Re: FDA docket #: FDA-2022-N-0824
Antimicrobial use is the primary selective force behind the emergence of resistant bacteria. Better stewardship is essential to combat the spread of resistance. However, veterinary antimicrobial use and stewardship cannot be optimized without measurement.
The FDA’s Draft Framework for a Public-Private Partnership to Support the Tracking of Antimicrobial Use in Food-Producing Animals is lacking in three important ways, which I urge you to address:
- Challenges to collecting representative data from a voluntary program
- Failure to consider alternatives, and
- Challenges to balancing divergent public and private interests
I know that you are in receipt of proposals to address these concerns from the Keep Antibiotics Working coalition, and I urge you to act on those recommendations. Failure to do so will result in an ineffective program and prolong the overuse of antibiotics in animal agriculture.