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Environmental contamination of ecosystems from antibiotic use in livestock production

Petition: No. 190

Issue(s): Agriculture, compliance and enforcement, human health/environmental health, science and technology, and other

Petitioner(s): Beyond Factory Farming Coalition

Date Received: 2 January 2007

Status: Completed

Summary: The petitioner raises concerns about the potential impact of antibiotic use in livestock production on human health and the environment. The petitioner asks for information on the status of federal regulations that prevent antibiotic resistant bacteria (for example, C. difficile) from entering the environment and posing potential pollution hazards. The petitioner also requests details on monitoring and surveillance data and federal resources that are currently allocated to this area.

Federal Departments Responsible for Reply: Agriculture and Agri-Food Canada, Environment Canada, Health Canada

Petition

2 January 2007

Contact information:
Cathy Holtslander
Beyond Factory Farming Coalition
#501 – 230 22nd Street East
Saskatoon, SK
S7K 0E9
Phone (306) 955-6454
Email: cathyh@beyondfactoryfarming.org

Title of petition:

Environmental contamination of ecosystems, water, soils and food by antibiotic resistant micro-organisms due to excessive and/or inappropriate antibiotic use in livestock production.

Background information

Antibiotics and antibiotic resistant bacteria cause harm in the environment—they are pollutants. Excessive use of antibiotics in livestock production causes the development of antibiotic resistance bacteria, and maintains high levels of antibiotic resistant microorganisms in the environment. Antibiotic resistant bacteria create a health hazard and an environmental hazard.

Pathogenic disease organisms that are antibiotic resistant are a serious health concern, because infections caused by these organisms cannot be easily treated. Canadians can be exposed to antibiotic resistant disease organisms through contaminated water, soil and food. For example, recently, antibiotic resistant strains of c.difficile have been found outside of hospital situations, raising concerns that meat with the antibiotic resistant pathogen may be the cause.

Soil, water and food can be contaminated by antibiotic resistant microorganisms as a result of excessive and/or inappropriate use of antibiotics in livestock production. The problems related to antibiotic use in livestock production have been recognized for decades, but more recently, in 1997 the World Health Organization did a major study and published recommendations for countries to implement in order to protect public health and the environment.

The federal government has made some statements committing Canada to support of the WHO recommendations; however resources allocated to implementing the policies and results obtained so far appear to be seriously lacking. A serious impediment to effective action is the lack of comprehensive, comparable, reliable, publicly accessible data from all across Canada over time.

Data that has been collected to date under the CIPARS program indicates that there is an on-going and serious problem with antibiotic use and antibiotic resistance bacterial contamination in Canadian livestock production and the Canadian meat supply.

The first step toward solving a problem is understanding it. The federal government appears to be dragging its feet when it comes to ensuring that needed information is properly collected and analyzed.

We need to have reliable up-to-date information so we can how much antibiotic is being used in livestock production and what kinds of antibiotics are used as a first step toward prevention of serious environmental and health consequences of environmental pollution by antibiotic resistant bacteria.

Specific questions:

  1. What measures are being taken to address the lack of precise, comparable, and comprehensive data on the kinds and quantities of antibiotics being used in hog, poultry and cattle production in all parts of Canada?
  2. What is the federal government doing to enforce regulations to prevent pollution by antibiotic resistant bacteria entering water and soils, and prevent such pollutants from having a deleterious effect on the ecology of micro-organisms, as well as upon human health.
  3. What measures has the federal government taken to implement the 1997 recommendations from the World Health Organization regarding monitoring of antibiotic use in animal agriculture, surveillance of antibiotic resistance, and phasing out the non-therapeutic use of antibiotics in livestock production?
  4. What resources have been allocated to monitoring and surveillance of antibiotic use in Canadian livestock production, and to monitoring and surveillance of antibiotic resistant micro-organisms in meat sold in Canada in each of the past five years?
  5. What are the results of the above monitoring and surveillance work? For example, for each type of antibiotic approved in Canada for use in livestock, what amounts are being used for each species? What is the incidence of unapproved antibiotic use in Canada? What are the levels of antibiotic resistant bacteria in different types of meat?
  6. Based upon the answers to 4 and 5 above, what gaps in measurement of antibiotic use in livestock and antibiotic resistance in food animals and meat, still exist in Canada?

Federal departments and agencies that need to respond:

Agriculture and Agri-Food Canada
Canadian Food Inspection Agency
Environment Canada
Health Canada

Additional information:

  • Antibiotics and antibiotic resistant bacteria cause harm in the environment—they are pollutants.
  • Excessive use of antibiotics in livestock production causes the development of antibiotic resistance bacteria, and maintains high levels of antibiotic resistant microorganisms in the environment.
  • Antibiotic resistant bacteria create a health hazard and an environmental hazard.

The following excerpts from the website of APUA: Alliance for the Prudent Use of Antibiotics, outline the role of naturally occurring bacteria in ecosystems, and the impact of pollution of ecosystems by antibiotics and antibiotic resistant bacteria. (emphasis added). For more information see www.apua.org.

The Role of Bacteria

Bacteria are microorganisms that are found on our skin, in our digestive tract, in the air, in soil, and on almost all the things we touch every day. Most are harmless. Many are helpful because they occupy ecological niches that could be occupied by harmful bacteria. These helpful strains keep harmful microorganisms in check. They also help our digestion to function effectively and stimulate the development of a healthy immune system.

The Use of Antibiotics

Antibiotics used to treat infections are an invaluable tool, and their introduction revolutionized the treatment of infectious disease. However, in addition to being used to treat human disease, they have other applications. In the United States roughly half are used in non-human applications. Large amounts are employed in both plant and animal farming. In animals, antibiotics are used to prevent infection as well as to treat disease. Smaller doses are added to animal feed to promote growth. Antibiotics, chiefly streptomycin and oxytetracycline, are used to control bacterial infections of fruits and vegetables. Because of their wide-spread use, it is not surprising that antibiotics have been found in liquid waste at animal feedlots, and have spread into many surface and ground water supplies.

