A recent opinion column in the February issue of BEEF (“We still need you,” by Mike Apley, DVM, page 16) discusses antibiotic use in food-animal production. Included was an attack on the Pew Commission on Industrial Farm Animal Production (the Commission). The author calls the Commission's report “biased” and claims that the report includes “misinformation.” As leaders of the Commission, we are compelled to respond to these inaccurate statements.

The Commission was established to develop consensus recommendations to address the impact industrial farms have in the areas of public health, environmental quality, animal welfare and rural communities. It was comprised of members from diverse professional backgrounds, experiences and professions, including human medicine, veterinary medicine, production agriculture, the food-service industry, public health, rural sociology, state and federal policy, religion, nutrition and ethics.

The Commission's primary public health recommendation was to curb routine, non-therapeutic antibiotic use on industrial farms. More than three decades of research have shown that overuse of antibiotics in food-animal production contributes to antibiotic resistance in humans.

In fact, the American Academy of Pediatrics, the World Health Organization, the American Medical Association, the American Nurses Association, the American Public Health Association, and the European Union have all separately concluded that the routine use of antibiotics in food-animal production must end in order to protect human health. In addition, the lead veterinarian of the Centers for Disease Control and Prevention has stated that “there is scientific consensus” that non-therapeutic use in food animals is a contributor to the increase in antibiotic-resistance bacteria and that those resistant bacteria are a serious public health threat.

For your reference, we are enclosing a partial bibliography of the studies that have been conducted over the last 30 years outlining the link between routine antibiotic use in food-animal production and the impact on human health. The list includes 51 separate peer-reviewed scientific studies that detail this connection (to see the bibliography, go to www.beefmagazine.com).

Contrary to the assertions in BEEF, the Commission took an unbiased approach with respect to technical reports and academic studies. The Commission sought eight technical, peer-reviewed reports based on the official process used by the National Academy of Sciences. We also consulted a broad range of academic experts on the issues, including a review of 170 separate, peer-reviewed reports in the areas of our inquiry, and solicited input from representatives of the industrial food-animal industry.

We based all primary and corollary recommendations on sound science, including industry-funded assessments, as well as research by authoritative experts in the fields we examined. Finally, the authors of those reports relied on many additional peer-reviewed scientific reports in writing their technical reports.

We stand by the quality of the Commission's work, and the strength of the scientific data upon which its recommendations were based.

John W. Carlin
Chairman, Pew Commission on Industrial Farm Animal Production, former Kansas Governor and Archivist of the U.S.

Michael Blackwell, DVM, MPH
Vice Chairman, Pew Commission on Industrial Farm Animal Production; and former dean, College of Veterinary Medicine, University of Tennessee/Knoxville

Mike Apley responds:

The response on behalf of the Pew Commission seeks to paint the process as wide reaching and inclusive of all possible data. How were opinions different from those the Commission considered?

In defense of the Commission's rejection of a technical section by a group of scientists, the executive director of the Commission stated in a letter to the editor of The Journal of the Veterinary Medical Association that “the Commission found that agriculture academics are too heavily influenced by industrial agriculture, primarily because of the concern of losing research funding.”1

The implication that the authors cited in defense of the Pew Commission position are somehow free of any need for dramatic results to drive research funding and career advancement, while agricultural researchers build their research and interpretations around pleasing their funding sources, is reflective of the Commission process.

I would point out that the dismissed agricultural researchers publish in peer-reviewed journals where the reviewers are not selected by the authors. In contrast, consider the Commission-selected “independent” reviewers of the technical reports submitted to the Commission. In the case of the antimicrobial resistance technical report, three of the four reviewers have their work cited in the report as supporting the conclusions of the technical writers. And, one of the reviewers is the person quoted at the front of the bibliography supplied by the Pew Commission with their letter to the magazine.

The response letter by Carlin and Blackwell makes great claims as to the data-gathering process, but yet, as in the report, no explanation is given related to criteria for inclusion or exclusion of data in the decision process, weighting of data, or the methods of the decision process. I refer the reader to a recent evaluation of reviews on zoonotic public health issues in which the authors found an underlying lack of structured and scientific principles.2 There are established methods for transparent, structured systematic reviews of large bodies of science related to an issue, and subsequent allocation of evidence to a decision-making process. “The commission deliberated” is not a review based on scientific principles.

Let's just take a look at one example. A paper by Fey, et al, documented the Salmonella illness of a Nebraska youth in which the isolate was related to isolates recovered from calf scours in area cattle herds, one owned by the youth's family.3 The technical writers included this paper in a discussion of zoonotic pathogen transfer directly to people and did not make assertions as to the selection pressure that led to the presence.

