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NMPF Recommends Next Steps to Government on Animal Antibiotic Data Collection

July 6, 2016

As the federal government continues its focus on the health impacts of antibiotics use in people and animals, NMPF has provided the Presidential Advisory Council on Combatting Antibiotic-Resistant Bacteria with input on how drugs are used on dairy farms, and how the government should consider updating its data collection process.

Current data collection efforts on farm animal antimicrobial use are fragmented and ad hoc, “resulting in information that has not been scientifically beneficial,” NMPF wrote June 22 to the Department of Health and Human Services, which is the lead federal agency on this issue.

NMPF cautioned that a mere comparison of sales data to animal and human markets is not helpful, and that such comparisons create the impression that sales volumes correlate to the risk of spreading antibiotic-resistant bacteria. Rather than comparing the relative sales of antibiotics for animal and human uses, NMPF believes a national data collection program should be:

1. Objective driven.  A data collection program should start with a clearly stated scientific purpose which drives the collection method.  To date, this clear objective has been lacking in federal data collection efforts.

2. Comprehensive.  Data should be collected on all uses, and data from the human, veterinary and other sectors should be collected in a way that makes meaningful comparison possible.  Human health care systems are not reporting on a weight based measure, but rather in either days of treatment or defined daily doses. Simple comparisons by kilograms or pounds of antibiotics between animal and humans are inherently misleading due to the larger size of most food animals.

3. Globally comparable.  Events continue to demonstrate the global nature of the antibiotic resistance challenge.  Other countries have moved away from volume measurements toward animal defined doses.  Ensuring the U.S. produces globally comparable data will assist in the necessary global coordination of mitigation efforts.

4. Protective of confidentiality.  Public use of farm-level data must be aggregated to protect confidentiality and raw data must be protected from public disclosure.

NMPF expressed support in its comments for a USDA Animal and Plant Health Inspection Service initiative that features a more comprehensive data collection process.  National Milk has been part of a coalition of livestock, veterinarian, and allied industry organizations that are urging Congress to allocate funding to USDA for this effort.

NMPF’s comments also outlined the value of the National Dairy Farmers Assuring Responsible Management (FARM) animal care Program’s guidance on the proper use of antibiotics as part of an overall herd health plan, along with the importance of the FARM program’s Milk and Dairy Beef Drug Residue Prevention Manual.

The CARB process is a multi-year effort across the federal government to address several related priorities, including on-farm antibiotic use data collection and increased antimicrobial stewardship in food and companion animals.