Antibacterial Resistance and the Environment

The ubiquitous presence of antibiotics has upset the delicate balance of microorganisms in the environment. Over millions of years, bacteria have evolved a number of strategies to coexist peacefully, including the capacity to produce antibiotics to ward off competitors. Other organisms have an ability to destroy these substances programmed into their genetic makeup, and having this capacity, are said to be antibiotic resistant. Both types have always existed. However, before the wide-spread use of antibiotics, resistant strains were a small fraction of the microorganism ecosystem. Significant change has occurred with the large scale human uses of antibiotics because these substances kill off antibiotic susceptible bacteria, and thus create favorable environments for the overgrowth of resistant strains.

As antibiotics become more widely used, resistant strains of both harmful and harmless bacteria are replacing antibiotic susceptible bacteria. Furthermore, resistant bacteria in one environment may not be confined to that specific environment, but can be carried thousands of miles away by wind, water, animals, food, or people. And, most importantly, antibiotic resistant organisms that develop in animals, fruits, or vegetables can be passed to humans through the food chain and environment. All of these factors have had the effect of changing the balance between antibiotic susceptible and the antibiotic resistant bacteria in our ecosystem, locally and globally.

Future Implications of Antibacterial Resistance

Further compounding the problem is that harmless bacteria with resistance genes can transfer these genes to pathogenic bacteria that enter the same environment. The genetic elements that are transferred often carry factors that impart resistance to more than one type of antibiotic. When such genetic elements are transferred, they create "superbugs" that are resistant to many distinct antibiotics. More and more frequently, we are seeing outbreaks of dangerous infections caused by such superbugs. Over the past few decades, the use of antibiotics has enabled us to control many serious infectious diseases. However, as resistant strains become more widespread due to natural and inevitable evolutionary adjustments, antibiotics will cease to be the effective tool they have been for physicians and patients to control infectious diseases.

Antibiotics kill more than the disease-causing bacteria to which they are directed. They kill any other susceptible bacteria. Once the ecosystem is cleared of susceptible bacteria, resistant bacteria can multiply and dominate the environment due to lack of competition. The phenomenon can be likened to weeds that have overgrown a lawn where the grass has been completely destroyed by an overdose of herbicides.

The following quotes from "Agricultural use of antibiotics and the evolution and transfer of antibiotic-resistant bacteria", (George G. Khachatourians, BA, MA, PhD, Canadian Medical Association Journal, Nov. 3, 1998; 159 (9). pp 1129–1136) provides a scientific perspective on antibiotic use in livestock in Canada, and recommends a federal policy response.

"Microbial resistance to antibiotics is on the rise, in part because of inappropriate use of antibiotics in human medicine but also because of practices in the agricultural industry. Intensive animal production involves giving livestock animals large quantities of antibiotics to promote growth and prevent infection. These uses promote the selection of antibiotic resistance in bacterial populations. The resistant bacteria from agricultural environments may be transmitted to humans, in whom they cause disease that cannot be treated by conventional antibiotics." p. 1129

"Poorly regulated use of antibiotics in medicine and agriculture has contributed to a build-up of reservoirs of antibiotic-resistant bacteria. The absence of newer antibiotics to treat the emerging infectious diseases caused by antibiotic-resistant organisms has heightened public apprehension. Levy has presented arguments supporting the view that the problem of resistance is ecological and represents an imbalance between sensitivity and resistance in bacterial populations. Some data suggest that if antibiotic use is discontinued, the ecological balance will be reestablished, at least in terms of the presence of antibiotic sensitivity." p. 1135.

Similarly, "Agricultural antibiotics and resistance in human pathogens: Villain or scapegoat?" by Allison J. McGeer, MSc, MD, (Canadian Medical Association Journal, Nov. 3, 1998; 159 (9). pp 1119–1120) highlights human health implications of pollution by excessive use of antibiotics in livestock production.

Quoting from the article: "Nearly half of all antimicrobial use in North America is in agriculture, and the great majority of such use is for promotion of growth in farm animals, rather than for crop treatments or therapy. The volumes used, and the fact that the low doses of antibiotics used for growth promotion may be more effective in inducing resistance than the higher doses used for therapy, mean that this use of antibiotics contributes significantly toward selection for antimicrobial resistance in human pathogens." p. 1119

The Report of the Advisory Committee to Health Canada on Animal Uses of Antimicrobials and Impact on Resistance and Human Health, June 2002 agreed, stating:

"Food animals are important reservoirs of many bacterial infections of humans. In Canada, the most prominent include Salmonella enterica and Campylobacter jejuni. Thousands of cases of these infections occur annually, and most are transmitted through contaminated food or water, although contact with animals and person-to person spread are sometimes responsible. Many, but not all of these infections are resistant to antimicrobials, and there is considerable evidence that resistance does make matters worse. Although scientists often do not know the precise origin of resistance in these bacteria, antimicrobial use in animals is probably the major contributing factor."

"Even resistance in animal bacteria that are harmless to humans is important to public health because these bacteria are a pool of resistance genes available to be transferred from animal bacteria to human pathogens."

  • Pathogenic disease organisms that are antibiotic resistant are a serious health concern, because infections caused by these organisms cannot be easily treated. Canadians can be exposed to antibiotic resistant disease organisms through contaminated water, soil and food. Recently, antibiotic resistant strains of c.difficile have been found outside of a hospital situation, raising concerns that meat with the antibiotic resistant pathogen may be the cause.

