Antibiotic Use in Livestock Production: New FDA Guidance

Today, the FDA announced the issuance of its Draft Guidance on The Judicious Use of Medically Important Antimicrobials in Food-Producing Animals. FDA's press release states that this guidance is "intended to help reduce the development of resistance to medically important antimicrobial drugs" and calls for their "judicious [use] in animal agriculture."

The draft guidance summarizes the current research on antimicrobial resistance and concludes that "using medically important antimicrobial drugs for production or growth enhancing purposes (i.e., non-therapeutic or subtherapeutic uses) in food-producing animals is not in the interest of protecting and promoting the public health." The guidance recommends "phasing in measures that would limit medically important antimicrobial drugs to uses in food-producing animals that are considered necessary for assuring animal health and that include veterinary oversight or consultation."

Although some in the livestock industry are likely to criticize the report, the development of antibiotic resistant bacteria is (or should be) of particular concern to those in livestock production, where farmers, farm workers, and meat processors are particularly vulnerable and are already contracting resistant infections.

The Pew Commission on Industrial Animal Production estimates that seventy percent of antibiotics are used in livestock production, most for increased growth production and disease prevention rather than treatment. The World Health Organization and many medical groups have long called for greater regulation to preserve antimicrobials for true public health needs.

While there are multiple causes underlying the development of antibiotic resistance, feeding livestock antibiotics and other antimicrobials at sub-therapeutic levels for growth promotion and to allow greater concentration of production is not a wise use of these critical weapons against disease. The public health risk is far too great.

The Guidance is available online on the FDA's website. Comments are requested. The Federal Register announcement will be published on June 29, 2010.

The Risks of Farming

I returned to our family farm this week for my annual summer visit. One of the first items on the Minnesota “to do” list was to visit the local pick-your-own fruit farm, Afton Apple for strawberry picking. In a short time, we picked four beautiful boxes of strawberries, and I was again struck by the sweet flavor and tender texture - so different from the ones shipped across country. When picking our berries, I tried to be a responsible picker, carefully getting all of the berries in my assigned row and even picking off and discarding some of the over-ripe berries that would tax future production. I hoped to return to the patch next week for a second picking.

That very night, storms moved through the area. Three inches of rain, some hail, and high winds hit hard and fast.

I called Afton Apple this morning to check their recorded message about the crop. Gone was yesterday’s cheerful message declaring that “strawberry picking is great and the berries are excellent.” The new message announced that “because of the hail and wind, we lost the crop tonight. . . The strawberry season is over.”

A sad reminder of the vulnerability of crops and another reason that farming is a different kind of business.

Challenges to Agricultural Policy: Diet

Two issues are certain to change American agriculture. There are questions about timing - how fast or how slow policies will change and agriculture will adapt. And, there are questions about how the changes will occur, who will benefit and who will lose. But these two issues - health and energy - are two of the most important challenges to confront our society. And agriculture is right in the middle of each one. This post addresses the first - the issue American health and our diet.

The 2010 Dietary Guidelines Advisory Committee, established jointly by the Secretaries of USDA and HHS was charged with reviewing the current U.S. Dietary Guidelines and recommending updates. The committee's report, 2010 Dietary Guidelines for Americans was released yesterday.

For the first time, the report confronted an American public of whom the majority are overweight or obese and yet under-nourished in several key nutrients. The recommendations could have been taken from a Michael Pollan book -

On average, Americans of all ages consume too few vegetables, fruits, high-fiber whole grains, low-fat milk and milk products, and seafood and they eat too much added sugars, solid fats, refined grains, and sodium. SoFAS (added sugars and solid fats) contribute approximately 35 percent of calories to the American diet.

Here are three of the main recommendations:

• Reduce the incidence and prevalence of overweight and obesity of the US population by reducing overall calorie intake and increasing physical activity.

• Shift food intake patterns to a more plant-based diet that emphasizes vegetables, cooked dry beans and peas, fruits, whole grains, nuts, and seeds. In addition, increase the intake of seafood and fat-free and low-fat milk and milk products and consume only moderate amounts of lean meats, poultry, and eggs.

• Significantly reduce intake of foods containing added sugars and solid fats because these dietary components contribute excess calories and few, if any, nutrients. In addition, reduce sodium intake and lower intake of refined grains, especially refined grains that are coupled with added sugar, solid fat, and sodium.

