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CU comments on FDA Draft Guidance: the Judicious Use of Medically Important Antimicrobial Drugs in Food-Producing Animals

We completely agree with the FDA that the overuse of antibiotics in food animals has created a serious global public health problem for both human and animals and think the Guidance does a very good job of summarizing the key scientific reports on this topic. We commend FDA for addressing this problem by developing a policy framework regarding the judicious use of medically important antimicrobial drugs in food-producing animals. We also strongly agree with FDA that injudicious use of antimicrobial drugs should be minimized and eliminated, where possible, in order help minimize antimicrobial resistance development. In general, we do support the two principles laid out by the FDA in Draft Guidance #209: 1) limiting medically important antimicrobial drugs to uses in food-producing animals that are considered necessary for assuring animal health; and 2) limiting such drugs to used in food-producing animals that include veterinary oversight or consultation. However, we have some concerns regarding these principles and regarding FDA’s approach to this problem.