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AgVetLink: Number 54, February 2006

Submissions on the report of the Antibiotic Resistance Expert Panel

The Approvals and ACVM Group received two submissions on the 2005 Antibiotic Resistance Expert Panel Report. One described New Zealand’s present regulatory regime as prudent and conservative relative to those of its trading partners. Both respondents expressed caution to ensure that regulatory action is not overly conservative and restrictive to the detriment of animal health and welfare. Both respondents were concerned about the potential to limit therapeutic options available to protect the health and welfare of animals.

Submissions

One respondent, who was opposed to any further intervention (particularly in regard to public health objectives about antimicrobial resistance) that might limit therapeutic options, said, “To achieve the desired control over animal diseases it is imperative that New Zealand maintains the availability of a comprehensive range of antimicrobials for animal use and the ability for veterinarians to prescribe antibiotics for therapeutic and prophylactic use”. It was considered that regulatory decisions must be based on sound scientific evidence and should not be restrictive, if there is no scientific evidence that the use of antimicrobials in New Zealand’s pastoral farming systems will lead to antimicrobial resistance. The recommendation to develop and document ‘best practice’ guidelines for veterinarians in the appropriate use of antimicrobials was supported.

The other respondent made more specific recommendations. While supporting the recommendation for an antimicrobial resistance surveillance programme for meat and milk, the respondent considered that the resistance risk from greater use of intramammary antimicrobials is low because of pasteurisation and milk discard. It was considered that technology may allow for centralised recording of statistics and practices, and a disciplined survey of prescribing veterinarians in regard to prescribing practices was recommended. It was pointed out that, even though there has been considerable investigation and research carried out on this subject, there is still limited understanding on quantifiable risks, in epidemiological terms, posed by antimicrobial use in animals.

The submission recommended that a technical group be established to help collate the information gathered from local and world research, New Zealand database and surveillance data to identify the important risk pathways for antimicrobial resistance threat to humans to support MedSafe and NZFSA regulatory decisions. It was recommended that New Zealand follow guidelines from world organisations such as WHO, OIE and FAO that promulgate safety with food and antimicrobial use. Regulatory decisions should be made on a product specific basis rather than depend on generalities about antimicrobial families.

Response

The Expert Panel report and submissions received indicate that, while refinements could be made, the regulatory control in New Zealand is set at an appropriate level and consistent with international guidelines. The Group will continue to make decisions on a product basis, working with MedSafe to apply scientifically sound principles. The Approvals and ACVM Group will prepare a response to the recommendations of the Antimicrobial Resistance Steering Group and the Expert Panel report, focussing on what needs to be done to respond to the recommendation concerning ongoing surveillance.