November 21, 2012
The Honorable Henry A. Waxman, Ranking Member
Energy and Commerce Committee
U.S. House of Representatives
Washington, DC 20515
Re: Draft Proposal of the Delivering Antibiotic Transparency in Animals (Data) Act of 2012
Dear Congressman Waxman:
We thank you for the opportunity to provide comments on the discussion draft of legislation to enhance the reporting requirements pertaining to the use of antibiotics in food animals.
The National Research Center for Women & Families supports the Data Act, and we share your concerns about the current and growing risk of antibacterial resistance to medically important drugs as a consequence of agricultural practices.
The Data Act’s proposed changes to the Federal Food, Drug, and Cosmetic Act would provide needed data to help public health officials interpret trends in microbial resistance, and understand the relationship between drug use in food animals and antibacterial drug resistance in medical treatment. It would also identify strategies to control antibacterial resistance in the future. We support this legislation and offer the following suggestions that should help to ensure a more complete reporting and monitoring of antibiotic use in food animals.
In light of recent reports, consistent with the November 19, 2012 Washington Post article, we suggest including fish in the list of reportable animal species. A recent report from a collaborative group between the United States and Canada found that “resistance to tetracycline in one or more species of bacteria was reported as ‘frequent-to-almost always’” in the most frequently farmed species (including catfish, salmon, tilapia, and shrimp). With the rise in consumption of fish, monitoring antibiotic use in aquaculture now may be a way to prevent widespread antibiotic resistance and serve as a way to promote a healthy image for farm-raised fish in the U.S.A. as compared to imported seafood.
Section 4(3)(D) Guidelines to amend list of antibacterial active ingredients important in human medicine
We strongly support the requirement that sponsors must report on new drugs with an antibacterial active ingredient designated as important in human medicine or sharing resistance patterns with antibacterial active ingredients important in human medicine. We suggest adding a third clause to this section to clearly state that the Secretary has the authority to require reporting of new drugs with antibacterial active ingredients that may become important in human medicine in the future. Bacteria are constantly changing and antibacterial active ingredients used in human medicine must adapt accordingly.
Thank you for the opportunity to comment on this discussion draft of the Data Act and look forward to working with you on this important legislation.
National Research Center for Women & Families
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 Butler C (November 19, 2012). Eating fish is wise, but it’s good to know where your seafood comes from, Washington Post. http://www.washingtonpost.com/national/health-science/eating-fish-is-wise-but-its-good-to-know-where-your-seafood-comes-from/2012/11/17/73483c5a-2cd9-11e2-9ac2-1c61452669c3_story.html
 Tuševljak, N., Dutil, L., Rajić, A., Uhland, F. C., McClure, C., St-Hilaire, S., Reid-Smith, R. J. and McEwen, S. A. (2012), Antimicrobial Use and Resistance in Aquaculture: Findings of a Globally Administered Survey of Aquaculture-Allied Professionals. Zoonoses and Public Health. doi: 10.1111/zph.12017