Hog farmers in the United States continue to exhibit their commitment to preserving public health, animal health and animal welfare through responsible use of antimicrobials. Producers and their veterinarians are presently engaged in the evaluation of their on-farm animal health treatment practices and recordkeeping to ensure compliance with the enhanced Veterinary Feed Directive rule, which is slated to go into effect on Jan. 1, 2017. 

As these on-farm preparations are being completed, swine industry officials continue to be actively engaged in the dialogue surrounding the pending implementation of the Federal Drug Administration Guidance 213 document.

Released in December of 2013, the document is part of the three-year transition process to complete FDA’s food-animal antibiotic strategy. Guidance includes the request that animal health companies outline their voluntary intentions to remove any production-growth uses from their product labels of medically important antibiotics. The guidance also eliminates the over-the-counter use of these medications while increasing the veterinary oversight for on-farm therapeutic use antimicrobials. These changes include the Veterinary Feed Directive for feed and a prescription for water treatments. 

As part of this process, the agency has expressed interest in gathering more data on antibiotic use on the farm in addition to the excising sales data collected under the Animal Drug User Fee Act.

According to Liz Wagstrom, chief veterinarian at NPPC, “The importance of establishing clear objectives for data collection to the success of this expanded surveillance program cannot be overstated.”   

At a recent public meeting held by the FDA in conjunction with USDA and CDC focused on identifying potential sources of on-farm antimicrobial-use data, Wagstrom stated, “The swine industry has been in discussions with USDA and FDA about potential sources of data, and there has been significant discussion on what are the correct metrics as far as measurement of antibiotic use and outcomes of that use.

“Collecting information on gross pounds of antibiotics does not provide useful information,” Wagstrom said. “Basing decisions on gross pounds of antibiotics suggests that all antibiotics are of the same potency and of the same importance to human medicine.

“The identification of the correct metrics will help the industry and government officials clearly look at the public and animal health outcomes,” adds Wagstrom.

The pork industry continues to be involved in ongoing discussions with USDA and FDA on data sources, data analysis and data reporting.

Historically, the pork industry was the first industry to participate in National Animal Health Monitoring System studies. Along with that involvement, hog farmers have developed a level of trust with USDA’s Center for Epidemiology and Animal Health through this program.

Data confidentially essential

Data confidentially is essential to pork producers, and the ability of the CEAH to ensure their information is secure is essential to farmer trust and participation. It is for these reasons that NPPC officials have suggested that CEAH take the lead in data gathering, analysis and reporting. This data could be either collected by CEAH or be proprietary information that is shared with CEAH.  

The American Association of Swine Veterinarians expressed its continuing support for research and data collection in an effort to understand the role veterinary medicine may play in developing and maintaining antimicrobial resistance. 

The swine veterinarians’ primary objectives include support for enhanced National Animal Health Monitoring System, to evaluate on-farm use relative to resistance findings at the plant and in retail meat samples. In other words, identify, if any, the patterns of use on-farm that contribute significantly to resistance findings at the plant or in retail meats.

The organization also suggests the on-farm data collection should determine what impact on-farm antimicrobial use has on resistance contributing to increased illness in the human population and explore how on-farm antimicrobial use contributes to enhanced food safety.

Regarding the issues of on-farm antimicrobial-use data collection, the AASV encourages FDA to define the specific objectives of on-farm data collection and the particular pathogens and resistance patterns to be monitored before any data collection protocols are developed.

AASV also notes USDA has proposed a series of projects that would explore on-farm use through longitudinal, cross-sectional, prospective and proprietary data collection.

They, with other stakeholders, have worked with USDA on developing these projects to achieve meaningful collection, analysis and interpretation of use data so as to meet common objectives.

While many of the details of the data-collection system are still unknown, one major outstanding issue is funding for the program. Government officials as well as industry representatives are concerned that funding has not been secured to continue the development of the on-farm data collection.

Wagstrom said there is some concern that there is inadequate funding to expand the NAHMS and CEAH programs with the existing infrastructure to collect the on-farm data. “The funding issue is a concern for pork producers and other interested parties. We hope that the necessary appropriations will be made soon to allow these programs to proceed,” said Wagstrom.

In his remarks at the meeting, John Clifford, chief veterinary officer and the Animal and Plant Health Inspection Service deputy administrator for veterinary services for the USDA, spoke about the importance of the One Health concept.

“The One Health concept maintains that human health, animal health and environmental health are inextricably connected,” said Clifford. “Although this meeting is focused on antibiotic-use data collection, we recognize that incorporating that data stream with antimicrobial resistance and other information is needed to provide an accurate picture of the epidemiology and ecology of the situation that allows for the development of critical mitigation strategies.”

Clifford stated that the USDA and others recognize that the One Health approach is needed to prevent, not just react to, complex public and animal health issues. In his remarks he also noted that funding would be necessary to carry out these efforts.

