Anna E. Mazzucco, Ph.D.
August 13, 2014
My name is Dr. Anna Mazzucco. Thank you for the opportunity to speak today on behalf of the National Center for Health Research. After completing my Ph.D. in Cell Biology at Harvard Medical School, I conducted research at the National Institutes of Health. Those are the perspectives I bring today.
Our research center conducts research, analyzes data in the research literature, and then explains the evidence of risks and benefits to policymakers and consumers. Our president is on the Board of Directors of the Alliance for a Stronger FDA, which is a nonprofit dedicated to increasing the resources that the FDA needs to do its job. Our organization does not accept funding from pharmaceutical companies, and therefore I have no conflicts of interest.
Antibiotic resistance and the inability to treat common infections is an increasingly urgent public health crisis which affects everyone, but especially some of the most vulnerable in our society- the very young, the old, and the ill. A CDC report from last year estimated that there at least 2 million illnesses and 23,000 deaths annually in the United States due to antibiotic resistance.1
The NARMS effort is the primary source of information on antibiotic resistance in foodborne pathogens in the United States. We thank the FDA, CDC, and USDA for all their joint efforts in this critical endeavor. However, we feel that additional steps would strengthen these ongoing efforts. Specifically:
- Mounting evidence supports the link between antibiotics in animal production and the increase in resistant infections in humans. FDA efforts to reduce antibiotic use in animal production need to be broadened to halt use of antibiotics for disease prevention purposes, not just those used for growth promotion. Identical drugs and treatment durations are often used in both scenarios. And voluntary agreements are not enough: we need requirements that are enforced, including phase-outs and bans.2
- NARMS sample testing should be expanded to include more on-farm sites, breeding facilities and slaughterhouses in more geographic areas in addition to animal feed. Such information is critical to accurately pinpoint sources of contamination, as these are important entry points into the food supply chain. Quantitative data on antibiotic use in animal feed, especially antibiotics important for human medicine, is urgently needed, and should be added to NARMS monitoring.
- To better understand human infections, NARMS should expand its testing to also include human extraintestinal clinical samples to monitor pathogenic E. coli and Enterococcus.
- Retail product testing should be expanded to include a sufficient number of samples to generate meaningful results. Testing should also be expanded to include dairy products, and ground pork and turkey products, as these products have been a significant source of antibiotic resistant outbreaks.
- More comprehensive microbial testing for other strains such S. aureus and MRSA should also be done. A 2012 report found that 65% percent of 395 pork samples were contaminated with S. aureus and that 7% were contaminated with MRSA.3
- More sensitive microbial techniques should be used to detect antibiotic resistance, such as using selective broth culturing rather than single colony testing.
- There is still a significant delay in releasing data from NARM surveillance efforts. Faster turnover times are needed for this critical data to be actionable by public health and medical workers in order to respond to emerging situations in a timely manner.
Last but definitely not least, we urge the participating agencies to ensure that NARMS receives the funding that it needs to maintain and build upon these vital efforts. Antibiotic resistant infections are estimated to cost the U.S. healthcare system between $21 and $34 billion dollars every year.4 The above recommended changes would be cost effective, saving millions if not billions of dollars for federal programs and individual taxpayers. Our Center will help educate Congress about the need for these efforts, but the agencies need to clearly make the case that this is an urgent priority.
- Centers for Disease Control and Prevention. Antibiotic Resistance Threats in the United States, 2013. ▲
- U.S. Food and Drug Administration (2013). Guidance for Industry: New Animal Drugs and New Animal Drug Combination Products Administered in or on Medicated Feed or Drinking Water of Food-Producing Animals: Recommendations for Drug Sponsors for Voluntarily Aligning Product Use Conditions with GFI #209. #213. Available at http://www.fda.gov/downloads/AnimalVeterinary/GuidanceComplianceEnforcement/GuidanceforIndustry/UCM299624.pdf ▲
- O’Brien AM, Hanson BM, Farina SA, Wu JY, et al. (2012). MRSA in conventional and alternative retail pork products. PLoS One, 7(1), e30092. ▲
- Infectious Disease Society of America. Comments on NARMS Strategic Plan. 2011. ▲