By David Fairfield, Senior Vice President, Feed
NGFA submitted an official statement to the U.S. Food and Drug Administration (FDA) on Nov. 13 regarding certain aspects of the National Antimicrobial Resistance Monitoring System (NARMS) Strategic Plan 2021-2025.
NGFA’s statement primarily focused on proposed activities within the strategic plan to initiate an antimicrobial resistance testing program for animal feed, pet food and associated ingredients, and included the following comments:
- Monitoring Thermally Processed Pet Food Would Not Provide Meaningful Information: Since antimicrobial drugs are not approved by FDA for use in commercial dog and cat food and the vast majority of such products is produced using a validated thermal process to eliminate foodborne pathogens, NGFA stated that sampling and testing of these pet foods would not represent a risk-based approach for monitoring antimicrobial resistance or provide meaningful information for the NARMS program.
- Anticipated Benefits of Monitoring Animal Feed Should Be Clarified: Given FDA’s previous actions to ensure judicious use of medically important animal drugs used in feed, NGFA stated it was unclear how sampling and testing of animal feeds would assist in obtaining a more complete view of resistance across human, animal and environmental ecosystems. In addition, NGFA stated the scientific basis for such surveillance is not stated within the plan, and that before monitoring of animal feed is initiated, additional detail and explanation to clarify how this activity would directly enhance the mission of the NARMS program are warranted.
- Further Stakeholder Involvement Is Necessary: NGFA urged FDA to further engage stakeholders as the agency develops and implements strategies for addressing individual actions identified in its plan, including those related to monitoring antimicrobial resistance in animal food products. NGFA noted it is essential for FDA to work collaboratively with stakeholders to mitigate development of antimicrobial resistance and promote stewardship of antimicrobials.