C. eL al. 2012 aL 3797. 162 luA. [ress 8elease]. Cephalosporln Crder of rohlbluon Coes lnLo LecL." Aprll 6, 2012. 163 luA. [ress 8elease]. luA Lo proLecL lmporLanL class of anumlcroblal drugs for Lreaung human lllness." !anuary 4, 2012, Schnlrrlng and 8oos, 2012. 164 uSuA lood SafeLy lnspecuon Servlce. uecember 1S, 2011. 16S Parrls, 2012, Schnlrrlng and 8oos, 2012. 166 Schnlrrlng and 8oos, 2012. 167 21 Cl8 arL S30 [uockeL no. luA-2008-n-0326] aL 31, luA. [ress 8elease]. Cephalosporln Crder of rohlbluon Coes lnLo LecL." Aprll 6, 2012. 168 21 Cl8 arL S30 [uockeL no. luA-2008-n-0326] aL 12. 169 lblJ. at 13. 170 rlce eL al. 2012 aL 4. 171 luA CenLer for veLerlnary Medlclne (CvM). Aprll 13, 2012, luA CenLer for veLerlnary Medlclne. Culdance for lndusLry 213: new Anlmal urugs and new Anlmal urug Comblnauon roducLs AdmlnlsLered ln or on MedlcaLed leed or urlnklng WaLer of lood-roduclng Anlmals: 8ecommendauons for urug Spon- sors for volunLarlly Allgnlng roducL use Condluons wlLh Cll #209." uecember 2013. 172 luA. luA's SLraLegy on Anumlcroblal 8eslsLance: Cuesuons and Answers." Aprll 11, 2012. Avallable aL hup://www.fda.gov/AnlmalveLerlnary/Culdance- CompllanceLnforcemenL/CuldanceforlndusLry/ucm216939.hLm. Accessed Aprll 17, 2012. 173 luA CvM. Aprll 13, 2012 aL 3. 174 luA CvM. uecember 2013 aL 2. 17S lblJ. aL 4, 6 Lo 7. 176 lblJ. at 8. 177 78 led. 8eg. 7SS1S-7SS27. uecember 12, 2013. 178 luA CvM. Aprll 13, 2012 aL 22. 179 luA CvM. uecember 2013 aL 8. 180 1avernlse, Sabrlna. l.u.A. 8esLrlcLs Anubloucs use for LlvesLock." 1be New otk 1lmes. uecember 11, 2013. 181 luA CvM. uecember 2013 aL 7. 182 uCS. 1he reservauon of Anubloucs for Medlcal 1reaLmenL AcL (AM1A, P.8. 96S/S. 1211) Lndorsers LlsL for Lhe 112Lh Congress." SepLember 1S, 2011. Avallable aL hup://www.ucsusa.org/food_and_agrlculLure/soluuons/wlse_an- ubloucs/pamLa-endorsers-112Lh.hLml. Accessed March 27, 2012. 183 Amerlcan larm 8ureau lederauon. [ress 8elease]. Anubloucs vlLal Lo Anlmal PealLh, lood roLecuon." March 24, 2009, Amerlcan MeaL lnsuLuLe. Slgn-on Leuer Lo 8epresenLauve Mlchael Lnzl, 8anklng Member, SenaLe Commluee on PealLh, Lducauon, Labor & enslons Commluee. november 18, 2009. Avall- able aL hup://www.meaLaml.com/hL/dlsplay/ArucleueLalls/l/SS381. Accessed March 27, 2012, Morgan, Ashley. 8elnLroducuon of Leglslauon Seeklng Lo 8an Anubloucs." 1be AMvA AJvocote. Amerlcan veLerlnary Medlclne Assocla- uon. Aprll 2011. 184 Cmce of Congresswoman Loulse SlaughLer. [ress 8elease]. SlaughLer llghLs Lo keep Anubloucs Lecuve, 8educe unnecessary use ln Anlmals." March 9, 2011. 18S lblJ. 186 lood & WaLer WaLch analysls of daLa from CenLer for 8esponslve ollucs. Avallable aL www.opensecreLs.org. Accessed lebruary 23, 2012. 187 CAC. Agencles Pave Made LlmlLed rogress Addresslng Anublouc use ln Anlmals." (CAC-11-801). SepLember 2011 aL WhaL CAC 8ecommends. National Ofce 1616 P St. NW, Ste. 300 Washington, DC 20036 tel: (202) 683-2500 fax: (202) 683-2501 info@fwwatch.org www.foodandwaterwatch.org Food & Water Watch