BILL ANALYSIS                                                                                                                                                                                                    �



                                                                  SB 835
                                                                  Page  1

          Date of Hearing:   July 2, 2014

                        ASSEMBLY COMMITTEE ON APPROPRIATIONS
                                  Mike Gatto, Chair

                      SB 835 (Hill) - As Amended:  June 4, 2014

          Policy Committee:                               
          AgricultureVote:7-0

          Urgency:     No                   State Mandated Local Program:  
          Yes    Reimbursable:              No

           SUMMARY  

          This bill codifies the US Food and Drug Administration (FDA)  
          Guidance for Industry #213, requiring the Secretary (Secretary)  
          of the California Department of Food and Agriculture (CDFA) to  
          refuse to register a drug administered in the feed or drinking  
          water of food animals if that drug is a medically important  
          antimicrobial drug.  Specifically, this bill:

          1)Defines "medically important antimicrobial drug" as a drug  
            listed in the FDA Guidance for Industry #152, which  
            categorizes those drugs as critically important, highly  
            important, or important antimicrobial drugs.

          2)Requires the Secretary to refuse to register a medically  
            important antimicrobial drug administered to food animals  
            through feed or drinking water unless the drug complies with  
            the following requirements:

             a)   The drug manufacturer has removed growth promotion and  
               feed efficiency from the approved uses on the drug label.

             b)   The drug manufacturer has ceased offering the drug over  
               the counter and requires a veterinary feed directive if the  
               drug is to be administered in animal feed or a veterinary  
               prescription if the drug is to be administered in drinking  
               water.

             c)   The drug administered through feed or water is used only  
               under the supervision of a veterinarian to treat, prevent,  
               or control disease.









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          3)Requires a "veterinarian-client-patient" relationship (as  
            defined under existing regulations) exist to ensure that  
            medically important antimicrobial drugs are used according to  
            professionally accepted best practices.

          4)Requires drug manufacturers to comply with these provisions by  
            January 1, 2017, and reregister medically important  
            antimicrobial drugs with the Secretary, although the Secretary  
            may continue to register a drug during the FDA's review period  
            under Guidance for Industry #213 if that period is delayed  
            beyond January 1, 2017 or extend the implementation date if  
            the FDA delays implementation of the Guidance.




           FISCAL EFFECT  

          Minor and absorbable loss of revenue to CDFA as a result of  
          reductions in registration fees currently paid for medically  
          important antimicrobial drugs; negligible enforcement costs to  
          the Veterinary Medical Board.

           COMMENTS  

          1)  Purpose.   According to the author, this bill will help  
            preserve the effectiveness of medically important  
            antimicrobial drugs through codification of FDA guidance to  
            phase out nontherapeutic use of those drugs in food-producing  
            animals.  Supporters assert the bill will prohibit use of  
            medically important antimicrobials for growth promotion and  
            feed efficiency while requiring veterinary oversight of drug  
            use, ensuring antibiotics are used only to treat sick animals  
            and control the spread of disease.

          2)  Antibiotic Resistant Bacteria.   The Centers for Disease  
            Control (CDC) estimates more than two million people are  
            infected with antibiotic-resistant bacteria in the United  
            States each year, with at least 23,000 of those infections  
            resulting in death.  The CDC claims the use of antibiotics is  
            the single most important factor leading to antibiotic  
            resistance around the world.  According to the World Health  
            Organization, antibiotics are used in greater quantities in  
            healthy food-producing animals than in the treatment of  
            disease in humans.








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            In response to growing antibiotic resistance, the FDA issued  
            several industry recommendations regarding the use of  
            medically important antimicrobial drugs in the feed and  
            drinking water of food-producing animals.  The recommendations  
            contained in Guidance for Industry #152, #213, and #219  
            establish lists of antibiotics important to human health,  
            promote judicious use of those drugs in food production, and  
            encourage veterinary oversight to ensure compliance with  
            industry best practices.

          3)  Opposition.   Opponents, including CALPIRG and the Center for  
            Food Safety, argue the bill does not go far enough to prevent  
            the inappropriate use of antibiotics on food-producing  
            animals.  In particular, opponents claim that many antibiotics  
            are used for multiple purposes, including growth promotion as  
            well as disease prevention, and this bill would not restrict  
            that use so long as disease prevention was at least one of the  
            objectives for use.  As a result, opponents argue total use of  
            medically important antimicrobials will not be significantly  
            reduced, and that only a prohibition on all use except for the  
            treatment of sick animals will lead to meaningful reductions.

          4)  Staff Comment.   While the bill currently states that "[t]here  
            shall be a veterinarian-client-patient relationship" to ensure  
            the use of medically important antimicrobials is consistent  
            with best practices, it is silent as to who is responsible,  
            and therefore may be held accountable, for ensuring the  
            existence of the relationship.

            The author and the Committee may wish to consider amending the  
            paragraph beginning page 4, line 5 to clarify that "no person  
            shall administer a medically important antimicrobial drug"  
            through feed or drinking water except pursuant to a  
            veterinarian-client-patient relationship.



          4)  Related Legislation.  

             a)   SB 1311 (Hill) requires general acute care hospitals to  
               implement an antimicrobial stewardship policy that meets  
               specified criteria, and to report to the Legislature by  
               January 1, 2018 on hospital compliance with the  
               requirement.  SB 1311 is before this committee today.








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             b)   AB 1437 (Mullin) bans the sale, in California, of a  
               livestock or poultry product if the animal was given a  
               medically important antimicrobial for nontherapeutic use.   
               AB 1437 is in the Assembly Agriculture Committee, and has  
               not been heard.


           Analysis Prepared by  :    Joel Tashjian / APPR. / (916) 319-2081