CSPI Offers Suggestions to FDA on Collecting Data Regarding On-Farm Antimicrobial Use
The Center for Science in the Public Interest (CSPI) has submitted comments to the FDA regarding the Reagan-Udall Foundation’s preliminary report on monitoring antimicrobial use.
Last spring, the Food and Drug Administration commissioned the Reagan-Udall Foundation to explore how the agency could collect data on antimicrobial use on farms to better understand and limit antimicrobial resistance resulting from such use. .
The Reagan-Udall Foundation is an independent organization created by Congress “to advance the FDA’s mission to modernize the development of medical, veterinary, food, food ingredient, and cosmetic products, accelerate innovation, and improve product safety”.
The FDA and CSPI consider antimicrobial surveillance to be essential because the use of antimicrobials in food animals can lead to the development of antimicrobial resistance in bacteria harmful to humans.
The foundation has been evaluating the possibility of a public-private partnership to facilitate the collection of anonymous data on antimicrobial use on farms by the FDA. The report has developed a series of principles which it recommends should be included in any data collection system.
“Creating a system whereby farmers and veterinarians can compare a farm’s use of antibiotics to use by similar farms will promote the responsible use of these drugs,” says Dr. James Kincheloe, a veterinarian who worked on production farms and is the food safety manager. Campaign manager at CSPI. “With such a system, farms will be better able to see where there may be inappropriate use, which is often a financial cost in addition to being a danger to public health.”
- The FDA should ensure that the appropriate components of antimicrobial use data are recorded on farms.
- The FDA should require each farm to record its usage data and that this data be made available to the agency for sampling.
- The FDA should develop a data collection system to compare farms.
CSPI agreed with the foundation’s assessment that there is a need to collect data showing the nuances of how these antibiotics are used, including animal species, size and purpose of treatment. However, the CSPI recommended that this data collection be mandatory. The center suggests that this data would be held by producers, but the FDA could sample a random set of producers on an annual basis to track antibiotic use more finely than is possible with current practices. The agency could then provide updated aggregate data in an annual report or on a website.
CSPI suggests that some growers could use this data to see how their practices compare to overall industry practices. This data can also help public health agencies develop policies to target uses that could be mitigated or modified to minimize the development of resistance.
To facilitate such comparisons, CSPI urged the FDA to require each farm to record its use consistently, whether or not FDA samples a farm’s data that year, and that the agency publish the data collected. in a way that allows producers and veterinarians to benchmark their use of antimicrobials against that of their peers. The center added that standardized data collection and random sampling of a subset is necessary to avoid biased data that could result from a voluntary opt-in process.
Full CSPI comments are available here.
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