Mt. Baker Vererinary & E.T. Services - Comment

I am strongly opposed to the prohibition of extralabel use of approved cephalosporins in food animals. As a veterinarian, I use these drugs for diseases which the drug is not labelled for because they are very effective for these conditions and the long acting nature of some of these cephalosporins (Excede) allows for an adequate dose duration to fully resolve the disease, where other labelled and extralabel treatments do not. By using cephalosporins in this manner, where the disease is fully resolved, there is LESS chance of creating antibiotic resistance than there is if the farmer utilizes a less effective, shorter duration treatment, often times not treating the animal for long enough duration to resolve the disease, thereby INCREASING the chance of developing antibiotic resistant organisms! I would like to see the science that shows that extralabel use of cephalosporins in food producing animals (under AMDUCA guidelines) increases antibiotic resistant organisms in people. I do not believe that this evidence exists. Everyday in bovine veterinary practice I see instances of farmers misusing over the counter (OTC) antibiotic treatments. I truly beieve that if FDA wants to have an impact on decreasing development of antibiotic resistant organisms they should remove the licenses for all the OTC antibiotics which are available at every corner feed store and are used indescriminantly and inappropriately in food animals, rather than removing one of the valuable tools that we as food animal veterinarians have to help relieve animal suffering and aid farmers in producing SAFE food for our nation. Extralable use of cephalosporins in food animals occurs with the involvement of the veterinarian, helping to ensure an accurate diagnosis and adherance to the principles of prudent antimicrobial use. I urge the FDA to reconsider the proposed prohibition of extralabel use of cephalosporins in food animals! Robert E. Holt, DVM Mt. Baker Veterinary & E.T. Services Lynden, WA