The World Veterinary Association (WVA) is the world’s largest professional, veterinary association. Representing more than 500,000 veterinarians through 95 veterinary member associations on six continents, the WVA unites and is the common voice of the veterinary profession at a global level. The WVA supports the work of veterinarians in diverse areas of medicine, research, practice, and outreach and is guided by its belief in One Health, which recognizes that humans and animals share the natural environment and create harmony with and for each other.
In this context WVA wishes to underline that in recent years the veterinary profession has taken several steps to promote pharmaceutical stewardship and the responsible use of antimicrobials in animals. In a number of countries (with WVA member organisations) the use of antimicrobials in food animals has gone down considerably and in some countries, a decrease of resistance is becoming visible.
WVA looks forward to other health professions joining them and moving forward together in the same direction.
The WVA wishes to commend IACG on the development of the draft recommendations, and is pleased to have the opportunity to give feedback. WVA wishes to offer the following comments:
A. ACCELERATE PROGRESS IN COUNTRIES
Recommendation A1: The IACG calls on all Member States to ensure equitable and affordable access to existing and new quality-assured antimicrobials and their prudent use by competent, licensed professionals across human, animal and plant health.
This recommendation must be supported by efforts both to reduce the need for antimicrobials and improve access through:
a. Lowering the prevalence of infection through clean water, sanitation and hygiene;
b. Decreasing the likelihood of diseases and their spread through delivery of existing vaccines and strengthening infection prevention and control measures;
c.Ensuring best practices in terrestrial and aquatic animal and plant health, food
World Veterinary Association
(WVA)
production and waste management;
d. Supporting behaviour change through effective communication and incentives targeted at the public and professionals in human, terrestrial and aquatic animal and plant health, as well as food production and the environment;
e. Developing national instruments based on international standards for equitable access to and prudent use of existing and new quality-assured antimicrobials in humans, animals, plants and food production, as well as waste and water management in health care, manufacturing and farming-related activities; and f. Strengthening national surveillance, regulatory and accountability mechanisms.
WVA agrees with recommendation A1 about equitable and affordable access to antimicrobials.
However, concerning “… their prudent use by competent, licensed professionals across human, animal and plant health” WVA is of the opinion that further capacity building efforts are needed.
Sufficient numbers of qualified and regulated health professionals, in our case licensed veterinarians, covering all areas where antimicrobials are used, are crucial for achieving prudent use goals.
WVA agrees that in settings where trained prescribers are in short supply, students of veterinary medicine and paraprofessionals may also be trained and authorised to prescribe or administer some antimicrobial agents under the supervision of a licensed veterinarian, however this may not lead to structurally replacing prescribers by paraprofessionals. WVA believes that antimicrobial use in animals should only be under direction of a veterinarian, even if necessity in some cases requires that this be by a paraprofessional under the direction of a veterinarian. “Equitable access” does not mean that antimicrobials for animals can be accessed without veterinary oversight and appropriate regulation. As much as possible the properly educated paraprofessionals should work under the responsibility of and have close communication with the licensed veterinarian.
Regarding supporting action c, about ensuring best practices in terrestrial and aquatic animal health, WVA would like to suggest including here, similar to point b, -the delivery of existing vaccines and strengthening infection prevention and control measures. More-over WVA strongly recommends adding a similar action point for ensuring best practices in the medical field.
In relation to point f, WVA wishes to underline the importance of transparency in the use of antimicrobials. Record keeping and data collection on the use of antimicrobials, together with qualitative and quantitative data on the occurrence of antimicrobial resistance, are indispensable for identifying future goals and for monitoring the progress made in the achievement of such goals.
Recommendation A2: The IACG calls on all Member States to accelerate the development and implementation of One Health National Antimicrobial Resistance Action Plans within the context of the SDGs that, at a minimum, include:
a.Prioritized actions and interventions that are specific to the national context and that are costed and funded, including with adequate domestic resource allocations;
b. Strengthening key national systems for infection prevention, monitoring, integrated surveillance, procurement of health commodities and waste management;
c. Technical co-operation, capacity development, research and advocacy components, including support for champions at national and local levels to mobilize action on antimicrobial resistance;
and
d. Effective national coordination, accountability and governance mechanisms.
Concerning Recommendation A2, WVA fully supports the accelerated development and implementation of One Health National AMR Action Plans but wishes to remark that for this task, collaboration between the Member States authorities and private partners is indispensable. Private entities, associations, companies, etc, have to be involved and engaged in the development and implementation of the action plans. Good communication between the public (governmental) and the private partners and vice versa needs to be assured.
