The National Farmers Union (NFU) is pleased to provide input on the proposed amendments to the Food and Drug Regulation regarding Veterinary Drugs — Antimicrobial Resistance. We will focus our comments on two aspects of the proposed regulatory amendment:
- the measures to restrict the own use importation of unauthorized veterinary drugs; and
- the measures to require manufacturers, importers and compounders of veterinary antimicrobials to provide sales volume information by species.
We support these changes, which promote human health, food safety and transparency.
The NFU recognizes the importance of antimicrobials for both human and veterinary use and the need to prevent the evolution of resistant disease-causing microbes that occurs when these drugs are improperly used.
Measures to Restrict the Own Use Importation of Unauthorized Veterinary Drugs
The NFU agrees that restrictions on importation for own-use are necessary to ensure antimicrobials are not irresponsibly used in animal agriculture. For example, Canada has restricted the use of third generation cephalosporins in animal agriculture in order to prevent the evolution of pathogens that are unaffected by the drug. This measure has been effective in reducing the incidence of resistant e coli and salmonella in poultry, swine and cattle; however some resistance is still occurring.[i] If allowed to continue, unregulated own-use importation of unauthorized antimicrobials would permit unscrupulous operators to undermine preventative measures, endangering the future health of Canadians and potentially damaging the reputation of Canadian agriculture.
Canadian officials often state our regulatory system is “science based.” Allowing unregulated own-use importation of veterinary drugs goes against this assertion. Proper regulatory oversight of veterinary drug use is needed to ensure Canada’s food system produces wholesome, healthy food for our domestic population and international customers. The current own-use exemption is unacceptable in today’s context where virtually any drug may be ordered online and where agriculture enterprises that raise and sell tens of thousands of animals may seek to reduce their costs by using imported unapproved antimicrobials.
Measures to require manufacturers, importers and compounders to provide sales volume information by species
As stated in the Canadian Antimicrobial Resistance Surveillance System Report 2016 “Information on antimicrobials distributed for sale for use in animals has been voluntarily provided by the Canadian Animal Health Institute (CAHI) since 2006. These data represent quantities of antimicrobials distributed for sale by member companies and do not include quantities of antimicrobials imported for own use or as active pharmaceutical ingredients used in further compounding.” [ii]
The same report also notes that in 2014, 99% of the reported antimicrobials were for use in food-production animals and less than 1% was for pets. Nearly three quarters of these antimicrobials were in the same classes as those used in human medicine. The report says “inappropriate antimicrobial use in food-producing animals is a public health concern as it contributes to emergence of resistant bacteria in animals that can be transmitted to humans through food supply.” The current lack of data on own-use importation means that policy makers have no way of knowing the quantities, types or uses of these antimicrobials, and thus cannot properly govern the use of these drugs in Canada. Reporting requirements would allow research on impacts of these drugs to be made on the basis of actual data and policy decisions could be made with greater confidence.
In conclusion, the NFU supports “Option 3 – Amending the Food and Drug Regulations” as presented in the regulatory consultation document.
Respectfully submitted by
The National Farmers Union[i] Canadian Antimicrobial Resistance Surveillance System Report 2016, Public Health Agency of Canada, September 12, 2016. http://healthycanadians.gc.ca/publications/drugs-products-medicaments-produits/antibiotic-resistance-antibiotique/antimicrobial-surveillance-antimicrobioresistance-eng.php#a4-4-2
[ii] Ibid.
