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I
Introduction
Like humans, animals can become ill and may need treatment for a bacterial
infection. In this situation, the veterinary surgeon may decide that a course of a
therapeutic antimicrobial is necessary.
The term originally referred to any agent with biological activity against living organisms;
however, "antibiotic" now is used to refer to substances with anti-bacterial, anti-fungal, or
anti-parasitical activity. The first antibiotic compounds used in modern medicine were
produced and isolated from living organisms, such as the penicillin class produced by fungi
in the genus Penicillium, or streptomycin from bacteria of the genus Streptomyces. With
advances in organic chemistry many antibiotics are now also obtained by chemical
synthesis , such as the sulfa drugs. Many antibiotics are relatively small molecules with a
molecular weight less than 2000 Da.
It is estimated that greater than 50% of the antibiotics used in U.S. are given to feed
animals (e.g. chickens, pigs and cattle) in the absence of disease. Antibiotic use in food
animal production has been associated with the emergence of antibiotic-resistant strains of
bacteria including Salmonella spp., Campylobacter spp., Escherichia coli, and
Enterococcus spp. Evidence from some US and European studies suggest that these
resistant bacteria cause infections in humans that do not respond to commonly prescribed
antibiotics. In response to these practices and attendant problems, several organizations
(e.g. The American Society for Microbiology (ASM), American Public Health Association
(APHA) and the American Medical Association (AMA)) have called for restrictions on
antibiotic use in food animal production and an end to all non-therapeutic uses .
However, delays in regulatory and legislative actions to limit the use of antibiotics are
common, and may include resistance to these changes by industries using or selling
antibiotics, as well as time spend on research to establish causal links between antibiotic
use and emergence of untreatable bacterial diseases. Today, there are two federal bills
(S.742 and H.R. 2562) aimed at phasing out non-therapeutic antibiotics in US food animal
production.
Second, antibiotics are used in the absence of disease to prevent diseases during times
when animals may be susceptible to infections. This use affects a larger number of animals,
because it usually involves treating a whole herd or flock, which increases the likelihood of
selecting for organisms that are resistant to the antibiotic. In these two examples, high doses
of antibiotics are used for short periods of time.
II
Third, antibiotics are commonly given in the feed at low doses for long periods to promote
the growth of cattle, poultry, and swine. In the 1950s studies showed that animals given low
doses of antibiotics gained more weight for a given amount of feed than untreated animals.
Exactly how this occurs is unknown. This effect appears to be less effective or absent in
animal production settings with good sanitation.
Examples :
Fluoroquinolones
With most therapeutic antimicrobials used to treat bacterial infection in animals there are
related antimicrobials used in human medicine from the same family, so there are
fluoroquinolones used in animal medicines and fluoroquinolones used in human medicines.
This is inevitable because frequently similar bacteria cause disease in humans and animals
and so have to be treated with similar antimicrobials.
All therapeutic antimicrobials are Prescription Only Medicines (POM) are only available on
prescription from a veterinary surgeon.
Marketing Authorization
Therapeutic antimicrobials must pass strict examination by the Veterinary Medicines
Directorate and fulfill criteria of safety, quality and efficacy before being allowed a
Marketing Authorization for use in animal health. 'Safety' includes safety to the treated
animal, the user, the environment and, for farm animals, the consumer.
In products used for farm livestock, a withdrawal period is calculated i.e. the time that must
follow after the last treatment before the animal, or its produce, can be used for human
consumption.
III
When dogs and cats need antimicrobials, the veterinary surgeon treats an individual
animal. A combination of fluoroquinolone injections and tablets may be used. Other pet
animals may have medicines administered orally in water or milk. Cattle and pigs are
treated on an individual basis with oral or injectable products.
When chickens or turkeys become ill, it is necessary to treat all in-contact birds i.e. all the
birds in the one shed. Some birds will be showing clinical signs whereas some, although
they may appear clinically normal, may be incubating the disease. Fluoroquinolones are
given in the drinking water for a short period of time under the direction of the prescribing
veterinary surgeon.
Nevertheless, in the US, the FDA/CVM have proposed to withdraw the use of
fluoroquinolones in poultry. This proposal has been addressed very positively by industry.
penicillin
some drugs have retained excellent activity against particular target organisms, such as the
penicillin against Streptococcus agalactia despite extensive use for 40 years. development of
resistance to animal antimicrobials may present a hazard to humans when the resistant
bacteria can cause disease in humans and can be transmitted via contaminated food.
Bacteria from animals which do not cause human disease may still present a hazard when
transferred via food if they then transfer their genetic material coding for resistance to
pathogenic human bacteria. Clearly a risk to humans exists when the antimicrobial used in
animals is also used in humans or displays cross resistance with an antimicrobial used in
human medicine. This risk has not been quantified.
IV
Phenylbutazone
Phenylbutazone became available for use in humans for the treatment of rheumatoid
arthritis and gout in (1949), but is no longer approved, and thus not marketed, for any human
use in the United States. This is because some patients treated with phenylbutazone have
experienced severe toxic reactions, and other effective, less toxic drugs are available to treat
the same conditions.
Phenylbutazone is known for its ulcerogenic, nephrotoxic, and hemotoxic effects in horses,
dogs, rats, and humans. It is known to induce blood dyscrasias, including aplastic anemia,
leukopenia, agranulocytosis, thrombocytopenia, and deaths. The reported adverse reactions
were associated with the human clinical use of 200 to 800 milligrams phenylbutazone per
day. Hypersensitivity reactions of the serum-sickness type have also been reported in
patients with phenylbutazone. The threshold for this effect has not been defined. Therefore, it
is unclear what level of exposure would be required to trigger such reactions in sensitive
people. Moreover, phenylbutazone is a carcinogen, as determined by the National Toxicology
Program (NTP) based on positive results in genotoxicity tests and some evidence of
carcinogenicity seen in the rat and mouse in carcinogenicity bioassays NTP conducted.
For animals, phenylbutazone is currently approved only for oral and injectable use in dogs
and horses. Use in horses is limited to use in horses not intended for food. There are
currently no approved uses of phenylbutazone in food-producing animals.
Investigation by FDA and state regulatory counterparts has recently found phenylbutazone
on farms and identified tissue residues in culled dairy cattle. In addition, the U.S. Department
of Agriculture's (USDA's) Food Safety Inspection Service has reported phenylbutazone
residues in culled cattle presented for slaughter for human food throughout the United States
in the past 2 calendar years. This evidence indicates that the extralabel use of
phenylbutazone in female dairy cattle 20 months of age or older will likely result in the
presence, at slaughter, of residues that are toxic to humans, including being carcinogenic, at
levels that have not been shown to be safe. Because of the likelihood of this adverse event,
we are issuing an order prohibiting the extralabel use of phenylbutazone drugs in female
dairy cattle 20 months of age or older.
We will continue to monitor the extralabel use of phenylbutazone and will adjust the scope
of this prohibition should we find that extralabel use in other species or classes of animals
presents a risk to public health.