RUMA (the Responsible Use of Medicines in Agriculture Alliance) is disappointed and saddened by the tone of the latest report and press release from the Soil Association on Antimicrobial Resistance. The Alliance believes that these documents do not support the views expressed in the foreword by Helen Browning, the Soil Association’s Chief Executive, that she wants a collaborative approach to tackle the issue of antimicrobial resistance.

“RUMA welcomes constructive dialogue and suggestions to promote the responsible use of all medicines across the whole farming spectrum,” said RUMA Secretary General John FitzGerald. “We fully support the responsible use of antimicrobials – for example through our detailed species guidelines – and believe it is essential to maintain their effectiveness. However, once again the Soil Association has produced a report of cherry-picked comments from other papers and very small sample numbers extrapolated to the whole UK to provide alarmist and scaremongering comments for their press release. This is very unfortunate and does not encourage others to enter any debate with them on antimicrobial resistance.

“Antimicrobial resistance is an internationally important issue that affects both veterinary and human medicine and decisions should be taken on good scientific evidence rather than propaganda produced to support one type of farming system,” he added.

Rather than enter into a tit for tat discussion on the detail in the report, RUMA would offer the following comments on the report’s recommendations. The RUMA Alliance remains available to join in rational and sensible discussions on the responsible use of medicines, including antimicrobials, on farm.

Soil Association Recommendations

Recommendations to the Government and retailers

1. The UK’s regulatory system for farm antibiotics was designed to limit the level of antibiotic residues in food and needs significant upgrading to address the issue of antimicrobial resistance as well. We recommend that the Government establish the factors that lead to the development of resistant strains of bacteria in farm animals and in the food chain, consider the approaches adopted in other EU countries and draw up a blue print for an improved regulatory system that is appropriate for addressing the farming dimension of one of the key emerging health concerns of the 21st Century.
   

   RUMA believes that this reflects the Soil Association’s misunderstanding of the medicines regulatory system which is driven by EU legislation. Since the Veterinary Medicine Regulations (which replaced the old Medicines Act) were first introduced in 2005 to implement the over-arching EU directive, they have been regularly reviewed. RUMA is aware that the Government has already invested heavily in research to determine how antimicrobial resistance develops, and supports continued scientific research.

   Other EU member states have unilaterally introduced additional controls on farm to address resistance problems caused by the irresponsible use of antimicrobials on their farms. There is no such evidence of this type of irresponsible use in the UK.

   The Soil Association statement shows a distinct lack of understanding of the risk posed by the presence of any antimicrobial residues in food derived from animals in terms of resistance development and its potential transfer to man. In determining the maximum residue limits (MRLs) for antimicrobial residues in food the sponsor has to demonstrate a microbiological acceptable daily intake (ADI) by which a residue limit threshold is set internationally which poses no threat to man. The incidence of violative residues for antimicrobials in the UK as evidenced by VMD reports is very low and in 2010 was around 0.05%.

2. The Government should take back control of policy work to address the use of antibiotic resistance in farm animals and the food chain. It was not appropriate to hand this responsibility, as the Government did last year, to the Veterinary Medicines Directorate, an executive agency which is largely funded by the pharmaceutical and farming industries.
   

   RUMA considers that this is an inappropriate comment against a highly effective and efficient Government Agency which is held in high regard by other regulatory bodies across the EU and worldwide.

3. The Government should set a target to halve the overall use of antibiotics on farms within five years, and develop policies to ensure the target is met. There should be enhanced monitoring and greater transparency of veterinary prescribing and farm use of antibiotics.
   

   RUMA supports the call for enhanced monitoring and more information on veterinary prescribing and how antibiotics are used on farm. This would provide more evidence on which to base decisions.

   However, RUMA does not support an arbitrary reduction in the amount of antibiotics to be used on farm as this takes no account of the need to maintain animal health and welfare so that good quality food can be produced from UK farms in the quantity and at the price required. Indeed, this recommendation could be counter-productive as reducing the quantity of antimicrobials used by, for example, halving the dose or the treatment time would achieve the reduction but increase the risk of resistance development. RUMA believes antimicrobials should be used responsibly ‘as little as possible but as much as necessary’ and always in accordance with the veterinary prescription and for the full course of treatment.

4. The Government should actively support proposals currently under discussion by the European Commission to phase out the preventative use of antibiotics in groups of healthy animals and prohibit all off-label use of modern cephalosporins and fluoroquinolone antibiotics.
   

   RUMA comments that antibiotics are used preventatively in both human and veterinary medicine, where population medicine is required. This is less common in human medicine where we are normally treated as individuals but, for instance, bacterial meningitis outbreaks lead to the treatment of whole school or university populations to prevent the healthy individuals becoming ill. Individual prophylactic use is also carried out in humans, for instance, to prevent infection from forthcoming surgery and in nursing homes where a recent study on behalf of the European Surveillance of Antimicrobial Consumption Project Group found that more than 25% of antimicrobial use in nursing homes across the EU was to prevent urinary and respiratory tract infections. Farm animals normally live in close groups so it is good practice to treat therapeutically all the animals in the group when clinical or sub-clinical symptoms are displayed in some of the group. This maintains good health and welfare and reduces suffering. All treatments with antimicrobials have to be done in accordance with a veterinary surgeon’s prescription.

   RUMA considers that veterinary surgeons should remain able to prescribe off-label the 3rd and 4th generation cephalosporins and fluoroquinolone, in exceptional circumstances, for the benefit of the health and welfare of the animals concerned.

