Animal Welfare Approved

Certified Animal Welfare Approved by AGW Position Statement on Antibiotics and VCPr

Certified Animal Welfare Approved by AGW (AGW) is concerned about the rising public health crisis posed by the unbridled abuse of medically important antibiotics in industrial farming systems—and the resistance to antibiotics that these systems foster.

In the U.S., we use more antibiotics per pound of meat produced than any other nation. Over 80 percent of all antibiotics produced in the U.S.—29.9 million pounds in 2011 alone—are used in industrial livestock farming. Almost all intensive farming operations will administer routine low or “sub-therapeutic” doses of antibiotics to their animals via animal feed or water—whether they need them or not. But these drugs are not used to treat individual sick animals: they are used to prevent these intensively farmed animals from succumbing to sickness as a result of the overcrowded, stressful and insanitary conditions and to artificially maximize growth or productivity. Scientists around the world, including the U.S. Centers for Disease Control and Prevention, now emphatically link this non-therapeutic abuse of antibiotics in farming to the dramatic rise in life-threatening antibiotic-resistant bacteria in humans.

Over recent years, AWA has put significant resources into raising awareness of the growth of antibiotic resistance and promoting alternative livestock production systems that do not rely on the sub-therapeutic use of such drugs. AWA is a supporter of Congresswoman Louise Slaughter’s Preservation of Antibiotics for Medical Treatment Act (PAMTA), a vitally important legislative proposal which would ban the use of eight major classes of antibiotics on healthy livestock, while allowing exceptions to treat sick animals.

The Food and Drug Administration (FDA) is currently working on plans to phase out the overuse of some classes of antibiotics when these are given to animals in food and water. The problem is that the FDA’s proposals are reliant on an entirely voluntary agreement with the pharmaceutical companies that manufacture antibiotics. But while the voluntary nature of the FDA’s plans is clearly of grave concern, some of the well-meaning but misguided options proposed by certain public health groups to strengthen the FDA’s proposals are equally problematic.

Currently, many farm antibiotics are available “over the counter” in the U.S. This means anyone can go into a feed store and buy what they want—despite the fact that other medication for livestock can only be given under the direction of a veterinarian. Some public health groups are now proposing new rules which would require what is known as a “Veterinarian-Client-Patient relationship” (or a VCPr) before farmers can use any antibiotic (not just in feed and/or water).

According to the American Veterinary Medical Association (AVMA), a VCPr requires that (among other things) the vet has sufficient knowledge of the animals concerned to be able to diagnose the medical condition, and that the vet must also be personally acquainted with the keeping and care of the animals to be treated. This must be by virtue of a timely examination of the animal(s) by the vet, or medically appropriate and timely visits by the vet to the operation where the animals are managed.

On the face of it, the proposals to require a VCPr might seem like a sensible and straightforward option to help reign in the abuse of antibiotics in intensive farming. However, there is one fundamental problem with this proposal: there are not enough vets working with farm animals in the U.S. to make it workable. In fact, in some huge swaths of the U.S. there are no farm vets at all. While worthy in intent, the proposal to introduce VCPr is simply not a viable option at present.

A similar problem arises with the proposal by the same public health groups to prohibit all in-feed or water medication on farms. Again, as most abuse of antibiotics takes place with the mass routine dosing of animals via their feed and water, this proposal seems reasonable at first—until you realize two key facts. First, even the best-kept and well-managed pasture-raised, high welfare animals can still get sick and require treatment. Second, for certain diseases in certain species of animal (particularly flocks of poultry) the most appropriate and effective treatment is in-feed or water.

AWA is considered an expert voice regarding high-welfare, environmentally sound food animal production and works with thousands of farms across the U.S. and Canada. As of today, if the proposed VCPr is successfully introduced, it is fair to say that many of the pioneering farmers who use sustainable and alternative systems of livestock production would be faced with the appalling choice of either letting animals suffer for lack of veterinary oversight or breaking the law and treating their animals without a vet’s input.

In 2008, AVMA stated that only 10–15% of qualified vets were involved in promoting the health and welfare of animals that will eventually become food. Since then, the situation has certainly not improved—and has more likely got worse.

As the leading certifier of high-welfare, sustainable farms in the U.S., AWA standards initially required that every farm must have contact with a vet for health planning and management. However, we quickly discovered that many farms had no access to a vet with experience in the species of livestock and type of system they ran—that is if they had access to a vet at all. We also discovered that many of our farmers had worked on innovative ways to access advice on the health of their animals, although such solutions might include vets from different states or advice from extension agents or mentoring from other experienced farmers and advisors. The AWA standards therefore now require all farms to have access to a qualified expert, defined as a “person who has a comprehensive and authoritative knowledge of livestock in pasture based systems.”

As well as access to expert advice and the production of a health plan, AWA standards define systems of management that lead to good health. AWA farmers must have low animal stocking densities and manage pasture or foraging area access in ways that ensure the pasture/vegetation is rested and rotated. AWA standards also prohibit the sub-therapeutic use for any drugs—including antibiotics. When sick animals are treated, AWA farmers must apply double the legal withdrawal time before marketing the animal under the AWA logo. This approach not only allows the treatment of a sick animal while simultaneously reassuring consumers that the risk of any residue is almost non-existent, but also ensures that the efficacy of antibiotics—for both humans and livestock—is maintained.