In October 2006 there were news reports about the emergence of antibiotic resistant C. difficile in the community—whereas previously it had been considered a disease found only in hospital settings. See http://www.ctv.ca/servlet/ArticleNews/story/CTVNews/20061003/difficile_meat_061003?s_name=&no_ads= for CTV's report, including the following:

"Scientists in Canada and the United States are exploring the unsettling question of whether C. difficile can be contracted by eating meat after finding evidence of infection in food animals, including dairy calves in Ontario."

"A new study by researchers at the Ontario Veterinary College in Guelph supports the idea, even revealing that the bacterium has already been isolated from meat in the retail food system."

"The study further shows that a strain of Clostridium difficile that has caused severe hospital outbreaks in Quebec, Britain and parts of the U.S. has been found it the feces of dairy calves in Ontario. Earlier U.S. studies have found other strains of C. difficile in piglets."

"Scientists admit they don't know whether people can become infected and develop C. difficile-associated disease through eating meat containing the bacterium. But it's important to find out, they say."

"C. difficile has been traditionally thought of as an infection acquired in hospitals, where antibiotic use is rife. Antibiotics are known to upset the bacterial balance of the human gut, which can allow C. difficile to take root and flourish."

But increasingly researchers are discovering cases of C. difficile disease in people who haven't been hospitalized, begging the question: How did they contract the bacterium? Suspicion has been turning to the food supply.

The article by Weese and his colleagues reported on their effort to see if they could find C. difficile in calves in Ontario. They tested feces samples from 278 calves from 102 farms in the spring and summer of 2004, finding C. difficile spores in 31 calves (11 percent).

Eight different strains of C. difficile were isolated, including the one blamed for hundreds of deaths in Quebec, Britain and parts of the U.S. The authors said the cattle strains were "indistinguishable'' from those that have infected humans."

  • Soil, water and food can be contaminated by antibiotic resistant microorganisms as a result of excessive and/or inappropriate use of antibiotics in livestock production.

The following points highlighting the dangers of antibiotic resistant bacterial pollution in the environment are taken from the extensive body of work published by the World Health Organization 2001. Antibiotic resistance: synthesis of recommendations by expert policy groups by Alliance for the Prudent Use of Antibiotics, JL Avorn, JF Barrett, PG Davey, SA McEwen, TF O'Brien and SB Levy. Boston, MA, United States of America. Pp 68–69:

1. Treatment of animals with antimicrobials important in human medicine, or drugs of the same family or class, can select for resistance to these drugs in zoonotic pathogens (e.g., Salmonella, Campylobacter). Resistant zoonotic pathogens can be transmitted from animals to humans through direct contact or indirectly through food or water, and cause illness which does not respond to treatment. Exposure of animals to drugs not used in humans (or no longer used in humans) can also select for resistance to drugs important in human medicine if the resistance determinants are genetically linked. For this reason, the linkage of two or more resistance genes on transmissible elements such as plasmids is of increasing concern. This phenomenon also makes the separation of antibiotics into "animal" and "human" use categories less tenable from a resistance point of view.

2. Genetic determinants of resistance in commensals of animals (e.g., Escherichia coli, enterococci) may be shared by exchanging plasmids, transposons or other transferable elements with related or even unrelated human pathogens during transient colonization of the gut of humans after ingestion of contaminated food or water. Some of the documents drew attention to other potential human health impacts.

3. Extending the principle in (2) above, resistant bacteria from animals or plants are part of a larger antimicrobial resistance ecosystem, and their resistance genes could find their way through a variety of poorly understood, indirect pathways to human pathogens. These pathways could involve transfer of resistance genes through intermediary environmental organisms. Concern in some quarters has been expressed about inclusion of resistance markers in genetically modified plants, however the documents reviewed do not consider this as an important issue (93,21).

6. Antimicrobial use in food animals may, in some cases, lead to an increase in the shedding of zoonotic pathogens (e.g., Salmonella) in animal faeces and thereby available for human exposure, whether or not the pathogen is resistant. This is a phenomenon called "pathogen load", and it could occur through a number of complex and poorly understood mechanisms whereby antimicrobial use in animals results, for example, in an increase in the duration of faecal shedding of foodborne pathogens, or an increase in the concentration of pathogens in faeces which may then contaminate food or water.

7. There is some concern that antibiotic residues eliminated in animal faeces and urine may exert resistance selective pressure on bacteria in soil and water. Treated animals and humans may excrete considerable quantities of active drug or metabolite and many of these residues are slow to degrade in the environment.

Most of the documents acknowledge that the public health impacts of antimicrobial use in animals and plants are complex and poorly understood. These issues have been the subject of considerable controversy and scientific debate for decades. There is consensus, however, that resistance does occur in zoonotic pathogens and commensals when animals are treated, that humans are occasionally exposed to these bacteria through contaminated food and water, and that illness, and sometimes treatment failure, does occur due to these resistant zoonotic infections. There is also consensus, however, that much uncertainty remains about the frequency with which these events occur, and the overall magnitude (numbers of people affected, severity of outcome, economic impact, etc.) of the public health impact of resistance arising in agriculture.

  • The problems related to antibiotic use in livestock production have been recognized for decades, but more recently, in 1997 the World Health Organization has done a major study and has published recommendations for countries to implement in order to protect public health and the environment.

The World Health Organization recommendations are summarized as follows:

  • No antimicrobial agent be used in agriculture unless it has been evaluated and authorized by competent national authorities,
  • That a systematic approach to replacing growth-promoting antimicrobials with non-antimicrobial alternatives is essential, and
  • That the use of any antimicrobial for growth promotion be terminated if it is also used for therapeutic purposes in humans or is known to select for cross-resistance to antimicrobial drugs used in human medicine
  • The federal government has made some statements committing Canada to support of the WHO recommendations; however resources allocated to implementing the policies and results obtained so far appear to be seriously lacking.
  • A serious impediment to effective action is the lack of comprehensive, comparable, reliable, accessible data from all across Canada over time.
  • The limited data that has been collected under the CIPARS program indicates that there is a significant problem with antibiotic resistance in Canadian livestock production.

