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NMPF Comments on FDA Veterinary Priorities and Antimicrobial Use Duration

February 5, 2024

NMPF submitted comments Jan. 19 to the FDA Center for Veterinary Medicine on their Environmental Scan.

The scan’s purpose is to identify major trends, including emerging issues and ongoing challenges, in the veterinary center’s internal and external environments to support, inform, and improve short-term and long-term strategic planning. The center asked six wide ranging questions about priorities, legal authority, communications, and One Health, an effort to improve health outcomes among all species.

NMPF’s comments reviewed the nearly 40-year U.S. dairy industry commitment to One Health through residue avoidance and the FARM animal care program. Comments to specific questions included support for broader FDA authority through the FEED Act to regulate feed additives with non-nutritive benefits, including environmental benefit claims, production claims, and claims about effects on the animal well-being and pre-harvest food safety. The comments also supported FDA’s efforts to streamline development and approval of other novel technologies to address animal health, antimicrobial use, and environmental issues.

The veterinary medicine comments followed joint comments NMPF submitted Jan. 5 with the American Association of Bovine Practitioners (AABP), the Academy of Veterinary Consultants (AVC), and the National Cattlemen’s Beef Association (NCBA) on the draft FDA Guidance for Industry (GFI) #273 Defining Durations of Use for Approved Medically Important Antimicrobial Drugs Fed to Food-Producing Animals. In reviewing GFI #273, the groups identified several substantive concerns.

The group also referenced the agency back to extensive evidence-based comments previously submitted to earlier requests by the agency for public comments on this topic — specifically, the joint comments from AABP, AVC, NMPF and NCBA in 2017 and 2021, to include a request for information document with more than 80 scientific references.