Editor’s note: California State Veterinarian Annette Jones submitted this letter in response to a letter posted from a group of faculty and staff from the Johns Hopkins Center for a Livable Future at the Bloomberg School of Public Health regarding California legislation about antibiotic use in animals used for human food. The letter from the Johns Hopkins staff can be read by clicking here.
Dear Colleagues from Johns Hopkins Center for a Livable Future:
I appreciate that you wrote expressing your concerns about the implementation of California Senate Bill 27 (SB 27) via letter dated October 13, 2017. The only way to ensure that a collaborative process continues as we move toward the goal of mitigating the rate of development of antimicrobial resistance in order to protect public, animal, and environmental health, is to communicate concerns.
Your first concern that we are not collecting Veterinary Feed Directive (VFD) data is easy to address because we are going to collect that data. We have the authority to collect this data, there are strong data retention laws in place that preserve the data, and our strategic plan calls for the collection of VFD data. We have visited ALL facilities in California that submitted a letter of intent to FDA to manufacture or distribute medicated feeds using VFD’s and have ensured that they are retaining the needed data.
Due to the time sensitivity, we are currently focusing activities on enhancing compliance with antimicrobial use laws that will be effective in 2018, including ensuring the VFD’s are filled out properly so the baseline data collected is meaningful, but as we bring newly funded staff on board, we will be well prepared to collect and analyze VFD data, including historical data, for use in our initial 2019 report to the legislature. However, we do not feel this information alone is sufficient for evaluating the effects of stewardship best practices which are also being developed as we gain staff, so we are initiating much more in depth data gathering studies as well.
To your second point about “regular pattern” use of antimicrobials for preventative purposes, we have a different understanding of the situation. We agree that SB 27 clearly limits regular pattern use for prevention, but the issue is not that someone wants a “loophole.” Remember that animal owners and veterinarians also want to preserve the potency of antibiotics, perhaps more than most people since not only do they and their families need effective antibiotics, but they want to be able to keep their animals healthy well into the future.
The issue is that trained and licensed veterinarians want the autonomy to use their skills when practicing medicine within the framework of California law, so finding the best wording was challenging. That being said, we agree that the wording on our website did not exactly reflect SB 27. It was not intentional and we have been working on how to improve it ever since these concerns were pointed out.
To reduce confusion, we have now removed the items of concern from our website. Because the law itself is fairly explicit, to avoid confusion as we approach 2018, we will likely just use the exact wording from SB 27 in the future.
Again, while we may come at this issue from different backgrounds, I truly believe we share common goals as we implement SB 27, so we encourage you to stay engaged and continue this productive dialogue. Your letters are helpful and welcomed because they formalize your concerns, but also feel free to contact me directly at (916) 900-5000 or via email at firstname.lastname@example.org.
Thank you for your continued support of effective implementation of SB 27. Sincerely,
Annette Jones, D.V.M.
California State Veterinarian and Director
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