3.3.6 Food safety and antimicrobial resistance
As a veterinarian I have a commitment to protect public health, animal health, food safety and ecosystem health. It is clear that this draft also recognizes the need for a One Health approach to address this complex issue. Balancing priorities outlined in other sections – such as increasing productivity and economic growth to improve nutrition outcomes, reducing net unit costs, increasing farmer’s incomes and lowering food prices – with the need to produce safe food while protecting public health, animal health and the ecosystem by using antimicrobials responsibly should be considered when making recommendations.
Meat is a nutrient rich component of the diet that provides an important source of iron and folic acid, along with other important nutrients. Producing a safe and abundant supply of meat requires the ability to keep animals healthy. To that end, I make the following specific comments on the draft priority actions found in Chapter 3.3.6:
· Terminate non-therapeutic use of antimicrobials, such as the use of antimicrobials as growth promoters.
I recommend that the language be consistent with the WHO Action Plan on Antimicrobial Resistance which addresses these concerns with the following point: 4.2. In the absence of a public health safety evaluation, terminate or rapidly phase out the use of antimicrobials for growth promotion if they are also used for treatment of humans.
The rationale for this is that consistency between the two documents will minimize confusion. In addition, the term non-therapeutic has different definitions from country to country, while the definition of growth promotion is more consistent. Finally, there are certain antimicrobials, such as ionophores, that are only used in animal production and their use appears to have no potential negative effect on public health.
· Restrict or eliminate the use in food-producing animals of antimicrobials identified as critically important in human medicine, especially the use of fluoroquinolones, and third-and fourth generation cephalosporins.
Since keeping animals healthy is an important part of safe food as well as an important animal welfare consideration I would recommend the following revision: Restrict the use in food-producing animals of fluoroquinolones and third-and-fourth generation cepahalosporins to treatment of individual animals under the direction of a veterinarian who has given careful consideration to the use of these classes.
The rationale is that this restriction will allow the treatment of individual sick animals identified by the veterinarian as appropriate for treatment with these compounds following careful consideration of other potential treatments. It will prevent these compounds from being used to promote growth or other production purposes. This will promote antimicrobial stewardship while also preserving public health, animal health and animal welfare.