The 1999 report of the Canadian Coordinating Committee on Antimicrobial Resistance posted on the website at www.omafra.gov.on.ca/english/livestock/animalcare/amr/facts/
irwin.htm
states that:

In May of 1997, two hundred individuals representing a vast array of professionals concerned with this problem met in Montreal. The Canadian Consensus Conference on Controlling Antimicrobial Resistance, co-sponsored by Health Canada and the Canadian Infectious Diseases Society, had as its primary goal the development of an integrated action plan for Canadians. A summary of this meeting and an outline of its many recommendations may be obtained from the Internet. This meeting did articulate a national strategy as follows:

It is impossible to address the threat posed by antimicrobial resistance without knowledge of the types and characteristics of antimicrobial resistance that are occurring. To develop this type of knowledge, it is critical that appropriate surveillance systems be established. There is a need to:

  • Establish a national integrated surveillance system for resistant organisms associated with both humans and animals.
  • Establish a national integrated surveillance system of antimicrobial use for humans and animals.
  • Establish national standards for laboratory testing for identification of antimicrobial resistance.
  • Study the impact of antibiotic use and resistance in human and animal health.
  • Establish mandatory reporting of certain infectious diseases caused by antimicrobial-resistant organisms.
  • Conduct research (targeted surveillance studies) to better understand the epidemiology of antimicrobial resistance in humans and animals.

In 2002, the Advisory Committee on Animal Uses of Antimicrobials and Impact on Resistance and Human Health to Health Canada reported that publicly available antimicrobial use data are scarce in Canada and indeed most countries in the world. We have no mechanism by which antimicrobial consumption data for food-producing animals is collected, analyzed, and reported. We don't know the quantities of various antimicrobials used in animals, and we do not collect use data in a manner that helps to further our understanding of resistance and its impact on human health.

The committee recommended that Health Canada should monitor antimicrobial use in Canada in order to aid interpretation of antimicrobial resistance surveillance data from human, animal, food and environmental sources, to evaluate effectiveness of prudent-use programs, and for use in risk analyses relating to the use of antimicrobials in food-animal production and the protection of human health.

The Canadian Integrated Program for Antimicrobial Resistance Surveillance (CIPARS) was set up for that purpose, but reported in 2004 that "The current lack of detailed data describing antimicrobial use in food animals limits exploration of links between antimicrobial use and resistance in livestock."

The most recent results posted on the CIPARS website show that in 2004 there was an alarmingly high percentage of antibiotic resistant bacteria in food animals. CIPARS also posted no data, and had apparently collected none, to show the extent and types of antibiotic use in livestock production facilities. At the end of 2006, the publicly accessible data was already two years old. Apparently data is only collected in Ontario and Quebec, leaving out significant segments of the meat and livestock sector located in western Canada.

Abattoir surveillance showed that in 2004 Generic E. coli samples showed resistance to one or more antimicrobials in 80 percent of swine, 78 percent of chicken, and 31 percent of cattle isolates. In the case of Salmonella, 40 percent of isolates from chickens and 48 percent from swine were resistant to one or more antimicrobials. In chickens, one percent of Salmonella isolates were resistant to ceftriaxone and 13 percent showed reduced susceptibility to ceftriaxone. And a significantly increased number of isolates were resistant to ceftiofur between 2002/2003 (7 percent) and 2004 (22 percent).

Retail surveillance showed that in the case of Salmonella, 63 percent of all chicken isolates from Ontario and Québec were resistant to one or more antimicrobials. Ceftiofur resistance was detected in 45 percent and 40 percent of chicken isolates from Ontario and Québec, respectively. For Campylobacter isolates from chicken, 53 percent from Ontario and 81 percent from Québec were resistant to one or more antimicrobials. For Enterococcus isolates from chicken, 98 percent from Ontario and 94 percent from Québec were resistant to one or more antimicrobials.

  • The first step toward solving a problem is understanding it. The federal government appears to be dragging its feet when it comes to ensuring that needed information is properly collected and analyzed.

In "Agricultural antibiotics and resistance in human pathogens: Villain or scapegoat?" Dr. Allison J. McGeer, expresses concern about Canada's reluctance to act. She outlines various international recommendations and strategies dating back to the 1960s and comments on the failure to implement effective policies: "Other countries, including Canada, have, because of the absence of proof of selection for cross-resistance, continued to use antibiotics that are structurally related to human antibiotics in animal feeds. Unfortunately, research and surveillance data regarding selection for antimicrobial resistance in animals are extraordinarily sparse, and we are just now learning that interpreting the absence of proof as proof of absence may have been an error."

Dr. L.E. Nicolle also expressed frustration in his article "Antimicrobial resistance: A continuing Canadian tale" (The Canadian Journal of Infectious Diseases and Medical Microbiology, December 2002, Volume 13, Number 6)

"One recommendation of the 1997 conference was the formation of a coordinating committee to provide leadership and to take responsibility for forwarding the Canadian Action Plan. The Canadian Committee on Antimicrobial Resistance (CCAR) was formed within a year, and has spearheaded the antimicrobial resistance containment agenda through an advocacy and promotion role. A CCAR summary of Canadian activities relevant to resistance is published in The Canadian Journal of Infectious Diseases twice yearly. CCAR has been restricted, however, in its pursuit of the resistance agenda by limited resources, with support primarily through short term funding from the federal government. In early October, 2002, CCAR organized a National Canadian Policy Conference on Antimicrobial Resistance. The goal of this conference was to review the current status of antimicrobial resistance in Canada in the context of the global experience, and to revitalize and refocus the national action plan to limit antimicrobial resistance.

