Ron Doering, the first and only president of the Canadian Food Inspection Agency anyone can remember, and current counsel in the Ottawa offices of Gowlings (Ronald.doering@gowlings.com), writes in his monthly Food Law column that:

Health Canada (HC) and the Canadian Animal Health In­stitute (CAHI), the trade asso­ciation representing Canadian veterinary drug manufacturers, are to be com­mended for their decision on April 10 to follow the American initiative to address the growing concern over antimicrobial resistance in humans by introducing measures to promote the more prudent use of antimicrobials in animal produc­tion. HC announced its intention (1) “to work towards the removal of growth promotion and/or production claims of medically important antimicrobial drugs” and (2) “to develop options to strengthen the veterinary oversight of antimicrobial use in food animals.”

Contrary to many mainstream media reports, this does not mean that Canada is phasing out antibiotic use in meat production. Moreover, both initiatives face several difficult barriers to implementa­tion. This month we look at the difficulties associated with the first proposal, leaving next month for an analysis of why the oversight role by veterinarians must be strengthened if we are ever going to make real progress on what may be the most serious public health problem of our time.

First some law. The licensing and sale of antimicrobials fall under the jurisdic­tion of the federal government and its Food and Drugs Act, but the authority to manage their “use” lies with the provinces. The provinces also have the exclusive authority over the practice of veterinary medicine. What this means is that HC can require that a vet drug no longer have “growth promotion” as an indicated use on its label, but under the current regime it has limited power to actually determine how the drugs are used.

The issue of preventing growth promotion claims, and whether such a step will actually make a real difference, is a complex one. To begin with, most antibiotics are not actually used directly for growth promotion purposes but rather for disease prevention and control, what is often called disease prophylaxis. Removal of growth promotion claims will not prevent drugs to claim and be used for disease prevention. Farmers can continue to give their animals low doses of antibiotics to keep them from getting sick. The Public Health Agency of Canada, estimating that 90 per cent of the medication on farms is used for disease prevention, argues that antimicro­bials should not be used in this way and should be “limited to treating infection and not long-term mass medication for growth promotion or guarding against disease.” Others argue that there is insuf­ficient science to support the conclusion that low doses given to animals contrib­ute to antimicrobial resistance in humans and that outlawing the practice would result in more animal disease and the need for more drugs for disease treat­ment, possibly exacerbating the problem of antimicrobial resistance. When the science is uncertain, policy development is always difficult.

What is clear is that the proposal will not even apply to a large amount of anti­biotic use because of regulatory loopholes that result in part from our jurisdiction­ally fragmented regulatory framework. Our provinces still allow veterinarians to prescribe drugs for purposes not indicated on the product label (extra-label use). Unapproved drugs may be used on ani­mals because it is still legal for drugs to be imported for livestock production “own use” (OUI) if the drug is not offered for resale and it is not a prescrip­tion drug. As well, Active Pharmaceutical Ingredients (APIs) can still be imported by livestock producers to be mixed into feed on farm. None of these unregulated antibiotics are covered by the proposal. The latest Canadian Medical Association Journal contains a critical assessment of Canada’s performance in enhancing antimicrobial stewardship in agriculture and veterinary medicine, but it does state that HC has recently proposed measures to address OUI and API so, hopefully, reforms may be imminent.

As we shall see next month, none of the barriers described above can be adequately tackled without Canada’s veterinarians and their provincial regula­tory bodies taking a greater leadership role in combating the serious and growing problem of antimicrobial resistance in humans. Nowhere is the concept of One Health more compelling.