AHI is the national trade association representing research and development companies for animal medicines and vaccines in the United States. Many of our member companies are global in nature and supply technologies to animal agriculture to keep animals healthy in order to provide a safe and affordable food supply. As such we have a great interest in food safety and security issues.
We appreciate the opportunity to comment on the ICN2 Framework for Action. We have some general comments and some specific suggestions for rewording the recommendations under 3.3.6 Food Safety and Antimicrobial Resistance.
On page 8 – the WHO dietary recommendations; the last bullet point (“adequate intake of animal source foods is guaranteed in children under five) could identify a more specific quantitative goal and could be expanded to children older than five.
Page 24 – last paragraph of section 4.4; 2nd sentence could read: “There should be effective incentives for farmers to produce sufficient healthy foods (e.g. fruits, vegetables and animal-sourced proteins) to be sold at affordable prices.
3.3.6 Food Safety and Antimicrobial Resistance
We find it curious that the issue of antimicrobial resistance, while important, would be specifically covered in a document dealing with nutrition to the exclusion of other food safety issues of greater importance. We do not believe that recommendations presented here are necessary as this issue has already been extensively reviewed by WHO, FAO, the OIE and many national authorities. However, if the report is to include recommendations we would suggest the following wording changes:
- On the third bullet point we suggest it be reworded to “Phase out the use of medically important antimicrobials for growth promotion.”
- On point number 4 revise to: “Ensure appropriate control of the use in food-producing animals of antimicrobials identified as critically important in human medicine, such as fluoroquinolones and third-and fourth generation cephalosporins.”
- On point number 6, revise to: “Develop and implement national guidelines on responsible use of antimicrobials in food-producing animals, with multidisciplinary involvement, taking into consideration recommendations made by OIE for clinical practices.”
We again thank you for the opportunity to comment on this important work.