The pork industry has long been a leader on the issue of antibiotic use in pork production. In the mid-1990s, Paul Sundberg led the NPPC team assigned to address the issue of antibiotic use. 

“The argument pertaining to public health concerns and about antibiotic use has not changed,” says Sundberg, now the executive director of the Swine Health Information Center. “Antibiotic residue and how it could affect public health was the main issue at that time.” 

NPPC led the efforts to expand what little science was available on antimicrobial residues.

The original Pork Quality Assurance Program was created to educate producers, and also to help reassure the public that the pork industry was working to address their concerns on the farm.   

“It took some time to put the program together, but producers understood how this would be an important tool to help them better understand what production changes were needed to address the antibiotics residue issue,” says Sundberg. 

NPPC noted in its written comments on data collection that the Pork Quality Assurance program has evolved over the past 26 years, from a program focused largely on avoidance of volatile residues to become the industry’s cornerstone tool for producer education on antimicrobial use and other facets of pork safety and production practices.

Today more than 56,000 producers and 28,800 youth are certified as having received education on PQA Plus.  Additionally, more than 16,000 sites have been assessed on their compliance with the PQA Plus production practices, including demonstration of a veterinary-client-patient relationship and adequate treatment records.

Jennifer Koeman, D.V.M., National Pork Board director of producer and public health, says the recordkeeping of on-farm antibiotic use will be pivotal in the success of the new Veterinary Feed Directive and prescription requirement for water-based medications.

“It’s a critical step, but one most producers should be familiar with, thanks to their certification in the Pork Quality Assurance Plus program. However, requirements like keeping original copies of VFD for two years will be an adjustment.

“PQA Plus outlines the principles of responsible antibiotic use,” continues Koeman. “Producers have a long history of using antibiotics responsibly. With the PQA Plus principles already in place, we are well in line with the new FDA regulations.”

Koeman notes, “One of the other areas of focus will be to encourage producers to start working with their vets to develop alternative strategies and create whole-herd health plans.  We all know that in some situations antibiotics are necessary. However, it is possible that the creation of a whole-health strategy may help them minimize their antibiotic usage.”

NPPC and other industry stakeholders believe that as producers adapt to the changes in on-farm recordkeeping for the new VFD they will be well equipped to adopt to any changes that may be required to comply with any new antibiotic data collection provisions that are a result of the reporting provisions of Guidance 213.

Three point plan

In October, the NPB announced the adoption of a three-point plan of action focused on five research priorities, shaping educational outreach to pig farmers and broadly sharing information with the retail and food-service industries and consumers.

The research point includes investing $750,000 in new research projects intended to provide data for animal and public health outcomes. These projects will be focused on pig health-welfare, human health-safety, environmental impact and pork quality.

Updating the Pork Quality Assurance Plus farmer certification program in 2016 is the second point of the plan and includes investing up to $400,000 in education and awareness programs to ensure pig farmers understand and adopt new FDA rules for the use of medically important antibiotics (to treat human illness) in feed and water.

The final point in the plan includes expanded communication, such as gathering industry leaders for meetings on responsible antibiotic use and sharing the U.S. pork industry’s story of continuous improvement with producers and consumer media through outreach, byline articles and advertisements.

According to Mike King, director Pork Checkoff Science Communications, the pork checkoff recently kicked off its new 12-month producer awareness campaign, “Don’t Wait ... Be Ready.” It will serve as a constant reminder for producers to start making plans now to ensure their operation will be in compliance with the VFD rule on Jan. 1, 2017.

Along with the “Don’t Wait ... Be Ready” message, pork producers and industry partners can expect to see the new acronym USCARE. King says the acronym was created to outline the steps producers will need to complete in 2016 to be in compliance with the new regulations (see graphic on Page 26).

One of the other messages pork producers and consumers place emphasis on is the One Health concept.  As John Clifford noted in the FDA public meeting, it is important to embrace the One Health concept not just as a response mechanism, but also as a means to create new prevention. 

One Health umbrella

Because antibiotic resistance is a global concern, the One Health approach to combat antibiotic resistance is critical to human and animal health. One Health is a collaborative effort of multiple stakeholders to attain optimal health for people, domestic animals, wildlife, plants and the environment. Medical doctors and patients, veterinarians and farmers are cooperating together with government, academia and industry stakeholders.

Pork producers play an important role in the shared effort to use antibiotics responsibly to help minimize the potential emergence of antibiotic-resistant bacteria. In the end, this comprehensive and inclusive approach will protect both human and animal health.

Pork industry stakeholders expect the methods of and rules for on-farm data collection to be developed in early 2016 as part of the FDA’s intent for implementation of Guidance 213 in accordance with its three-year transition process to complete its food-animal antibiotic strategy.  

Philippi owns and manages Philippi Farms LLC, and is a photographer and writer working out of the Washington, D.C., area.