Peer Benchmarking
Antibiotics
July 25, 2012 – DRAFT
Peer & Competitive Benchmarking
Antibiotic Positions
• Large Processors
& Suppliers
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Cargill
Tyson
JBS Swift
Seaboard
Prestage Farms
Hormel
Sara Lee
Smithfield
• Niche Processors
– Applegate Farms
– Coleman Natural
Foods
• Restaurants
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McDonalds
Burger King
Wendy’s
Compass Group
Wolfgang Puck
Bon Appetit
Starbuck’s
Panera
Chick-fil-A
Arby’s
Chipolte
YUM! KIF, Taco
Bell and Pizza
Hut
– Subway
• Grocery
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Walmart
Kroger
Supervalu
Target
Safeway
Wegman’s
Whole Foods
Glossary of Terms
• Antibiotic: A substance produced by microorganisms that kills or
inhibits other microorganisms
• Therapeutic: Treatment, control and prevention of bacterial disease
• Sub-therapeutic: Administration of an antibiotic at a low level for an
extended period of time to promote growth and prevent illness in
animals
• Antimicrobials: An agent that kills bacteria or suppresses their
multiplication or growth. This includes antibiotics and synthetic agents.
It exclused ionophores and arsenicals.
• Antiobiotic resistance: A natural biological process that enables
bacteria to outmaneuver the very drugs designed to kill them.
– Is transferred via two methods:
• Intrinsic transfer, in which pre-existing resistance only is transferable to the progeny
of a bacteria
• Acquired, which develops through mutations or from DNA transfer among bacteria
• Medically important antibiotics: Antibiotics used in both animal and
people that are important to treat human infections
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Four categories of FDA-approved
food animal antibiotic uses
Disease
Treatment
Disease
Control
Disease
Prevention
Growth
Promotion
Administered
only to animals
exhibiting signs
of disease
Administered to
a group of
animals when a
proportion of
the animals in
the group
exhibit clinical
signs of disease
Administered to
a group of
animals, none of
which are
exhibiting
clinical signs of
disease, in a
situation where
disease is likely
to occur if the
drug is not
administered
Administered to
growing, healthy
animals to
promote
increased weight
gain. Such uses
are typically
administered
continuously
through the feed
or water in a
herd- or flockwise basis.
The FDA considers treatment, control, and prevention all to be
"therapeutic" uses targeting a specific disease or agent, whereas
growth promotion is what some call a "sub-therapeutic.“
Where does Oscar Mayer belong?
Public positions on antibiotics
Offers choice
Antibiotic-free
Only used to prevent,
treat & control disease
Comply with FDA
guidelines
*
*Residue-free, no hormones added (which in pork isn’t
allowed any ways)
CBS News reports on costs
• “Meat prices in Europe have not risen dramatically
since the EU's ban. Danish authorities estimate the
total costs for pig farmers increased by just 1 percent,
or about $1.35 for every pig slaughtered -- far below
food industry estimates.”
• “U.S. health experts suggest the increase here would
be modest, too. The Institute of Medicine, a nonpartisan nonpartisan group of medical experts who
advise the federal government on public health issues,
estimates the average U.S. consumer would spend
between $5 and $10 more per year on meat if
antibiotics were restricted.”
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Position: Antibiotic-free
• No antibiotics, EVER! (Whole Foods)
• “First national restaurant company to serve 100%
naturally raised meat, all of which comes from animal
that are raised in a humane way and never given
antibiotics or added hormones.” (Chipolte)“
• Do, on occasion, incur unpredictable and short-term
supply disruptions
• “Strives to provide ‘clean” food at a reasonable price…”
(Panera)
• Serves antibiotic-free chicken
• Added some antibiotic-free roasted turkey
• Serves a growing portion of pork products
• “Does not sell any meat that was produced with
antibiotics” (Applegate Farms)
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• “Works with a network of nearly a thousand family
farmers who use common-sense animal husbandry
practices like a clean environment, enough space and
100% vegetarian diet, and as a result, we’ve managed to
have less than 1% of our producers’ animals fall ill.”
Position: Antibiotic-free
• Raised add’l concerns (Bell&Evans):
– DDGS: Estimates are that more than 50% of all
US ethanol plants use antibiotics to control
bacterial contamination. There is concern that
not all antibiotics are metabolized during
production and remain in the DDGS protein, and
so the animals may be ingesting add’l antibiotics
– Hexane gas: Commonly used process that
separates oil and vitamins from soybeans. EPA
categorizes hexane as hazardous air pollutant
and residuals potentially remain in the meat
– Arsenic: Arsenic-containing animal feed
additives have been used in poultry. FDA found
small amounts in chicken livers (the
International Agency for Research on Cancer
determined inorganic arsenic is carcinogenic to
humans).