"One theme of the conference was frustration. Frustration at the apparent failure of the antimicrobial resistance issue to capture government attention or the public policy agenda. Frustration at the lack of progress for infrastructure development for data collection systems to measure and monitor antimicrobial use and resistance. Frustration at the rising rates of MRSA and other key organisms in health care institutions despite intensive infection control measures. Frustration at the failure to secure dedicated resources for effective antimicrobial containment programs, including a lack of consistent funding for CCAR. And, certainly, frustration at the high talk-to-action ratio for this topic.

"Although Canada was among the first countries to propose a national agenda to contain antimicrobial resistance, five years later the antimicrobial resistance initiative appears to have languished. Antimicrobial resistance evolves—is Canada standing still?

… In Canada, despite a relatively early start, limited progress has been made in addressing this problem. The status quo in antimicrobial use has a clear future—ever increasing antimicrobial use, antimicrobial resistance and costs. An alternate path is clear and has been repeatedly articulated, including at the recent CCAR conference. Antimicrobial resistance containment is a clinical, public health and economic imperative. This country needs to move aggressively beyond the Action Plan, to the action."

[Original signed by Cathy Holtslander]

Cathy Holtslander
Saskatoon
December 22, 2006

[top of page]

Joint Response: Agriculture and Agri-Food Canada, Health Canada

2 May 2007

Ms. Cathy Holtslander
Beyond Factory Farming Coalition
501-230 22nd Street East
Saskatoon, Saskatchewan
S7K 0E9

cathyh@beyondfactoryfarming.org

Dear Ms. Holtslander:

I am writing in response to your petition of January 2, 2007, addressed to the Office of the Auditor General of Canada. Your environmental petition (Petition No. 190) concerning the environmental contamination of ecosystems, water, soils and food by antibiotic resistant micro-organisms due to excessive and/or inappropriate antibiotic use in livestock production has been presented pursuant to section 22 of the Auditor General Act. You request that Agriculture and Agri-Food Canada, the Canadian Food Inspection Agency, Health Canada and Environment Canada respond to this petition's statements.

Due to the nature of the issue's raised in the petition, the Government of Canada is providing you with a joint response that will be sent by the Minister of Health, the Honourable Tony Clement.

Thank you for writing with your views on this matter.

Sincerely,

[Original signed by Chuck Strahl, Minister of Agriculture and Agri-Food and Minister for the Canadian Wheat Board]

Chuck Strahl

c.c:

The Honourable Tony Clement, PC, MP
The Honourable John Baird, PC, MP
Mr. Ron Thompson


Response of the Federal Departments and Agencies to
Environmental Petition 190 Filed by the Beyond Factory Farming
Coalition under Section 22 of the
Auditor General Act
Received January 15, 2007

Environmental Contamination of Ecosystems, Water, Soils and
Food by Antibiotic Resistant Micro-organisms Due to Excessive
and/or Inappropriate Antibiotic Use in Livestock Production

May 12, 2007

Minister of Health and the Minister for the Federal Economic
Development initiative for Northern Ontario,
Minister of Agriculture and Agri-Food and
Minister for the Canadian Wheat Board,
Minister of the Environment.

Table of Contents

Question 1

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Question 2

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Question 3

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Question 4

4

Question 5

5

Question 6

6

Petition Regarding Environmental Contamination of Ecosystems, Water, Soils and Food by Antibiotic Resistant Micro-organisms Due to Excessive and/or Inappropriate Antibiotic Use in Livestock Production

The Response of the Federal Departments to the Petition

The Government of Canada is committed to promoting the prudent use of antibiotics and preserving their effectiveness through, amongst others, containing the development and spread of antimicrobial resistance (AM I) in microorganisms. Significant efforts have been made over the past several years in promoting systems that encourages the prudent and judicious use of antibiotics, and infection control. The Government of Canada embraces risk-based decision-making process in assessing and managing the human health risks arising from infectious agents as well as from other types of environmental pollutants. Efforts related to the specific questions posed by the Coalition are addressed below.

1. What measures are being taken to address the lack of precise, comparable, and comprehensive data on the kinds and quantities of antibiotics being used in hog, poultry and cattle production in all parts of Canada?

Since 1999, Health Canada has investigated sources and means of acquiring reliable and valid data on antimicrobial use in food-producing animals in Canada. At the federal level there is no current legislative mechanism to acquire this data. Much of the legislative power and mandate for this activity rests with the provincial agriculture ministries. Over-the-counter (OTC) antimicrobial sales (including in-feed use) and the practice of veterinary medicine are regulated by each province.

Antimicrobials utilized in the food-animal production sector are accessed through a complex web of sales and distribution channels, Attempts have been made to acquire market information on veterinary drug distribution (which actually represents a small proportion of total use), but restrictions on the publication of sampling methodology and data has made the process problematic. Furthermore, negotiations with the Canadian Animal Health Institute (CAHI) (representing 90 percent of pharmaceutical sales of licensed products) have failed to generate any meaningful data on sales or distribution of antimicrobials. Pharmaceutical industries are reluctant to provide this data because of market competitiveness.

The Public Health Agency of Canada (PHAC) has worked with academic institutions to acquire this data through the use of on-farm projects. Projects have been conducted in the Dairy, Swine, Sheep, Beef and Poultry sectors to collect precise antimicrobial use data, Research is also being conducted to develop drug use* estimation models in the absence of ongoing data collection.

In 2000, the Government of Canada established the Canadian Integrated Program for Antimicrobial Resistance Surveillance (CIPARS) and these individual projects have provided the background to the development of the On-Farm surveillance component of CIPARS. The farm component of CIPARS was initiated in 2003 with five-year funding from Agriculture and Agri-Food Canada's Agriculture Policy Framework. Swine are being utilized as the initial target species to test the feasibility, and sustainability of an ongoing farm-level surveillance program. Without major changes to legislation, CIPARS's On-farm and targeted research projects remain our only source of valid antimicrobial use data from the animal production sectors. These initiatives rely totally on the voluntary participation by farmers.

