Melina Simonet Rodriguez - Comment

Document ID: FDA-2012-N-1067-0003
Document Type: Public Submission
Agency: Food And Drug Administration
Received Date: January 27 2013, at 12:00 AM Eastern Standard Time
Date Posted: May 17 2013, at 12:00 AM Eastern Standard Time
Comment Start Date: December 5 2012, at 12:00 AM Eastern Standard Time
Comment Due Date: March 5 2013, at 11:59 PM Eastern Standard Time
Tracking Number: 1jx-83cj-zhdb
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I want to start my comment using Dan Flynn's quote from Food Safety News: “Residues, usually from animal drugs, can cause allergic reaction and antimicrobials can contribute to antibiotic resistance to certain “superbugs”.” Furthermore, based on the Allergy Statistic of the American Academy of Allergy Asthma and Immunology, worldwide, drugs may be responsible for up to 20% of fatalities due to anaphylaxis. Moreover, Healthy Market Organization claims that “scientists after a long time searching discovered the first real reason for antibiotic resistance was the usage of sub - therapeutic doses of antibiotics over a long period of time. This appeared when the farmers used antibiotics as a growth promoter in their animals' feed. The antibiotic residues that are present in meat will enter the body of the consumer and start to accumulate gradually giving time for the pathogenic microorganisms to adapt with it and develop resistance.” Regulation §556.1 is currently outdated due to evolving science; therefore, it is important to be proactive and act. Regulation need to be changed in a more uniform format, and it needs to provide information in a more consistent manner. The new regulation also needs to be clear and easy to understand. Defining key terms it’s a way to do it because it eliminates the misconception on the terms used for tolerances. Passing this regulation would help to prevent the increase of, or even decrease, some human hazards produced by the residues in animal drugs in foods. However, if this regulation does not pass, it will create a negative impact in the public health. The regulation should also include tolerances for residues of new as well as old drugs. With the new advances of science, it can be discover if old and/or forgotten drugs have new or undiscovered impact in human health, especially, those drugs used in different countries from where United States import from. During the year of 2011, United States imported 2,893,186,281

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