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Position: Aims to reduce
“routine use” of antibiotics
“Seeking to reduce its purchasing of products raised
with routine usage of antibiotics, and now offers its
guests poultry and beef products that are produced
without routine use of antibiotics.”
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Position: Offer consumer choice
• Provide a wide variety of fresh and frozen choices,
including antibiotic-free products for our customer who
want them and understand why there may be a higher
price
• Shows a detailed chart that outlines which products are
produced without antibiotics, antibiotics only for disease
treatment, antibiotics for treatment and control and routine
use of antibiotics (Wegmans)
• All meat is free from unacceptable levels of residues,
whether the antibiotic was administered for disease
treatment or disease control (Wegmans)
• Supports responsible use which includes
• Supports all FDA, USDA guidance (withdrawal times, random
residue testing)
• Under supervision of certified veterinarians
• Witholding antibiotics from sick animals is nhumane and
doesn’t comply with our animal welfare program
• Safeway’s Rancher’s Reserve Beef Program – animals
removed from the program if antibiotic treatment
administered twice in animal’s life span
• Current limitations are due to “limited availability of raw
materials” (Safeway)
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Position: Only used to prevent, treat,
control illness; no growth promotion
• Antibiotics used for three purposes
(Smithfield/pork):
• Prevent disease
• Control disease
• Treat disease
• Not continuously fed
• Not used for growth promotion purposes
• Small portion of hogs raised without antibiotics for
niche market (pay up to 30% more) (Smithfield)
• Does not permit use of antibiotics for growth
promotion or to improve feed efficiency (Chick-fila; YUM! Brands (verified through annual supplier
certification process); Burger King – 100% for
chicken; beef and pork are not known due to the
fact that the animals come from thousands of
farmers )
• Working with suppliers to ensure that these new
FDA recommendations are fully reflected in
supplier practices (Yum! Brands)
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Position: May not use human antibiotics
in animal growth promotion
• Disapproved the purchase of poultry in which
antibiotics that belong to classes of compounds
approved for use in human medicine have been
used for growth promotion (Compass Group)
• Expect products which adhere to specific criteria
developed in partnership with Environmental
Defense Fund. Has guidelines in pork regarding the
use of non-therapeutic antibiotics – supplier is
gradually reducing use (Compass Group)
• Suppliers much meet our policy or present a plan
on how they will work with us to achieve our goals
in the future (Compass Group)
• Preference is to use antibiotic-free meat whenever
possible. In Feb 2012, initiated commitment to
source 25% from Certified Humane sources
(Compass Group/Bon Appetit)
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Policy: Restricting Antibiotic Use
McDonald’s global minimum standard prohibits the use of antibiotics
belonging to classes of compounds approved for use in human medicine
when used solely for growth promotion purposes. This applies to all
global suppliers where McDonald’s has a direct relationship in the meat
purchasing supply chain process. Today, this means that poultry
suppliers and our direct-relationship poultry suppliers (approximately
60% of our poultry supply) around the world acknowledge their
compliance with our antibiotics policy.
For suppliers with whom McDonald’s does not have a direct relationship,
compliance with this policy is a favorable factor in purchasing decisions.
Some McDonald’s markets have government regulations that supersede
McDonald's policy. In Europe, for example, use of antibiotics for any
purpose other than disease treatment or prevention is prohibited for all
products.
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Key Policy Aspects
• Recognize importance of antibiotics for
food animals and the need to combat
antibiotic resistance and supports work
on sustainable use of antibiotics
• Input from physicians, suppliers,
animal welfare scientists, veterinarians,
retail representatives and
environmental experts
• Key points:
– Limits sub-therapeutic use of certain antibiotics
to promote growth in livestock.
– Prohibits the use of antibiotics belonging to
classes of compounds approved for use in
human medicine when used solely for growth
promotion purposes
– Enforced through supplier certification and
assurance programs or regular audits.
– Gave suppliers 18 months to phase this in (June
2003 – Dec. 2004)
• Knows that scientific understanding
about antibiotic resistance continues to
grow, will adjust policy
as necessary
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Guiding Principles
for Sustainable Use of Antibiotics
• Quality & safety
• Animal welfare
• Antibiotics for animals
• Supervise use
• People first
• Limit exposure
• Record keeping
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Guiding Principles
for Sustainable Use of Antibiotics
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Position: Use according to
FDA’s regulations
• Food safety is our top priority
• Complies with all applicable laws and
regulations (FDA, USDA and FSIS)
• Support best practices and where
applicable “require suppliers”
• Meet or exceed government regulatory
requirements (Hormel increased monitoring
of residues)
• Expects suppliers look to industry
assurance programs
• Supports the changes being implemented
by FDA (phase out sub-therapeutic use and
phase in veterinary oversight for all
medically important antibiotics)
• Hope to identify new practices that could
eliminate their use
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Using but Following FDA’s Regulations
• Respectfully disagrees with premise of Rep.
