The FSIS Residue Violation Information System List identifies all producers that have marketed food animals which have tested positive for antibiotic residues at slaughter. The list is updated weekly, ranges from 110 to 140 pages and includes the names, addresses and phone numbers of producers who have marketed animals with antibiotic residues and businesses that have purchased their cattle during the previous 12 months. Not only does this list present a negative image for the cattle industry, but it is a target for increased scrutiny from industry critics. The reputation of individual producers and of the entire livestock industry is at stake.

View comments below from:
, University of Nebraska
, Kansas State University
, Beef Checkoff

Legislation is being considered that would withdraw seven classes of antibiotics from food production unless the animals are sick or unless the drug companies can prove that their use does not harm human health. The effort has the support of the American Medical Association, the American Public Health Association and 350 other groups.

The opinions of groups outside of agriculture also have a significant impact on government policy and consumer purchasing decisions. A good example is the organic section at the grocery store, where sales have steadily risen. Consumer perceptions concerning antibiotic use and misuse in farm animals have helped fuel that growth.

Understand the basics of USDAFSIS residue testing strategy
Four strategies are utilized to test for residues.
1. Random samples are collected from all classes of food-producing animals for targeted compounds such as antibiotics. The aim is to monitor for the presence of residues at or below 1 percent of a targeted class of residues and animals.

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2. Targeted sampling from animals believed to have a higher risk of a residue. Inspectors sample animals they identify that they believe have had a reason to have been treated.

These include evidence of a recent illness such as lameness, mastitis, pneumonia, reproductive infection or gastrointestinal (GI) disease. Additionally, they sample animals that show evidence of having been treated, such as injection site lesions or pills found in the GI tract.

3. Previous residue violator testing. Heightened surveillance residue testing will be done on animals from producers that have had previous residue violations.

4. Exploratory residue monitoring. The Food and Drug Administration (FDA), Department of Environmental Protection (EPA) and Center for Disease Control (CDC) may ask the USDA-FSIS to collect samples for exploring the potential for a residue existence of a compound not previously including in the strategic residue-testing plan. The list, which no responsible livestock producer should be on, can be viewed at http://www.fsis.usda.gov/Scienc/Chemistry/index.asp#NRP PD

Q. Who should be held responsible for antibiotic residues in meat?

Dee Griffin

Feedlot Production Management Veterinarian and Professor
University of Nebraska Great Plains Veterinary Educational Center
dgriffin@gpvec.unl.edu

A. The beef industry

Over-the-counter penicillin and sulfa drugs are giving beef and dairy producers a black eye and they give nothing in return. Meat from the more than 30 million beef and dairy cattle marketed each year is safe, as documented from the last residue report from the United States Department of Agriculture Food Safety Inspection Service (USDA-FSIS).

Where’s the problem?
Consider three pieces of information.

1. Penicillin and sulfa drugs comprise more than half of all violative residues in beef and dairy cattle. The last published USDA-FSIS residue report indicated 7,268 bovine (beef and dairy) were randomly sampled and only four samples were positive for an antibacterial residue (all four were sulfa drugs).

However, the inspectors identified 135,389 bovine (beef or dairy) and of these 1,311 were identified as having a residue from an antibacterial (antibiotic or sulfa drug) … sampled about 1,000 to get one positive. Of these 1,311 violative residues, 424 were penicillin and 331 were sulfa drugs (57.6 percent).

2. Bacterial resistance to penicillin and sulfa drugs make consideration for their use silly. Veterinary diagnosis laboratory testing indicates a high resistance to penicillin and sulfa drugs. An example is available at http://www.vads.org (Veterinary Antibiotic Decision Support Internet site).

Penicillin when dosed three to four times the labeled dose (which requires a veterinary prescription to be legal) only has a peak blood level of 3.4 mg/ ml, which would have no effect on E. coli or Salmonella.

For the respiratory disease-causing bacteria penicillin, typically less than two-thirds are sensitive, but since penicillin has very little ability to penetrate infected tissues, the drug will not likely reach the site of the infection and with its 5.2-hour half-life, would need to be dosed multiple times a day.

Additionally, when the massive doses required are used, the withdrawal time is likely to be in excess of two months and cost is equivalent to newer, more effective medications.

When sulfa drugs are considered, the vads.org data is even worse. The average peak blood level for the various sulfa drugs is approximately 9 mg/ml.

The dose required to inhibit even 10 to 25 percent of the GI or respiratory pathogens is five to 10 times the labeled dose and this would be a toxic dose for cattle, plus would cost more than the most expensive medication available. Considering the information available at vads.org, the use of sulfa drugs on foot rot cannot be supported.

3. Penicillin and sulfa drugs are likely most often used as a placebo and when a producer has an animal that is “really sick,” they most often rely on a medication other than penicillin or sulfa drugs.

God has for millions of years been saving cattle long before any drug company ever marketed an antibiotic. Most of the cattle we treat with penicillin or sulfa drugs get better in spite of us, not from the pen or sulfa we used.

Surveys of producers by the National Animal Monitoring System indicate producers seek veterinary advice when cattle are really sick and veterinarians don’t prescribe penicillin or sulfa drugs as often as they do the newer-technology antibiotics.

Bottom line
Beef and dairy producers get little to no value from the use of penicillin or sulfa drugs and therefore from an economic standpoint should avoid these over-the-counter medications.

Additionally, while the violative antibiotic residue rate in the beef produced in the U.S. is extremely low as our inspection system and our inspectors are tough, testing more than 1,000 they believe are high residue risks to fi nd one violation – the chances of them letting a residue into our food is extremely low.