PHAC has actively participated and organized discussions on tools to collect antimicrobial drug data. For example, in 1999 a meeting with the CAHI, the Canadian Veterinary Medical Association (CVMA), provincial agriculture, drug distributors, and private veterinary specialists was held. PHAC has also made numerous presentations to farming and production sector groups to motivate discussion about the importance of the collection of antimicrobial use data. PHAC also co-chaired the conference steering committee to host two national conferences on Agriculture's role in Managing Antimicrobial Resistance 2003 and 2005; hosted a Bilateral US-Canada Meeting on Monitoring Antimicrobial Use and Antimicrobial Resistance (February 8 & 9, 2005); participated and organized discussions with international groups on monitoring and quantifying antimicrobial use in agriculture and veterinary medicine (pre-meetings at International Conference on Antimicrobial Agents in Veterinary Medicine in Helsinki, 2002, Ottawa 2004).

Through Legislative Renewal efforts are being made to amend the Food and Drugs Act to enable the collection of drug sales an id use information on antimicrobials intended for use in animals from drug manufacturers and distributors.

The Canadian Food Inspection Agency (CFIA) does not have the regulatory authority to compel the collection of precise, comparable and comprehensive data on the quantities of antibiotics being used in hog, poultry and cattle production in all parts of Canada. However, the CFIA recognizes the potential importance of that information and has been requesting the voluntary disclosure of the type and amount of veterinary drug being used during the course of feed facility inspections at commercial arid on-farm feed mills.

It should be noted that commercial feed mills are inspected at least once annually, and that not all on-farm feed manufacturers ire inspected on a regular basis and the species of animal that the drug is being used for is not identified. Only medications included in the feed are identified. Information on medications delivered by water, orally or by injection is not collected by the CFIA's Feed program.

2. What is the federal government doing to enforce regulations to prevent pollution by antibiotic resistant bacteria entering water and soils, and prevent such pollutants from having a deleterious effect on the ecology of micro-organisms, as well as upon human health?

All veterinary drugs authorized for sale in Canada are evaluated for their safety and efficacy in intended species. In addition Jail drugs to be used in food-producing animals are evaluated for potential risks to human health. The current veterinary new drug guidelines stipulate that antimicrobial drugs to be used in food-producing animals be evaluated for their likely impact on human health, in particular for their effects on gut microflora and impact on human health through antimicrobial resistance.

At the present time, Environment Canada has no regulations in place to prevent pollution of the environment by antibiotic-resistant bacteria. The federal Fisheries Act provides a legislative authority respecting entry of deleterious or harmful substances into water inhabited by fish. That authority is subsection 36(3) of the Fisheries Act, which prohibits the deposit of substances harmful to fish into Canadian fishery waters. For the federal government to be able to take action under subsection 36(3) of the Fisheries Act, it would have to be determined whether or not the bacteria were deleterious to fish, fish habitat and/or human consumption of fish.

Similar to the Fisheries Act, the Migratory Birds Convention Act, 1994 (MBCA, 1994) contains a prohibition against the release of substances harmful to migratory birds in areas where those birds are found. Those areas could be land or water. As is the case with the Fisheries Act, in order for Environment Canada to take action under subsection 5.1 of the MBCA 1994, the Department would need to establish that the antibiotic-resistant bacteria are harmful to migratory birds.

Environment Canada would have to undertake research in this area and is developing scientific methods to analyze for the presence of antibiotics. The Department would need to study the behaviour of antibiotic-resistant bacteria in the environment, in order to determine whether there is a case to be made for deleteriousness as defined in section 34 of the Fisheries Act, or for harm under the MBCA, 1994.

Although not directly related to the, issue of antibiotic use in livestock, it should be noted that regulations do exist under the Canadian Environmental Protection Act, 1999 (CEPA 1999) requiring the notification and assessment of hew living organisms manufactured or imported into Canada. These Regulations (New Substance, Notification Regulations (Organisms)) also apply to micro-organisms that have been shown to exhibit resistance to one or more antibiotics (including those of clinical relevance to livestock or humans) as well as to those that have been engineered to include genetic elements related to antibiotic-resistance. Should the assessment conclude that the presence of antibiotic resistance in either case poses a risk to the environment or to human health through environmental exposure, then appropriate control measures are imposed that are designed to minimize this risk.

3. What measures has the federal government taken to implement the 1997 recommendations from the WHO regarding monitoring of antibiotic use in animal agriculture, surveillance of antibiotic resistance, and phasing out of the non-therapeutic use of antibiotics?

The Government of Canada is committed to ensuring that drugs used in livestock production are effective and meet human safety requirements.

PHAC has initiated an antimicrobial resistance program with components which includes surveillance, risk assessment and research. This program is based in the Laboratory for Foodborne Zoonoses, with the human component data being coordinated by the Centre for Infectious Disease Prevention and Control (CIDPC), and the National Microbiology Laboratory (NML) within PHAC. Support for this program also comes from the VDD, Health Canada, and the CFIA. PHAC also works with academic and international partners to investigate the associations between agricultural antimicrobial use and the impact on human health.

Health Canada has prioritized all approved veterinary antimicrobial growth promotants (AGPs) for reassessment, and is in the process of conducting human health risk assessments. An expert committee on antimicrobial r distance risk assessment his been established to advise Health Canada in this aspect. In December 2006, Health Canada issued an advisory on reassessment of efficacy of these AGPs for producers, veterinarians, and animal nutritionists regarding the use of these AGPs on farm http://www.hc-sc.gc.ca/dhp-mps/vet/antimicrob/agp_hc_vdd_e.html

4. What resources have been allocated to monitoring and surveillance of antibiotic use in Canadian livestock production, and to monitoring and surveillance of antibiotic resistant micro-organisms in meat so Id in Canada in each of the past five years?

