June 15, 2012
Hon. Louise Slaughter
Member of Congress
2469 Rayburn Building
Washington, DC 20515-3221
Dear Representative Slaughter:
[Company name] received your letter dated February 16, 2012 inquiring about
the use of antibiotics and the production of meat and poultry. Although [company name]
does not possess much of the information you requested I can provide you with the
following.
[Company name] supports the stringent Food and Drug Administration (FDA)
approval process for veterinary drugs, which was made even more vigorous with the
addition of significant FDA risk assessment requirements several years ago. We also
support the federal residue monitoring of all meat and poultry, which demonstrates the
cooperation among animal health companies, feed companies, producers, and
regulatory agencies to help ensure that antimicrobial products are used appropriately.
In order to maintain proper health and welfare of U.S. poultry flocks, poultry
producers diligently to manage their flocks through a combination of sound husbandry
practices, including genetics, nutrition, housing, handling, as well as veterinary care.
Poultry producers, working with their veterinarian, are in the best position to create the
animal health strategies and protocols on farms today. In short, optimal animal health
and welfare is not only good for poultry producers, it is good for the rest of the food
production chain, and it is essential to helping ensure a safe, affordable, and abundant
food supply.
[Company name] maintains rigorous purchase specifications with respect to the
poultry and/or poultry products that it acquires. We require our poultry suppliers to
utilize technologies and products, including the use of animal health products such as
antibiotics, in a judicious and appropriate manner. Given that FDA regulations provide
that labels of approved poultry drugs have a very clear “withdrawal time,” [Company
name] similarly has a specific policy regarding the administration of antibiotics to ensure
that these antibiotics have sufficient time to clear the birds system prior to harvesting.
To that end, we insist that our suppliers work closely with a trained veterinarian.
Indeed, the American Veterinary Medical Association has comprehensive guidelines
pertaining to the judicious therapeutic use of antimicrobials.1
Finally, the FDA regulatory requirements are becoming increasingly strict
regarding antibiotics in feed. In April 2012 FDA released Guidance for Industry #209,
which states that it is injudicious to use medically important compounds to improve
1
http://www.avma.org/reference/jtua.asp
production in food animals. Additionally, Guidance #209 provides that veterinary
oversight must be demonstrated for therapeutic use of these same antibiotics. This
Guidance in essence carries the weight of regulation and FDA has the authority to
implement these provisions. The effect of Guidance #209 is that using medically
important antibiotics in food producing animals for growth promotion purposes will
cease and the remaining therapeutic uses will be carried out under the guidance of a
licensed veterinarian.
[Insert any company specific responses to questions as appropriate.]
I hope this information has proven useful to you. If you have any questions about
the information provided above, please contact me.
Respectfully submitted,
[Company Representative]