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Keep Antibiotics Working coalition comments to FDA Science Board

We applaud the FDA and its National Antimicrobial Resistance Monitoring System (NARMS) partners – the Centers for Disease Control and Prevention (CDC), and the Department of Agriculture (USDA) – for building and maintaining a strong NARMS program and for recent improvements in sampling, reporting, and the adoption of new technology. We remain deeply concerned, however, with the NARMS program’s ongoing failure to include a system to collect data on the use of antibiotics on-farm. Federal agencies and policy makers need these data to better interpret the trends in antimicrobial resistance reported by NARMS. On-farm antibiotics use data is needed to make connections between use and resistance, as was recognized in the most recent and earlier Science Board reports. In that sense, on-farm antibiotic use data will greatly enhance the value of the retail, clinical, and food animal data already being collected by NARMS.

Additional changes should be made to NARMS to better identify and elucidate emerging antibiotic resistance problems such as with carbapenem- and colistin-resistant Enterobacteriaceae. KAW also requests that the FDA continue to strive to speed up release of data from all three NARMS partners (FDA, CDC, and USDA) and to work with partners to harmonize reporting.

We ask that the FDA Science Board continue to work with the FDA to make sure that the Science Board’s recommendations are followed, and to challenge the FDA and other federal agencies to do more with respect to addressing the urgent threat posed by worsening antibiotic resistance. In addition, we encourage the FDA Science Board to engage with the Presidential Advisory Council on Combating Antibiotic-Resistant Bacteria to help drive needed change.

For the full comments, click here.