However, penicillin and sulfa drugs are the majority of the ones they find … it is past time for producers to ask the FDA to get these beef and dairy industry eye-blacking over-the counter medications off the market. They do us no good, provide our naysayers rocks to throw at us and cost us consumer confidence. PD

Q. Who should be held responsible for antibiotic residues in meat?

Dr. Michael Apley DVM

Clinical pharmacologist
Kansas State University
mapley@vet.k-state.edu

A. The dairy industry

I am a veterinarian and clinical pharmacologist who works in the area of food animal drugs with an emphasis in cattle and swine production. A lot of my time now is spent on representing food animal production in the context of national issues such as antibiotic availability. While I am very proud of the vast majority of food animal producers, there are some that are difficult to hold up as examples of judicious use and attention to protocols.

To me, residues say “I don’t care about the person who consumes the product I produce.” Sure, there are occasional mistakes that can happen within the large volumes of animals that we produce.

But as I see the letters to violators published in the FDA Veterinarian (http://www.fda.gov/AnimalVeterinary/NewsEvents/FDAVeterinarianNewsletter/default.htm), it is pretty clear that cull cows present a challenge to some in the industry relating to assigning and adhering to labels or extralabel withdrawal times.

A residue violation is a wakeup call to an individual producer that the system needs to be fixed, no matter what species or product is being produced. A pattern of residue violations is a wakeup call to an industry.

This may mean that the protocols for drug administration, animal identification, withdrawal time determination, withdrawal time adherence (records!!) and final check before shipment may need to be refined.

Some of the major residue offenders in cull cows are penicillin G and flunixin meglumine. Penicillin G, as used by everyone I know, is dosed in excess of the label and therefore must be administered only within a valid veterinaryclient-patient relationship where the veterinarian is responsible for assigning an exaggerated withdrawal time.

This exaggerated withdrawal will be very susceptible to the route of administration (subcutaneous or intramuscular) and volume per site. The whole dose given in one spot subcutaneously will create the need for a major revision in the slaughter and milk withdrawal times, even from an extralabel withdrawal time calculated for 10-15 ml per site. And remember, long-acting penicillin is especially capable of providing some extended residues due to prolonged, low concentrations that are, in my opinion, of questionable therapeutic value.

The flunixin meglumine products are labeled for intravenous use for a reason. They cause significant injection site reactions, which result in the need for a substantially extended withdrawal time.

Also, giving flunixin intramuscularly results in only about 75 percent of the drug being available to the animal as compared to intravenous injection. Before we argue IV vs. IM for this product based on the realities of cows in lockups, why don’t we look to the data?

See if you can find clinical trial data for improved clinical response due to flunixin for any disease in dairy cattle. Not just fever reduction, but actual improvement in therapeutic outcome.

There is no room for violative residues in our food system. Residues are our industry report card on judicious antimicrobial use, and some dairy producers are flunking. The problem is that everyone will pay in the form of drug availability. Isn’t it time we adopt the same intolerance for residue violators in our industry as we have displayed for animal welfare abuse? PD

Q. Who should be held responsible for antibiotic residues in meat?

Drew A. Vermeire

Ph.D., PAS, Dipl. ACAN
Chairman, Beef Checkoff Joint Veal Issues Management/Quality Assurance program
veaux@earthlink.net

A. Veal producers

Every time a consumer enjoys veal piccata, marsala or another great veal dish, it is the culmination of months of work by America’s veal farmers and industry partners. We know that calf health and comfort are critical to the success of every veal farm, and food safety is critical to public confidence in our product.

Veal Quality Assurance Program
In the early 1990s, the Beef Checkoff Veal Quality Assurance program (VQA) was developed by veal farmers to educate all veal industry partners in proper use of animal health products, as well as in facilities management, biosecurity and calf care practices to improve calf care and assure food safety.

With the Beef Checkoff VQA program, both veal farmers and industry partners receive regular training and certification. VQA is more than just a veal industry program; it is a commitment that every segment of the veal industry makes to their calves and their customers.

As a result of this commitment, milk-fed veal consistently enjoys an excellent food safety record, based on annual USDA reporting.

Bob veal – high rate of violative residues
According to USDA, bob veal consistently has one of the highest violative residue rates of any meats.

While many bob calves go from the sale barn to a veal or dairy beef farm, about one in four bull calves go from the sale barn directly to a packing plant, where they are processed as bob veal.

If the calf was fed a typical medicated milk replacer with neomycin and oxytetracycline, or given an injection of antibiotics, there is a high probability that there will be a violative residue in the tissue.

All farmers share responsibility
Veal farmers are one of the dairy industry’s best customers, buying nearly 400,000 bull calves per year, in addition to 100,000 tons of whey, whey protein concentrate and other dairy ingredients. What’s good for the veal farmer is good for the dairyman, as well.

Veal farmers purchase calves that are healthy, uniform and typically weigh more than 90 pounds. Dairymen can increase the value of their calves by increasing the likelihood that a veal farmer will buy that calf.

Dairymen should give four quarts of colostrum to both heifer and bull calves within the first hour after birth, plus another two quarts within the next six hours. Bull calves should not be fed medicated milk replacer if the dairyman is planning on taking the calf to the sale barn.

Of course, any calf that is sick or has been given injectable antibiotics should not leave the farm until the calf is healthy and an adequate withdrawal period has been observed for the antibiotic. Bulls going to the sale barn should be healthy, have received adequate colostrum and have a dry navel.

These practices decrease the likelihood of violative antibiotic residues and increase the likelihood that the calf will go to a veal farm, consume 500 or more pounds of dairy ingredients in its feed and eventually be enjoyed by America’s consumers as a special veal meal. PD