In comments submitted this week to the Food and Drug Administration (FDA) about the agency’s proposal to collect from animal drug sponsors species-specific estimates of product sales, NCC wrote that the that FDA’s current data collection and reporting program meets the requirements of the Animal Drug User Fees Amendments of 2008.
Specifically, NCC sketched out three major areas of concern with the proposal:
- Species-specific estimates are highly susceptible to misinterpretation;
- The data collected reflect sales, not use; and
- Agency resources are better deployed through alternative programs.
Research initiatives such as the National Antimicrobial Resistance Monitoring System (NARMS) program and the National Animal Health Monitoring System (NAHMS) reports provide valuable information to the public, as well as to broiler chicken producers. The continued reliance on antimicrobial sales and distribution data unfortunately dilutes and distorts the information provided by NARMS and NAHMS, and NCC believes that the collection of species-specific data would contribute to consumer confusion and negative perception regarding agricultural animal production without providing a public health benefit.
NCC supports the efforts of the USDA and FDA to monitor antimicrobial resistance and their work with the agricultural community to discuss methods of judicious use and stewardship. We are committed to the judicious use and continued efficacy of antibiotics for human and broiler health. As such, NCC has collaborated with both agencies to identify methods through which the industry can help in reducing the spread of antimicrobial-resistant bacteria and is fully supportive of Guidance for Industry (GFI) #209 and #213, as well as the Veterinary Feed Directive (VFD).
The comments can be read in their entirety by clicking here.