Comments from IFAH
Thank you for taking on board the following comments related to section 3.3.6 Food safety and antimicrobial resistance from IFAH (International Federation for Animal Health). IFAH is the global representative body of companies engaged in research, development, manufacturing and commercialisation of veterinary medicines, vaccines and other animal health products in both developed and developing countries across the five continents. IFAH represents both animal health companies and national/regional animal health associations. These associations comprise both local small and medium-sized enterprises and international companies. Overall, these companies represent approximately 80% of the global market for animal health products.
Section 3.3.6 Food safety and antimicrobial resistance should be deleted as it does not belong in a document addressing food nutrition, as it is solely a food safety issue. AMR in animals is being dealt with separately by the WHO/FAO/OIE and individual countries. A specific action plan is being drafted by WHO, OIE has already taken extensive action in this area, as have many IFAH companies and food chain operators. A good example is the multi-stakeholder platform linking best practice with animal health and public health called EPRUMA (European Platform for Responsible Use of Medicines in Animals) www.epruma.eu.
If the text is kept, we recommend that at a minimum it should: 1) recognise the need for appropriate animal treatments to ensure that animals for food, are healthy animals, and 2) explicitly recognised that if the animals are not healthy, they and their products cannot be used to meet the rising demand for animal protein. Ineffective disease control, leading to inefficient animal production will lead to higher prices, once again hitting the poorest worst.
Regarding the text, we suggest three specific improvements to better reflect current developments.
1. On the third bullet point under “Priority actions” (page 23) reading: “Terminate non-therapeutic use of antimicrobials, such as the use of antimicrobials as growth promoters.”
We suggest that the text be reworked to read: “In line with current actions of national authorities, phase-out non-therapeutic use of medically important antimicrobials, such as the use of antimicrobials as growth promoters.” If the phase-out approach is not embraced, some constituencies will ignore this. It is also important to distinguish between therapy - the act of applying a medicine, – and a cure - which is the act of healing.
2. On the fourth bullet point under “Priority actions” (page 23) reading: “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.”
We suggest changing the text to: “Apply the prudent and responsible use of antibiotics guidelines developed by OIE to 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.” Many countries have developed intensive and widely-accepted responsible use guidelines in line with the OIE guidelines. Simply ‘eliminating’ will not be accepted and duly ignored by many countries and stakeholders, because it does not take into account medicinal needs and animal welfare considerations. Furthermore, in countries where the responsible use approach is applied rigorously, the use of those classes is minimal relative to the overall use of antibiotics, and in any case much lower relative to the human side.
3. On the sixth bullet point under “Priority actions” (page 23) reading: “Develop and implement national guidelines on prudent use of antimicrobials in food-producing animals, with multidisciplinary involvement, taking into consideration antimicrobials categorized as critically important for human medicine by WHO.”
We suggest adding at the end “as well as the OIE list of antimicrobial agents of veterinary importance.” (http://www.oie.int/fileadmin/Home/eng/Our_scientific_expertise/docs/pdf/OIE_list_antimicrobials.pdf)