5. Leading retailers should ensure that the farms that supply them phase out the preventative use of antibiotics in groups of healthy animals and do not use modern cephalosporins and fluoroquinolone antibiotics off-label or as first line treatments.
   

   RUMA is pleased to include the British Retail Consortium amongst its members and welcomes retailer support for the responsible use of medicines. RUMA believes that the Soil Association proposal would impact on animal health and welfare and would inevitably lead to a reduction in the availability of food supplies from UK farms without a consequent reduction in demand. Retailers would be likely to fill the gap by using other sources where the animal health and welfare requirements – and, indeed, medicine use requirements – may not be as stringent as the UK.

6. The Government should explore the possibility of encouraging farming systems with low use of antibiotics per tonne of meat, litre of milk etc. or dozen eggs, though EU farm payments.
   

   RUMA promotes the responsible use of medicines on farm regardless of the farming system used.

7. The Government must make sure there are adequate funds for the Food Standards Agency to undertake comprehensive testing to establish the levels of ESBL E. coli on retail food in the UK.
   

   RUMA has no comment on this recommendation.

8. The Government should ensure there are adequate funds for the Animal Health and Veterinary Laboratories Agency to increase its monitoring of ESBL E. coli of farms and also maintain an adequate level of research in this area. Defra’s budget for this work should be considered in the context of the potential costs to the NHS if the problem of ESBL E. coli is allowed to escalate further and, in particular, if it becomes widely established in Salmonella as well.
   

   RUMA welcomes the data provided by the work of the AHVLA as this helps evidence based decisions to be made on antimicrobial resistance but RUMA has no comment to make on how the Government should use its funds.

9. The Government should work constructively at a European level to define more precisely the circumstances under which antibiotics can be used on a herd, flock or group basis.
   

   RUMA supports this recommendation.

10. If the use of modern cephalosporins and fluoroquinolones cannot be greatly reduced by voluntary measures, the farm use of modern cephalosporins should be banned and the use of fluoroquinolones restricted to mammals in life-saving situations.
    

    RUMA believes that veterinary surgeons need to maintain a full range of antimicrobials from which to choose the most appropriate to prescribe in any given circumstance. This means that 3rd and 4th generation cephalosporins and fluoroquinolones should be available for use in animals. They should be used responsibly which means they should not be used on farm when an older antibiotic is also effective and they should not be used as the first line of treatment unless diagnostic testing has confirmed they are the right antibiotic to use.

11. The UK should immediately prohibit the advertising of antibiotics to farmers. Advertisements to veterinary surgeons should be purely factual and not emotive in any way.
    

    RUMA has no comment to make on this recommendation.

12. To prevent the development of ESBL E. coli in calves, current guidelines discouraging the use of milk containing antibiotic residues for the feeding of calves or other livestock should be given legislative force.
    

    RUMA has no comment to make on this recommendation.

13. The Veterinary Medicines Directorate’s Inspections Administration Team should be given additional powers and training to undertake more thorough inspection of livestock farms which are permitted to incorporate antibiotics into feed. This should include unannounced visits and feed sampling to check that inclusion rates are not below full therapeutic levels.
    

    RUMA has no comment to make on this recommendation.

14. All farmers should be required to compost farmyard manure thoroughly in order to kill off E. coli bacteria. Livestock slurry should be thoroughly aerated before spreading.
    

    RUMA has no comment to make on this recommendation.

    Recommendations to the farming and veterinary industries

15. The British Poultry Council’s voluntary initiative to stop using cephalosporin antibiotics and to reduce the use of fluoroquinolones in poultry production is to be welcomed. Similar moves by other sections of the livestock industry should be encouraged.
    

    RUMA supports initiatives on the responsible use of antimicrobials. RUMA Guidelines encourage the adoption of farm management practices that reduce the risk of disease developing and then provide guidance on the responsible way to use medicine when this is necessary.

16. The British Veterinary Association (BVA) should make renewed efforts to draw its 8-point plan to the attention of all veterinary surgeons. This provides excellent guidance on the prescribing of antibiotics and recommends using modern cephalosporins and fluoroquinolones in limited situations only.
    

    RUMA is pleased to have the BVA as one of its members and supports the BVA’s 8-point plan and encourages all veterinary surgeons to use in when prescribing antibiotics.

17. Veterinary surgeons should agree not to prescribe modern cephalosporins for dry-cow therapy or for use in suckling cows, in order to prevent calves ingesting milk containing their residues.
    

    RUMA believes that 3rd and 4th generation cephalosporins should be used responsibly which means they should not be used on farm when an older antibiotic is also effective and they should not be used as the first line of treatment unless diagnostic testing has confirmed they are the right antibiotic to use.

18. The BVA, Royal College of Veterinary Surgeons and the Government should consider how veterinary practices could best submit returns detailing the antimicrobials they have prescribed and the reasons they were needed. Results should then be analysed and summaries published annually, showing the key reasons for usage and how much of each antibiotic class was used in each species.
    

    RUMA would be pleased to take part in discussions with relevant parties on how more information can be obtained on how and why antimicrobials are used as this would provide more evidence on which to base decisions.

Notes to editors

1. The Soil Association report “E. Coli Superbugs on farms and food” is available here: http://www.soilassociation.org/LinkClick.aspx?fileticket=yCT9su5iViQ%3d&tabid=313
2. The European Surveillance of Antimicrobial Consumption Project Group paper “Indications for antimicrobial prescribing in European nursing homes: results from a point prevalence survey” is available here: http://onlinelibrary.wiley.com/doi/10.1002/pds.3196/full
3. For further information on RUMA please contact RUMA Secretary General John FitzGerald (rumasec@btinternet.com)