Compare this to Pollan's advice in In Defense of Food - "Eat food. Not too much. Mostly plants."

The report talks about the importance of all elements of government and society working together to attempt to shift dietary and lifestyle patterns away from our current dangerous path.

I submit that agricultural policy must come on board with this shift. We can no longer ignore the fact that agricultural policies favor the production of foods and food ingredients that are a significant part of the problem. Policies that have encouraged the overproduction of commodity crops such as corn have enabled the development of processed foods and meat products that are cheaper than and easier to acquire than the basic "plant-based foods" that we should be eating. Policies that are focused on the economic interests of those most powerful in the agricultural and food industries without a consideration of the overall food system that is created is part of the problem.

A coordinated strategic plan that includes all sectors of society, including individuals, families, educators, communities, physicians and allied health professionals, public health advocates, policy makers, scientists, and small and large businesses (e.g., farmers, agricultural producers, food scientists, food manufacturers, and food retailers of all kinds), should be engaged in the development and ultimate implementation of a plan to help all Americans eat well, be physically active, and maintain good health and function. It is important that any strategic plan is evidence-informed, action-oriented, and focused on changes in systems in these sectors.

The following recommendations, excerpted from the report should be included as primary goals of our future farm policy.

• For all Americans, especially those with low income, create greater financial incentives to purchase, prepare, and consume vegetables and fruit, whole grains, seafood, fat-free and low-fat milk and milk products, lean meats, and other healthy foods.
• Improve the availability of affordable fresh produce through greater access to grocery stores, produce trucks, and farmers’ markets.
• Increase environmentally sustainable production of vegetables, fruits, and fiber-rich whole grains.
• Ensure household food security through measures that provide access to adequate amounts of foods that are nutritious and safe to eat.

In a recent article, I called for an agricultural policy based on the goal of producing healthy, affordable food in a sustainable manner. A Reconsideration of Agricultural Law: A Call for the Law of Food, Farming, and Sustainability. This report supports that call.

The USDA is seeking comments on the report and a hearing will be held July 8, 2010.

Written comments can be submitted at www.dietaryguidelines.gov or mailed to Carole Davis, Co-Executive Secretary, Dietary Guidelines Advisory Committee, USDA Center for Nutrition Policy and Promotion, Room 1034, Alexandria, VA 22302.

To provide oral testimony at the July 8 public meeting, you must register by going to
www.dietaryguidelines.gov or by calling Crystal Tyler at (202) 314-4701 prior to 5 p.m. EDT on June 30. The meeting will be held in the Jefferson Auditorium in the USDA South Building, 14th Street and Independence Avenue, S.W., on July 8 beginning at 9:00 a.m. and ending not later than 5:00 p.m.

Food Propaganda

Salon delivers a great review some of the best/worst examples of food being renamed to match current political fashion - 10 tragic moments in food propaganda: From Freedom Fries to Mecca Cola. It offers examples from all political persuasions around the world and is billed as "a slide show of sadly politicized food to embarrass all eaters."

Well worth a look.

North Dakota Anti-Corporate Farming Law Decision

The North Dakota Supreme Court last month issued a decision related to the state's anti-corporate farming law, which I discussed over at Business Law Prof Blog. I hope no one minds the crosspost, but I thought it might be of some interest.

A Food Desert in the Delta

Tonight the PBS News Hour continued its reporting on the obesity epidemic, focusing on Mississippi, the state with the "highest rate of childhood obesity in the country [where] 44 percent of kids ages 10 to 17 are obese or overweight."

Tonight's report, In Mississippi, Growing Vegetables in a 'Food Desert' focuses on the delta region, and it considers the problem of "food deserts," areas where it is difficult to purchase healthy foods. Food in a "food desert" can often be found only in a convenience store, gas station or liquor store. That food is often highly processed junk food - high calorie, high fat, sodium filled chips and snacks. Grocery stores with a good selection of produce may be many miles away.

It is particularly ironic to find a food desert in the Delta - known for its prime agricultural soil. However, most of the farms in the Delta grow commodity crops that are shipped out of the region. And, despite the wealth of some of the large landowners, the poverty rate is among the worst in the country.

Enter, the local food movement and the re-education of people in the skills of gardening. A web feature on this last point is provided below.

The full report is now available at the News Hour website.