Mike Apley on AMGP The points brought up certainly have covered the overall complexity of this issue. Growth promotion is the first and most easily contested use by activists, and arguably the least defensible of all our uses. In cattle my count of straight growth promotion claims includes monensin, lasalocid, laidslmycin, bacitracin zinc, bambermycins, with no defensible relationship to human medicine) and chlortetracycline, oxytetracycline, neomycin/oxytetracycline, sulfamethazine/oxytetracycline, and virginiamycin (with arguable connections to human therapeutics). Many of these also have other regimens for prevention or treatment of a disease. The activist-proposed links have moved well beyond direct zoonotic transfer or even direct selection of a resistant population by use of an antibiotic in animals. The political surge now is to propose a food animal contribution to a "resistance reservoir" in the human community that contributes to human resistance that will then be transferred to pathogenic bacteria that will be selected for by use in human medicine. This is the perfect argument to drive the precautionary principle forward in the U.S. You can't really prove it, but try and disprove it. The real issue for us (as an entire food animal industry) is the ability to prevent or control disease through feed/water applications. The political push on this front is to blame our need for these uses on the structure of our industries. I don't think the growth promotion claims are worth much effort, but the disease prevention/control claims are definitely worth the fight, and what about therapeutics? So, why not just cut a deal where PAMTA just addresses growth promotion claims and not prevention/control claims and get on with life? Because they will be back for the next incremental step, and the next. Washington D.C. is run by 20-something staffers that have grown up on conspiracy theory TV and are very receptive to arguments that big, evil agriculture is pumping toxins into their brains. They do the research for their bosses and control access of who gets to interact with the representatives/senators and glean the information that is considered. And what better to get your constituency behind you than to joust the windmill of agriculture? The PEW foundation has masterfully crafted a report they are using to drive PAMTA lobbying knowing that 99% of the people will never check their references for actual support of their assertions, nor take time to look at what they have omitted. That is why the UCS 70% number survives in DC; nobody has the expertise or desire to actually investigate such a wonderful, juicy piece of damning information on an industry. And PEW has taken their first step, in a letter to the editor in JAVMA, to undermine credibility of anyone doing research that is industryfunded. Slant the data, claim to be all inclusive, discredit any people disagreeing with you, divide and conquer ("your industry has the fewest problems"), and work the staffers and representatives/senators on the hill. Pretty good strategy actually. I have struggled with this greatly. Could standing up against PAMTA and the precautionary principle lead to stalling removal of antibiotics used in agriculture that are causing treatment failures in human medicine? I'll tell you my opinion, if this exists, it isn't from lowlevel growth promotion use. And yes, I think there are some things we are doing that are unwise in the long run. Let's look at it from another angle, would giving in to activist spin and giving up uses without sufficient evidence set a precedent that activist groups can just wear us down in an incremental fashion? How about 5 years from now when a new antimicrobial that could dramatically effect disease and suffering in food animals is shown to have no demonstrable adverse public health effects but the approval is rejected because "you never know". How willing are we to accept activist groups and ballot boxes as the determinant of what we have to address disease in food animals? Are we willing to work under a demand for zero risk by activists? In my opinion, the FDA, EPA, and USDA are being empowered as rogue states by the current administration, seeking to bypass legislative oversight (let me be clear that I am not implying that all the people in these agencies are with this plan). To fold up now, in this environment, would be to set a precedent for the uninformed, sound-bite dependant media to drive our decision process. I don't want to spend time defending strict growth promotion uses of antibiotics, and I don't think it is the best use of compounds used therapeutically in human or veterinary medicine. However, I will fall on the sword of demanding sound reasoning for what we do, as well as demanding that all parties play straight with the data. These issues are inseparably entwined. I'm in it for the process, because the process we settle for now will be the process we have when the issue becomes preventive/control uses (actually already is), therapeutic uses, and the structure of our industry. I try not to be a conspiracy theorist or a slippery slope guy either, but we cannot stand for an erosion of a scientific process in determining our ability to treat diseases in food animals. And our opponents aren't trying to erode it, they are trying to remove a large chunk of it. Mike Mike Apley, DVM, PhD, DACVCP Professor, Dept. of Veterinary Clinical Sciences Director - PharmCATS Bioanalytical Laboratory 111B Mosier Hall Kansas State University Manhattan, KS 66506 mapley@vet.ksu.edu Office 785-532-4167 PharmCATS - 785-532-6335 Fax 785-532-3909