From: Susan Trivisonno [susan@saqqara.com]
Sent: Tuesday, January 09, 2001 6:23 PM
To: EXECSEC
Subject: Start A National Antibiotic-Use Reporting System Now

Dear Commissioner Henney, 

I urge you to establish a reporting system to determine the 
quantity of antibiotics used in U.S. agriculture. 

The rise in antibiotic resistance is slowly eliminating the 
effectiveness of these drugs for treating infectious 
diseases in people.  

But while there is growing acceptance of the causes of 
antibiotic resistance, there are few publicly available data 
on the quantity of antibiotics used in the United States - 
data that are necessary for scientists to explore the links 
between antibiotic use and the development of drug 
resistance and for developing rational strategies to curb 
use. 

In the just released report Hogging It!, the Union of 
Concerned Scientists attempts to address this lack of data 
by estimating antibiotic use in U.S. agriculture.  UCS 
calculated antibiotic use in the three major livestock 
sectors using publicly available information on herd size, 
approved drug lists and dosages, and estimates on the 
percent of herds treated. 

The report estimates that a staggering 24.6 million pounds - 
roughly 70 percent of all antibiotic drugs - are fed to 
healthy cows, pigs, and chickens annually for nontherapeutic 
purposes such as growth promotion.   This amount and total 
share of antibiotics used in livestock dwarf the 17.8 million 
pounds recently reported by industry for all agricultural use 
of antibiotics. 

Although they were devised by an indirect method, UCS's 
numbers are the best, most transparent estimate of 
agricultural antibiotic use available.  While they are good, 
they are not good enough.  Government-guaranteed information 
on U.S. antibiotic use is necessary for creating effective 
solutions for reducing antibiotic use.  The Food and Drug 
Administration has recognized the need for collecting such 
information, but it has not taken steps to establish the 
needed system. 

The FDA should move now to establish a system for collecting 
basic data on agricultural antibiotic use in the United 
States.  The information should be collected for both human 
and agricultural use and should include the class, 
indication, dosage, and treatment period. 

Please let me know your intentions. 

Regards, 

Susan Trivisonno 
2810 Oak Estates Ct. 
San Jose, CA  95135