Health Canada (HC) and the Canadian Animal Health Institute
(CAHI), the trade association representing Canadian veterinary drug
manufacturers, are to be commended for their decision on April 10
to follow the American initiative to address the growing concern
over antimicrobial resistance in humans by introducing measures to
promote the more prudent use of antimicrobials in animal
production. HC announced its intention (1) "to work towards
the removal of growth promotion and/or production claims of
medically important antimicrobial drugs" and (2) "to
develop options to strengthen the veterinary oversight of
antimicrobial use in food animals."
Contrary to many mainstream media reports, this does not mean
that Canada is phasing out antibiotic use in meat production.
Moreover, both initiatives face several difficult barriers to
implementation. This month we look at the difficulties associated
with the first proposal, leaving next month for an analysis of why
the oversight role by veterinarians must be strengthened if we are
ever going to make real progress on what may be the most serious
public health problem of our time.
First some law. The licensing and sale of antimicrobials fall
under the jurisdiction of the federal government and its Food and
Drugs Act, but the authority to manage their "use" lies
with the provinces. The provinces also have the exclusive authority
over the practice of veterinary medicine. What this means is that
HC can require that a vet drug no longer have "growth
promotion" as an indicated use on its label, but under the
current regime it has limited power to actually determine how the
drugs are used.
The issue of preventing growth promotion claims, and whether
such a step will actually make a real difference, is a complex one.
To begin with, most antibiotics are not actually used directly for
growth promotion purposes but rather for disease prevention and
control, what is often called disease prophylaxis. Removal of
growth promotion claims will not prevent drugs to claim and be used
for disease prevention. Farmers can continue to give their animals
low doses of antibiotics to keep them from getting sick. The Public
Health Agency of Canada, estimating that 90 per cent of the
medication on farms is used for disease prevention, argues that
antimicrobials should not be used in this way and should be
"limited to treating infection and not long-term mass
medication for growth promotion or guarding against disease."
Others argue that there is insufficient science to support the
conclusion that low doses given to animals contribute to
antimicrobial resistance in humans and that outlawing the practice
would result in more animal disease and the need for more drugs for
disease treatment, possibly exacerbating the problem of
antimicrobial resistance. When the science is uncertain, policy
development is always difficult.
What is clear is that the proposal will not even apply to a
large amount of antibiotic use because of regulatory loopholes that
result in part from our jurisdictionally fragmented regulatory
framework. Our provinces still allow veterinarians to prescribe
drugs for purposes not indicated on the product label (extra-label
use). Unapproved drugs may be used on animals because it is still
legal for drugs to be imported for livestock production "own
use" (OUI) if the drug is not offered for resale and it is not
a prescription drug. As well, Active Pharmaceutical Ingredients
(APIs) can still be imported by livestock producers to be mixed
into feed on farm. None of these unregulated antibiotics are
covered by the proposal. The latest Canadian Medical Association
Journal contains a critical assessment of Canada's performance
in enhancing antimicrobial stewardship in agriculture and
veterinary medicine, but it does state that HC has recently
proposed measures to address OUI and API so, hopefully, reforms may
As we shall see next month, none of the barriers described above
can be adequately tackled without Canada's veterinarians and
their provincial regulatory bodies taking a greater leadership role
in combating the serious and growing problem of antimicrobial
resistance in humans. Nowhere is the concept of One Health more
Originally published in Food in Canada.
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