THE ONE-MINUTE ACTIVIST

September 2010

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Michael R. Taylor,
Deputy Commissioner for Foods
Food and Drug Administration
5630 Fishers Lane
Room 1061,
HFA-305 Rockville, MD 20852

Deputy Commissioner Taylor,

I am writing to express my concern about the agency's draft guidance on the "Judicious Use of Medically Important Antimicrobial Drugs in Food-Producing Animals" (Docket No. FDA_2010-D-0094).

It is long past time for action from the FDA on the issue of antibiotic use in livestock production. Groups including the American Medical Association, the American Public Health Association, and the American Academy of Pediatrics have identified the growth of antibiotic resistance as a threat to public health that must be addressed.

The time for discussion is over—it is time for the FDA to act to curtail the overuse of antibiotics in livestock production.
Specifically, I have several comments on the draft guidance:

• The agency should define "judicious use" of antibiotics as the treatment of the disease, under the supervision of a veterinarian, which does not include the use of antimicrobial drugs for growth promotion and feed efficiency.
• The approach described in the draft guidance could allow the continued feeding of antibiotics to entire flocks or herds of animals to prevent illnesses they may never acquire or have little risk of contracting.
• The guidance fails to include any time-line or commitment to taking any concrete regulatory steps, and this is a major omission.

I urge the FDA to move swiftly to the step of issuing regulations that will finally curtail the widespread use of antibiotics in food animal production.

Sincerely,

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Thanks to Food and Water Watch