Slaughter’s position on antibiotic use in animal
agriculture. According to the American
Veterinary Medical Association, “based on
available science, the likelihood that human
consumption of animal products will lead to an
infection with resistant organisms is negligible”
and “there is little to no evidence that restricting
or eliminating the use of antimicrobials in foodproducing animals would improve human health
or reduce the risk of antimicrobial resistance to
humans.”
• Discontinued use of fluoroquinolones (2002)
• According to AVMA, many antimicrobials used in
human medicine are not approved for use in
animals or are, quite simply, too expensive to
use in animals.
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Lessons learned
in labeling
• As early as May 2007, Tyson was at
the forefront of the antibiotic trend
and introduced chicken “raised
without antibiotics”
● By fall, USDA officials reversed their
position, stating the Tyson’s chicken feed
ingredients including ionophores,
commonly used antimicrobials
● The USDA and Tyson eventually agreed on
a modified label that stated "raised without
antibiotics associated with human
resistance”
● Several competitors sued Tyson and
initiated a class action lawsuit.
● Ultimately, Tyson agrees to settle
lawsuit for falsely advertising its
“raised without antibiotics” chicken
brand ($5 Million) and voluntarily
withdraws label (June 2008)
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Chicken Policy
• Tyson Foods only uses feed ingredients approved by the U.S.
Food and Drug Administration (FDA) and administers them only
according to veterinary assessments and under veterinary
supervision. Each flock of birds and grow-out location typically
has different animal health needs. As a result, we may use
different animal health products and feed formulations at
different locations, according to the birds’ needs. Just like our
finished product recipes, our feed formulations are proprietary
and may vary from complex to complex, and even
seasonally. We do not disclose specific feed formulations for
specific grow-out locations to the public. However, we can say
that all FDA-approved antibiotics and antimicrobials may
sometimes be used by Tyson Foods for the well-being of our
chickens.
• Tyson Foods also complies with federal regulations prohibiting the
use of added hormones or steroids in any chicken product.
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Beef and Pork Policy
It is a violation of Federal Food, Drug and Cosmetic Act (FFDCA) to sell
livestock for slaughter that may contain drug residues or chemicals that
exceed tolerances in meat established by the U.S. Food and Drug
Administration (FDA). The U.S. Department of Agriculture’s (USDA) Food
Safety Inspection Service (FSIS) Residue Monitoring Program tests meat and
animal organs to ensure that livestock producers have followed safe
production methods regarding any pharmaceutical use. USDA inspectors
visually check each animal at the packing plant for signs that they were
managed with safe production methods regarding use of veterinary drugs and
hormones. In the rare instance of a violative drug residue finding, the animal’s
carcass and all parts are condemned. In such cases, USDA notifies FDA of the
violation, and FDA in turn contacts the livestock producer.
Tyson Fresh Meats supports the efforts of the National Cattlemen's Beef
Association (NCBA) and the National Pork Producers Council (NPPC), which
stress the importance of producers controlling drug residues in their livestock.
A unified commitment to animal health helps maintain the critical balance
between ensuring the needs of our animals are met and providing our
customers and consumers with the quality food products they deserve.
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Associations
• Antibiotics are stringently regulated and
judiciously used
–Safety assessment is more stringent
than for human antibiotics
–Risk to human health is vanishingly
small (reverse pyramid – next slide)
• Animal use contributes little, if any, to
the burden of human antibiotics
resistance
–Examination of specific resistant
bacterial challenges are the biggest
problems in clinical healthcare settings
• Antibiotics is among several tools used to
help enhance food safety
• Decisions must be made based on science
and risk assessment
Industry position: “Risk to human
health is vanishingly small”
Illustration from trade associations letter to
Rep. Slaughte (June 2012)
http://www.louise.house.gov/images/stories/Master
_List_Responses_FINAL_FINAL.pdf
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EXTRA SLIDES
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Medically important antibiotics that are
approved for use as growth promotants
• Carnevale estimated that medically important
antibiotics make up roughly half of the total volume of
antibiotics used in food animals (Richard Carnevale,
DVM, the AHI's vice president of regulatory, scientific,
and international affairs)
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CBS News reports on costs
• Meat prices in Europe have not risen dramatically
since the EU's ban. Danish authorities estimate the
total costs for pig farmers increased by just 1 percent,
or about $1.35 for every pig slaughtered -- far below
food industry estimates.
• U.S. health experts suggest the increase here would
be modest, too. The Institute of Medicine, a nonpartisan nonpartisan group of medical experts who
advise the federal government on public health issues,
estimates the average U.S. consumer would spend
between $5 and $10 more per year on meat if
antibiotics were restricted.
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