Comments submitted on May 22, 2006 to FDA re: Docket No. 2006N-0106

KAW believes the need to use the four anti-influenza drugs to respond to zoonotic infections alone is sufficient public health justification for prohibiting their use in poultry, but it would be unconscionable if use of these drugs in food animals deprived public health officials of their use in response to a human pandemic.

KAW recommends that the extralabel prohibition be extended to include all food-producing animals. The use of these drugs in any food-producing animals has the potential to select for resistance which could compromise the use of these drugs in treating human influenza infections including infections occurring as part of an influenza pandemic.