We are proud to say that our farmers are as good as it gets today. AWA does not penalize a farmer for treating a sick animal—unlike organic standards and the new green-washing marketing term, “antibiotic-free.”

In summary, AWA’s position is as follows:

  1. We believe, as was stated in our recent TEDx presentation, that antibiotic-resistant bacteria present one of the gravest threats to human health and represent the worst unintended consequence of the intensification of livestock production.
  2. We believe that we must have a qualified expert overseeing antibiotic use on farm animals.
  3. We believe ultimately that expert must be a qualified vet, once there are sufficient qualified vets available in the field.
  4. We also believe ultimately there must be VCPr before antibiotics are used, again once there are sufficient qualified vets available to support this approach.
  5. Confinement feeding operations are the real cause of antibiotic-resistant bacteria—not farmers raising animals sustainably outdoors on pasture or range.

Why Shouldn’t You Support the Proposals for a VCPr?

  1. There are insufficient numbers of farm animal vets in the U.S. to make the VCPr proposals workable. Currently, there are vast swaths of the U.S. without any veterinary support whatsoever.
  2. Where veterinary support does exist, the individual vets may not be prepared to carry out farm visits for small/alternative species farms.
  3. Smaller sustainable farms may be working on tight margins. Contracting the services of a vet can be very expensive—particularly when all you need them to do is tell you something you might already know.
  4. The real risk for antibiotic abuse is not extensive, pasture-based systems, nor organic farms. The real risks are from the industrial confinement operations (CAFOs) where sub-therapeutic antibiotics are routinely being misused to prevent the inevitable outbreak of disease or to maximize growth or productivity.
  5. Dairy cows with mastitis may genuinely need a dose of antibiotics to treat them. In fact, there are very few alternative treatments for certain types of mastitis that are efficacious. A competent dairy farmer is more than capable of diagnosing and treating in the absence of a VCPr. Huge CAFOs rarely have experienced farmhands, but they have the money to employ vets. Sustainable systems generally have hugely experienced livestock managers—but not vets. Let’s not penalize the sustainable farmer.

Why Shouldn’t You Support the Proposals for a Blanket Prohibition on In-Feed Medication?

  1. For certain diseases, and in certain species of animal, the most appropriate and effective treatment is in-feed or water. Poultry live as a flock. Even high-welfare, pastured birds spend a lot of time together. So if one gets sick, generally the problem will go through the flock. Therefore any prescribed treatment for one individual is often treatment for all, or you risk treating one and watching the rest fall ill.
  2. The same is true of other groups of animals. For example, hogs that are managed as a family or social group (which is best for their welfare) may need to be treated in feed if they become sick as a group.

AWA knows that big business already has access to vets, many who are directly employed. The proposal to move to VCPr means big business will continue with “business as usual,” while sustainable farmers get punished for doing the right thing. In the worst case scenario, animals may have to wait for diagnoses or be left untreated on farms in regions underserved by vets. It is also conceivable that in this situation an underground market for antibiotics could develop. To try and force a rule without a real understanding of the rural situation exacerbates the rural communities’ fear that their way of life is under threat. It paints advocates for change as ignorant or arrogant; and when the so-called solution cannot be delivered without impacting sustainable farmers, we would agree with them.

An Alternative and Realistic Strategy:

A risk assessment would show that confinement production systems represent the major source of antibiotic-resistant bacteria and efforts must be focused there first. We therefore need to work with farmers and the AVMA and Government state and federal agencies to provide practical, realistic solutions for the broader agricultural community.

Suggested actions now include:

  1. Require a VCPr and prohibit sub-therapeutic or routine in-feed/water use of antibiotics for all CAFOs and farms with a turnover of $300,000 or more.
  2. For all farms, require proper medication records which show details of why treatment was needed and which animals were treated. This is an inexpensive way to monitor and record medication use (and already a requirement for AWA farmers).
  3. Record the sale of antibiotics at the point of sale. A review of the records at the store level would quickly reveal consistent use and inquiries could be made.
  4. Subsidize vets in underserved areas and look at other ways to encourage more students to consider farm animal practice.
  5. Build resources around farm health planning.
  6. Build resources in training vets in alternative systems of livestock production and positive health management—in other words, use the vet to keep the animals healthy, not to treat them when they get sick. For example, see http://www.farmhealthonline.com/.
  1. Work to license other competent experts to prescribe.

As long as some unknowing public health experts and well-meaning advocates keep prescribing unrealistic and impractical solutions without broader stakeholder engagement, the intrinsic problems associated with confinement agriculture will continue, and the gulf between the rural community and the urban community will also grow. There is a clear consensus among scientists and many groups that we must act now to address the unequivocal link between antibiotic abuse in intensive farming and the threat of antibiotic-resistant bacteria—and that we must act decisively. Nevertheless, it is equally imperative that we also act collectively to ensure that any proposals put forward are not only practical and realistic, but address this very real global health crisis without affecting those who are already working for change.