The Government of Canada has invested approximately 16 million dollars over the past five years to support the development of a national antimicrobial resistance surveillance program (CIPARS*), and to investigate associations between agriculture and veterinary use of antimicrobials and the emergence of antimicrobial resistance among bacteria associated with human infections. This includes surveillance of animals at the farm and abattoir levels, meat at retail, and human Salmonella cases.

The CFIA recognizes the importance of the safe use of antibiotics. Commercial facilities are inspected annually and a cross-section of on-farm manufacturers are inspected as well to establish that medications are being used and handled safely. These inspections focus on the procedures and practices used in the manufacture of medicated feeds to confirm that intended medication levels are achieve 1 and drug residue carryover are managed to minimize the impact on animal and human health. In addition, information on the type and amount of drugs used is collected during these inspections. Approximately 70 full-time equivalent (FTE) staff are used to conduct inspections at commercial and on-farm feed mills.

In addition to regularly scheduled feed facility inspections, where the monitoring of meat, milk or eggs identifies an antibiotic residue, the CFIA investigates to determine the cause. The CFIA then works with the producer to confirm that the antibiotic residues are controlled.

With respect specifically to antibiotic resistant micro-organisms, random samples of feed obtained at commercial and on-farm feed mills, rendering plants, oilseed manufacturers and retail facilities are tested for the presence of Salmonella. Where feeds test positive for Salmonella, further testing to identify the stereotype and look for antibiotic resistance is undertaken. These activities account for an estimated additional five FTE staff.

In addition, there is a Government of Canada position for an antimicrobial resistance coordinator. The position was staffed in September 2006'and the officer is working part time on the Canadian Integrated Program for Antimicrobial Resistance Surveillance (CIPARS) project. He is coordinating the surveillance piece of antibiotic resistance in meat sold in Canada.

(*The Canadian Integrated Program for Antimicrobial Resistance Surveillance (CIPARS) was developed in response to recommendations of the 2002 Health Canada Advisory Committee on Animal Uses of Antimicrobials and Impact on Resistance and Human Health. Modeled after initiatives in the United States and Europe, GIPARS has been designed to provide an ongoing, permanent, national surveillance system to monitor antimicrobial resistance trends among selected enteric organisms fro n humans, animals and animal-derived food sources across Canada, and was initiated in the fall of 2002. CIPARS 2005 includes data from Active Abattoir Surveillance in cattle (generic Escherichia coli), chicken (Salmonella and generic E. coli) and swine (generic E. coli); Active Retail Surveillance in beef (generic E. coli), chicken (Campylobacter, Salmonella, generic E. coli, Enterococcus) and pork (generic E. coli) in Ontario, Saskatchewan and Quebec; Enhanced Passive Surveillance of clinical Salmonella in humans; Passive Surveillance of Veterinary Clinical Salmonella isolates; and Human Antimicrobial Use data provided by IMS Health (Canada). CIPARS is continuing to build the framework and partnerships for the collection of relevant and representative antimicrobial resistance data along the food chain. In 2006, CIPARS rolled out the on-farm surveillance component in swine farms across Canada, which simultaneously collects drug use and antimicrobial resistance data. Antimicrobial,, surveillance in, Campylobacter has also been added to the abattoir surveillance in cattle at the end of 2005. Retail surveillance has now been expanded to include British Columbia and the Maritime provinces.)

5. What are the results of the above monitoring and surveillance work? For example, for each type of antibiotic approved in Canada for use in livestock, what amounts are being used for each species? What is the incidence of unapproved antibiotic use in Canada? What are the levels of antibiotic resistant bacteria in different types of meat?

There are no systematic data yet available on the amount of drugs used in livestock production in Canada, although CIPARS a mal report includes data on AMR in selected bacterial species, and antimicrobial use for humans. Comprehensive antimicrobial use data from the food animal production sectors is unavailable. Data from targeted research projects have or will be published in scientific literature. Release of this information is subject to the academic institution's graduate program timelines.

Similarly, the incidence of the use of unapproved drugs in Canada is not available. However, recent initiatives that the Government of Canada is taking on controlling the personal use importation of veterinary drug s and regulating the import and use of active pharmaceutical ingredients is expected to significantly restrict the use of unapproved drugs in Canadian livestock industries.

For detailed AMR data in different types of meat, the CIPARS annual reports for 2002-04, and an interim report for 2005 are available on the PHAC web site http://www.phac-aspc.gc.ca/cipars-picra/index.html

6. Based upon the answers to 4 and 5 above, what gaps in measurement of antibiotic use in livestock and antibiotic resistance in food animals and meat, still exist in Canada?

The Government of Canada recognizes that antimicrobial use is a major risk factor for the development of antimicrobial resistance in animal, humans and the environment. There continues to be a strong need to track when and how antimicrobials are being used to enable the implementation of risk management strategies to reduce the emergence and spread of antimicrobial resistance. The drug distribution system in Canada is complex and must be understood in order to fully understand the complexity of the occurrence of antimicrobial resistance with food-producing animals. Federal and provincial governments need to continue to work together to support the collection of pharmaceutical, veterinary and farm-level data.

In contrast to antimicrobial use data, significant progress has been made in recent years through CEPARS in monitoring the antimicrobial resistance at the farm and retail levels. Further strengthening the CIPARS activities by expanding the range of bacterial species tested from various surveillance components/commodities, increasing the samples tested, and expanding the program from major food animal species to all food-animal species or food commodities could improve the quality and accuracy of AMR data.

Other aspects that need strengthening to minimize the human and environmental health impact through AMR are risk assessment capabilities and funding research to generate data required for risk assessment (particularly in areas where the most data gap exists). Efforts to promote prudent and judicious use of antimicrobial will also complement efforts to minimize undue risks to human and environmental health from the use of antimicrobials in animals.

