As medical, health, consumer, environmental and other groups deeply concerned about the growing health crisis of antibiotic resistance, we write to ask that you help address this problem - or at least refrain from exacerbating it - by ensuring that legislation to streamline approvals of certain drugs for use in animals does not apply inappropriately to antibiotics for use in food-producing animals. Unfortunately, the Minor Use/Minor Species Act (MUMS, S. 741) has no such limitations. We strongly urge that such a provision be incorporated prior to consideration of the MUMS bill in the 108th Congress.

Failure to limit the coverage of antibiotics under MUMS would constitute a significant step in exactly the wrong direction. MUMS authorizes the Food and Drug Administration (FDA) to issue conditional approvals, good for up to 5½ years, without full evidence of efficacy, for all uses in "minor species" of animals (a category that includes fish and shellfish) and for "minor uses" in major species (a category that includes cattle, swine, chickens, and turkeys). The term "minor use" is broadly defined to mean use in response to a situation that "occurs infrequently or in limited geographical areas." In addition, the bill would create an index of drugs that may be lawfully marketed for use in fish and other minor species in certain circumstances, thus allowing use of these drugs even though they have not been approved for use in those species. Although drug-residue issues are to be evaluated, the criteria for listing drugs on the index do not allow for consideration of any other issue related to antibiotic resistance.

Simply put, hastening wider use of antibiotics in agriculture and aquaculture makes no sense at a time when antibiotic resistance is an emerging public health crisis. The more widely that antibiotics are used, the more quickly resistance will arise and spread. Although definitive data are not available, it is clear that agricultural use of antimicrobials already accounts for half or more of the usage of these drugs in the U.S. It is particularly egregious to allow additional antibiotic use in food-producing animals absent full evidence that the antibiotics are effective as administered.

In short, Congress should be telling FDA to apply more, not less, scrutiny to uses of antibiotics in agriculture and aquaculture. Unless the MUMS legislation contains an appropriate exclusion for antibiotics, we will oppose the bill.

ACCORD Ag., Inc. (TX)
Adrian Dominican Sisters
American Academy of Pediatrics-Maine Chapter
American College of Preventive Medicine
American Holistic Nurses' Association
American Livestock Breeds Conservancy
American P.I.E. (MN)
American Public Health Association
Amigos Bravos (NM)
Association of Maternal & Child Health Programs
Audubon Society of NY State/Audubon International
Blue Heron Environmental Network (WV)
Border Ecology Project (AZ)
The Breast Cancer Fund
Center for Earth Spirituality and Rural Ministry (MN)
Center for Food Safety
Center for Science in the Public Interest
Children's Health Environmental Coalition
Coalition for a Clean Minnesota River (MN)
Concerned Citizens of Freedom Township (OH)
Concerned Citizens of Hidden Meadows (CA)
Consumer Federation of America
Consumer Policy Institute/Consumers Union
Cumberland Countians for Peace and Justice (TN)
Delmarva Poultry Justice Alliance
Department of the Planet Earth
Doris Day Animal League
Earth Day Coalition (OH)
ECO-Action (FL)
ECO-Store (FL)
Endangered Habitats League
Environmental Advocates of New York
Environmental Defense
F.H. King: Students of Sustainable Agriculture (WI)
Family Farms for the Future (MO)
Farm Sanctuary (NY)
Food Animal Concerns Trust
Friends of Miller Peninsula State Park (WA)
Friends of the Nanticoke River (MD)
Generation Green (IL)
Glenview (IL) Prairie Preservation Project
Government Accountability Project
GRACE Public Fund
Grass-Roots (NY)
Hardy Groves, Inc. (FL)
Hoosier Environmental Council (IN)
Humane Society of the United States
Huntington (NY) Breast Cancer Action Coalition
Institute for Agriculture and Trade Policy
Institute for Children's Environmental Health
Iowa Environmental Council
Izaak Walton League of America, Ohio
Kentucky Waterways Alliance, Inc.
Kettle Range (WA) Conservation Group
Kooskooskie Fish (WA)
MacArthur Agro-Ecology Research Center (FL)
Maine People's Alliance
Mankato Area Environmentalists (MN)
Mangrove Action Project (WA)
Marine Environmental Consortium
Michigan Antibiotic Resistance Reduction Coalition
National Catholic Rural Life Conference
Neighbors Against Pollution (OH)
Neponset River (MA) Watershed Association
Neuse River (NC) Foundation
Northeast Organic Farming Association (MA)
Northwest Environmental Defense Center
Obed (TN) Watershed Association
Ohio Ecological Food and Farm Association
Oregon State Public Interest Research Group
Park County (MT) Environmental Council
PCC Farmland Fund (WA)
Pennsylvanians for Environmental Protection
Philadelphia Fair Food Project
Potomac River Association (MD)
Preserve Wild Santee (CA)
Regional Farm and Food Project (NY)
Rivers Foundation of the Americas
Roseland Organic Farms (MI)
Safe Home Farm (WI)
San Francisco Medical Society
Savannah (GA) Riverkeeper, Inc.
Seavey Funds, Inc. (CA)
Seavey Vineyards (CA)
Sharing Help Awareness United Network (IA)
Sierra Club
South End/Lower Roxbury (MA) Open Space Land Trust
State Medical Society of Wisconsin
Stonyfield Farms, Inc. (NH)
Stream Team 714 (MO)
Students Improving the Lives of Animals
Sustainable Earth (IN)
Tools for Change Institute (WA)
U.S. Environmental Watch
Union of Concerned Scientists
United Church of Christ - Network for Environmental & Economic Responsibility
Virginia Forest Watch
The Washington Biotechnology Action Council
Waukesha County (WI) Environmental Action League
West Virginia Rivers Coalition
Western Nebraska Resources Council
Wildlife Action, Inc.
Wyoming Outdoor Council