American Society for the Prevention of Cruelty to Animals Animal Welfare Institute • Farm Sanctuary • Food Animal Concerns Trust Humane Farming Association • Humane Society of the United States Humane Society Veterinary Medical Association
October 21, 2009
The Honorable Louise McIntosh Slaughter U.S. House of Representatives 2469 Rayburn House Office Building Washington, D.C. 20515
Dear Representative Slaughter:
We, the undersigned animal protection organizations representing more than 11 million supporters nationwide, are writing to voice our strong support for H.R. 1549/S. 619, the Preservation of Antibiotics for Medical Treatment Act (PAMTA), introduced by Representative Louise Slaughter and Senators Edward Kennedy and Olympia Snowe.
Profligate use by industrial agriculture of antibiotics for non-therapeutic purposes – to keep animals from getting sick in overcrowded, stressful, often unsanitary conditions on factory farms and feedlots, and to artificially speed their growth – threatens to ruin the effectiveness of these wonder drugs for treating sick people and sick animals. An estimated 70% of all antimicrobials used in this country are squandered for non-therapeutic purposes. Most pigs, chickens, and turkeys raised for food in the U.S. are fed low doses of antibiotics virtually every day of their lives, and most beef cattle receive these drugs from the day they arrive in the feedlot until just before slaughter. This routine feeding of antibiotics to billions of animals who are not sick is tailor-made to hasten the development of resistant bacteria affecting both animals and people. Just as in human medicine, we must do all we can to minimize or eliminate unnecessary use of antibiotics in animal agriculture in order to preserve the effectiveness of these precious drugs.
The Food and Drug Administration (FDA) currently has the authority and the mandate to protect human and animal health by withdrawing its approvals of antibiotics for non-therapeutic purposes – approvals granted in many cases decades ago, before resistance concerns were being given real consideration. However, current law affords drug companies ample opportunities to contest any proposed withdrawal, effectively shifting the burden of proof away from the manufacturer (who is legally required to prove a drug is safe) and onto the FDA, which may end up having to spend many years of effort and limited agency resources to defend against appeals.
PAMTA would clearly restore the burden of proof on the manufacturer to prove safety and streamline the process for FDA to withdraw approval of antibiotics for non-therapeutic purposes. Without such streamlining, it could take the agency into the next century to work through the cancellations and appeals process for hundreds of prior approvals involving different drugs in different species for various non-therapeutic uses. We simply cannot afford to wait decades to address this urgent problem.
We note that PAMTA addresses only non-therapeutic uses. It would not impede use of antibiotics to treat sick farm animals. And it only affects drugs in classes that are used in human medicine, so it leaves other drug options available for producers. Perhaps most importantly, producers who employ humane, sustainable practices needn’t rely on constant medication to keep their flocks and herds healthy.
We urge Congress to enact this legislation quickly to help preserve the effectiveness of antibiotics for treatment of illness, and to stop wasting these drugs on reckless non-therapeutic uses that serve as a crutch to maintain inhumane conditions in industrialized animal agriculture. Thank you for your consideration.
Sincerely,
Wayne Pacelle President and CEO The Humane Society of the United States
Cathy Liss President Animal Welfare Institute
Gene Baur President and Co-Founder Farm Sanctuary
Barbara Hodges, DVM, MBA Veterinary Consultant Humane Society Veterinary Medical Association
Richard R. Wood Executive Director Food Animal Concerns Trust (FACT)
Jill Mountjoy Project Director Humane Farming Association
Betsy Dribben Vice President for Government Relations American Society for the Prevention of Cruelty to Animals