However, the Commission presents this paper in their bibliography attached to their letter to BEEF as one of the articles documenting “…the contribution of non-therapeutic use in food animals to the growing public health crisis of human antibiotic resistance.” What “non-therapeutic” uses would the Commission propose were routinely occurring in cowherds in the hills of western Nebraska to cause this selection?

Detailed evaluation of this paper would have revealed that no actual field investigation occurred (other than to gather samples from the diagnostic laboratory). Nor was an investigation of antibiotic use in these herds undertaken. In fact, the clone suddenly appeared one year, and hasn't been detected again in subsequent years.

The practices on these farms created an environment where dissemination of a multi-drug-resistant Salmonella met with an environment unfavorable to persistence of the clone. Where did the Salmonella come from?

Again, setting foot on the ground would have revealed that the calving grounds were heavily populated by geese traversing a major flyway. Is this proof of the source? No. But does this paper support a finding that “sub-therapeutic” use of antibiotics in livestock led to selection for this resistant isolate? Absolutely not.

This is the type of scientific discussion that is lost when a group holds itself as the sole judge of scientific bias and effectively excludes critical appraisal by those with another view of the issue.

The Pew Commission assertions are based on a mix of 1) sound data that should gain our full attention, and 2) over-reached interpretation of articles used in support of an apparent agenda. See the American Veterinary Medical Association's response to the Pew report for more examples (view the response at http://www.avma.org/onlnews/javma/sep09/x090901a.asp).

Proof of a mix of scientific rigor in both the Commission's reference selection and in the methods of determining suitability for entry into a decision-making process is further provided by the continued reliance on the Union of Concerned Scientists' inaccurate, non-peer-reviewed report of animal and human antibiotic use. When “data” are selected because of alignment with an agenda rather than scientific rigor, the process becomes transparent.

I respect the right of Blackwell and Carlin to stand by their report. I don't dismiss the entirety of evidence referred to in their report and agree that the evidence presented should be considered in a science-based decision process, along with the extensive references and observations left out of the report. However, I will also stand by my observation that the Commission assembled data in support of an agenda, rather than to drive a solution based on data.

I have no objection to different sides in a debate presenting their view of the data; I welcome that. I do object to presenting such an argument as representative of a middle ground when used in support of a political agenda.

Would the Pew Commission have a specific agenda? I will let the reader judge the above ad from the Washington Metro Transit System, placed by the Pew Charitable Trusts in support of the Preservation of Antibiotics for Medical Treatment bill.

Michael D. Apley, DVM, Ph.D.
Diplomate American College of Veterinary Clinical Pharmacology Professor, Kansas State University College of Veterinary Medicine

1Robert P. Martin, Executive Director, Pew Commission on Industrial Farm Animal Production, letter to the editor, Journal of the American Veterinary Medical Association, Vol. 233, October 16, 2008.

2Waddell L., et al. The Methodological Soundness of Literature Reviews Addressing Three Potential Zoonotic Public Health Issues. Zoonoses Public Health 56:477-489, 2009.

3Fey, P, et al. Ceftriaxone resistant Salmonella infection acquired by a child from cattle. P. Fey, T.J. Safranek, New England Journal of Medicine, 2000. 342: 1242-1249.

Three strikes

In regard to the January article “Why COOL, not NAIS?” by Steve Kay (page 58), I simply don't understand the logic behind this thinking. U.S. beef producers provide the safest product in the world due to the regulation of our industry, yet for years we had no way of providing this crucial information to consumers. Most people I talk to are surprised that the USDA stamp doesn't necessarily mean the meat is a product of the U.S.

As far as I know we are still the U.S., and Canada and Mexico are still Canada and Mexico. We are not a North American industry, nor should we be. We have a right to promote our product for our people.

The fact that Kay says country-of-origin labeling has added costs and not revenue for producers may be true. However, the law has been watered down so severely that it is difficult to tell what the real benefits would be. As far as feeder cattle imports, what is the problem with fewer imports from Canada? Why should we bear the burden of their production while they steal the benefits?

With regard to the National Animal Identification System (NAIS), lack of leadership is not the reason for its failure. NAIS failed because it's a piece of junk that burdened producers at the bottom of the chain. If you want to talk about added costs and no revenues, here is your program.

With regard to the checkoff, as reported in the article “Checkoff Checkup” (page 38), perhaps it should be viewed from the bottom of the chain. In 1990, fed-cattle prices were $75/cwt. In 2010, we're selling fat cattle at $85/cwt., a 13% increase in 20 years. Putting those same numbers toward the checkoff, we should be paying $1.13/head.

However, a 13% increase in revenue from fed cattle has been offset by an almost 30% increase in corn prices ($2.50/bu. in 1989 vs. $3.50/bu. in 2010). How can an increase from $1/head to $3-4/head as stated in the article be justified when looking at these numbers?
Chip Reid
Ordway, CO