This joint letter, submitted by Keep Antibiotics Working to the FDA, Docket No. FDA-2010-D-0094, addresses the issue of the FDA not doing enough about the overuse of antibiotics in food animals. The FDA is headed toward a two-part strategy that would attempt to persuade the drug industry to voluntarily withdraw label indications for production uses of antibiotics, such as growth promotion, and then attempt to subject therapeutic and preventive uses of the drugs to greater veterinary oversight.

Such a strategy will not lead to substantial reductions in antibiotic use in animals and thus will not seriously address the tidal wave of costly, resistant human and animal disease we now confront.