The American Association of Bovine Practitioners (AABP) and the Academy of Veterinary Consultants (AVC) welcome the opportunity to collaborate with the FDA-CVM on the principles identified in the draft guidance titled “The Judicious Use of Medically Important Antimicrobial Drugs in Food-Producing Animals.” The issues of drug availability for maintaining good animal health, as well as veterinary oversight/consultation for such uses have been priorities for AABP and AVC members for many years.
Although the AABP and AVC do not agree that the weight of the scientific evidence supports the phasing out of all production indications, we are committed to supporting changes that measurably and positively impact the critical issue of antimicrobial resistance. The AABP and AVC recognize the importance of antimicrobial resistance, and wish to participate in aggressively addressing resistance concerns; however, the organizations remain committed to regulation based on data-based analysis rather than expert consensus. It is imperative that the collaborators approach the issue of production enhancement uses of antimicrobials with the realization that the standards and practices established for these uses will serve as a precedent for evaluating disease prevention, control, and therapeutic uses.
Lastly, in regards to FDA-CVM’s request for comment on enhancing the efficiency of the Veterinary Feed Directive drug program, the AABP and AVC look forward to collaborating with the agency to evaluate potential methods of veterinary oversight, input or consultation for the use of antimicrobials in livestock feeds.
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