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Minister's Response: Environment Canada

17 May 2007

Ms. Cathy Holtslander
Beyond Factory Farming Coalition
501 - 230 22nd Street East
Saskatoon, Saskatchewan
S7K 0E9

Dear Ms. Holtslander:

I am pleased to provide Environment Canada's response to your Environmental Petition No. 190 to the Commissioner of the Environment and Sustainable Development, concerning the environmental contamination of ecosystems, water, soils and food by antibiotic resistant micro-organisms due to excessive and/or inappropriate antibiotic use in livestock production. Your petition was received in Environment Canada on January 15.

You will find enclosed Environment Canada's detailed response, which addresses the issue that falls within the Department's mandate. I understand that the Minister of Agriculture and Agri-Food and the Minister of Health will be responding separately to questions that fall under their mandate.

In light of the concerns you have raised, Environment Canada will consider the matter further and develop any recommendations that may be appropriate for consideration by the Minister.

I appreciate this opportunity to respond to your petition and trust that you will find this information helpful.

Sincerely,

[Original signed by John Baird, Minister of Environment Canada]

John Baird, P.C., M.P.

Enclosure

c.c.:

The Honourable Chuck Strahl, P.C., M.P.
The Honourable Tony Clement, P.C., M.P.
Mr. Ronald C. Thompson, Interim Commissioner of the Environment and
Sustainable Development


Environment Canada Response to Environmental Petition No. 190 Pursuant
to Section 22 of the
Auditor General Act

Question 2

What is the federal government doing to enforce regulations to prevent pollution by antibiotic resistant bacteria entering water and soils, and prevent such pollutants from having a deleterious effect on the ecology of micro-organisms, as well as upon human health.

Response

At the present time, Environment Canada has no regulations in place to prevent pollution of the environment by antibiotic-resistant bacteria.

The federal Fisheries Act provides a legislative authority respecting entry of deleterious or harmful substances into water frequented by fish. That authority is subsection 36(3) of the Fisheries Act, which prohibits the deposit of substances harmful to fish into Canadian fishery waters. Subsection 36(3) reads as follows:

" … no person shall deposit or permit the deposit of a deleterious substance of any type in water frequented by fish or in any place under any conditions where the deleterious substance or any other deleterious substance that results from the deposit of the deleterious substance may enter any such water."

Subsection 36(4) of the Fisheries Act provides that the prohibition in subsection 36(3) is not violated if regulations under subsection 36(5) of the Act or regulations made under another federal law authorize the deposit of the deleterious substance into Canadian fishery waters. There are currently no federal regulations under the Fisheries Act or any other federal law authorizing the release of antibiotic-resistant bacteria to Canadian fishery waters.

For the federal government to be able to take action under subsection 36(3) of the Fisheries Act, it would have to be determined whether or not the bacteria were deleterious to fish, fish habitat and/or human use of fish.

Similar to the Fisheries Act, the Migratory Birds Convention Act, 1994 (MBCA 1994) contains a prohibition against the release of substances harmful to migratory birds in areas where those birds are found. Those areas could be land or water. The relevant sections of the MBCA 1994 are as follows:

"5.1 (1) No person or vessel shall deposit a substance that is harmful to migratory birds, or permit such a substance to be deposited, in waters or an area frequented by migratory birds or in a place from which the substance may enter such waters or such an area.

(2) No person or vessel shall deposit a substance or permit a substance to be deposited in any place if the substance, in combination with one or more substances, results in a substance—in waters or an area frequented by migratory birds or in a place from which it may enter such waters or such an area—that is harmful to migratory birds."

There are three exceptions to the prohibitions in subsections 5.1(1) and (2). They are: first, deposit of a harmful substance authorized under the Canada Shipping Act (CSA); second, a deposit authorized under a federal law other than the MBCA 1994 or the CSA; and third, a deposit authorized by the Minister of the Environment for scientific purposes. The exceptions are set out in subsection 5.1(3) of the MBCA 1994.

As is the case with the Fisheries Act, in order for Environment Canada to take action under subsection 5.1 of the MBCA 1994, the Department would need to establish that the antibiotic-resistant bacteria are harmful to migratory birds.

The Species at Risk Act (SARA), which provides protection of species in danger of extinction or significant reduction in their numbers, has relevant clauses. Subsection 32(1) states that "no person shall kill, harm, harass ... an individual of a wildlife species that is listed as an extirpated species, an endangered species or a threatened species." The listing of such species is found in Schedule 1 of SARA. Also, section 33 states that "no person shall damage or destroy the residence of one or more individuals of a wildlife species that is listed as an endangered species or a threatened species, or that is listed as an extirpated species if a recovery strategy has recommended the reintroduction of the species into the wild in Canada."

If release of antibiotic-resistant bacteria into an area where a species listed in Schedule 1 of SARA as extirpated, endangered or threatened is found, and if that release led to the death of or harm to that species or constituted a "harassment" of that species, the prohibition in subsection 32(1) could come into play. Likewise, if such a release damaged or destroyed the residence of such a species, the prohibition in section 33 would apply. However, Environment Canada would be required to establish that the death of or harm to the species or its harassment was due to the release of the antibiotic-resistant bacteria, and would need to link that release back to a specific person. Similarly, for section 33 to apply, the Department would have to establish that a person released antibiotic-resistant bacteria into or in the area of the species' residence and that the release of those bacteria resulted in damage or destruction of the species' residence.

Environment Canada would have to undertake research in this area and is developing scientific methods to analyze for the presence of antibiotics. The Department would need to study the behaviour of antibiotic-resistant bacteria in the environment, in order to determine whether there is a case to be made for deleteriousness as defined in section 34 of the Fisheries Act, or for harm under the MBCA 1994 or SARA, or for damage to or destruction of the residence of an extirpated, endangered or threatened species under SARA.