Recommendation A3: The IACG calls on all Member States to phase out the use of antimicrobials for growth promotion, consistent with guidance from the Tripartite agencies (FAO, OIE and WHO), starting with an immediate end to the use of the Highest Priority Critically Important Antibiotic Agents (i.e. quinolones, third- and higher- generation cephalosporins, macrolides and ketolides, glycopeptides and polymyxins).
WVA agrees with the Recommendation to phase out the use of antimicrobials as growth promoters in food producing animals. WVA also agrees with an immediate end to the use of the Highest Priority Critically Important Antibiotic Agents (WHO list) as growth promoters
WVA notes that in the OIE third annual report on the use of antimicrobial agents intended for use in animals (2019) no countries reported the use of glycopeptides, ketolides or cephalosporins of any generation for growth promotion.
WVA would also like to suggest complementing this action by setting strict conditions for the use of the Highest Priority Critically Important Antibiotic Agents (WHO list) for therapeutic use in animals and people. Given the importance of this category of antimicrobials they should only be used when no proper alternative treatment is available. Similar to the WHO Guidelines on the use of medically important antimicrobials in food-producing animals, guidelines for a restricted use in people could be developed. Complementing actions in the medical and veterinary field will create a synergistic effect.
WVA supports the IACG statement that “It is particularly important that all countries employ appropriate risk analysis - the process of hazard identification and risk assessment, management and communication - as described in the OIE Terrestrial Animal and Aquatic Animal Health Codes. Such risk analyses should be unbiased assessments that transparently present the evidence base for findings and recommendations and be subject to peer review”. WVA believes that the availability of high quality peer reviewed risk analyses will enable improved ability to set priorities and manage risks.
B. INNOVATE TO SECURE THE FUTURE
Recommendation B1: The IACG calls upon public, private and philanthropic donors and other funders to increase investment and innovation in new antimicrobials - particularly antibiotics, as well as new diagnostics, vaccines, waste management tools, and safe and effective alternatives to
antimicrobials - for human, terrestrial and aquatic animal and plant health through:
a.Financial and non-financial incentives strategically targeting the most important research and development needs, scientific challenges, and market barriers based on the principles of affordability, effectiveness, efficiency and equity, as outlined in the 2016 UN Political Declaration on Antimicrobial Resistance; and
b. Building upon existing Product Development Partnerships in human health and establishing more of them, particularly for terrestrial and aquatic animal and plant health.
WVA agrees with the recommendation to “increase investment and innovation in new antimicrobials - particularly antibiotics, as well as diagnostics, vaccines, waste management tools, and safe and effective alternatives to antimicrobials” but we also believe that certainly on the animal health side research into good husbandry practices (biosecurity, animal resilience, herd health plans) is as important as searching for new antimicrobials or alternative treatments.
We estimate that more can be gained by keeping animals under proper conditions they can cope with and that require less medical interventions than through new antimicrobials. Disease prevention through good husbandry and animal welfare practices is also likely to be more sustainable than new antimicrobials which will trigger new resistance mechanisms.
Recommendation B2: The IACG recommends that existing and future global access initiatives should promote and support equitable and affordable access to existing and new antimicrobials, diagnostics, vaccines, waste management tools and safe and effective alternatives to antibiotics for human, terrestrial and aquatic animal and plant health.
WVA wishes to add that an important factor related to “access to existing and new antimicrobials” is assurance that the antimicrobials are of high quality and are used correctly. Recent publications from the OIE show that several countries do not yet have complete and relevant legislation and/or accompanying compliance programmes to ensure appropriate conditions for the import, manufacturing, distribution and use of veterinary medicinal products, including antimicrobial agents.
As a result, substandard or falsified agents may circulate and create conditions of high risk for the development and spread of resistance.
Recommendation B3: The IACG calls upon public, private and philanthropic research funders and other stakeholders to build upon current research and development efforts and strengthen research collaboration in a One Health context by:
a. Undertaking coordinated global mapping of research and development activities and funding to address antimicrobial resistance;
b. Establishing and maintaining a platform for sharing information on research and compounds in development in both ongoing and completed research and development activities;
c. Promoting synergies and opportunities for collaboration among funders and researchers in human, animal and plant health, and the environment; and
d. Promoting openness and transparency in data from all research and monitoring and surveillance sources.