The dairyman waved the paper in my face, exclaiming “What am I supposed to do about this? It was a form letter from the FDA, “You are in violation…” A full page of bureaucratic gobbledygook ending with, “Call this phone number.” It didn’t even say what the violation was! I knew, of course, having investigated antibiotic violations for several years, almost one a month.
“I called this number, only to be told that the number had been changed. When I called that number, I was told that the number was disconnected!”
This could give everyone in government a bad rep. I called my office and got the current number for the local FDA agent. This one had better be right! It was, but he wouldn’t give any information over the phone, only asking for an appointment to come see the dairyman. Then I asked “Where do you beef your cows?” “Beefpackers.” Fortunately it was the right time of day when the USDA meat inspector at Beefpackers wasn’t on the floor and was still in his office. I called the meat inspector and was able to get the backtag number of the cow and the antibiotic involved. “Let’s look at your records.” The dairyman pulled up his treatment records on his computer and there it was. The cow had been treated, then sent to slaughter the day the withdrawal time was up.
“There’s your problem. Withdrawal times are determined in healthy cows. Medications sometimes stay longer in sick cows. You need to wait a few days after the withdrawal time is up.”
I asked to see his meds .They were in a room next to the office. Everything was in order, the usual meds a dairy uses, with separate shelves for calves and adult cows. He gave all the meds himself.
Now the dairyman was required to call the meat inspector every time he shipped cows for six months. Every cow would be tested for drugs and antibiotics.
Under federal law, the presence of any antibiotics, drugs, or pesticides in meat and milk is illegal. The use of these substances is highly regulated and they can only be used for approved specific purposes. The length of time that drugs and antibiotics remain in the system, called withdrawal times, have been established. Meat and milk from treated animals cannot legally be sold for human consumption before the withdrawal time has been observed.
Enforcement of all these regulations depends on testing at slaughter and regular inspections of livestock and poultry facilities. Every truckload of milk is tested at the creamery for drugs and antibiotics. At any violation the entire truckload is poured down the drain. The creamery also tests for overall bacterial levels and a somatic cell count. Low levels of bacteria are controlled through pasteurization, but high levels can overwhelm the pasteurization process. At a first violation the creamery docks the pay to the producer. With a repeat violation the producer loses his class A contract and can only sell his milk for cheese or powdered milk.
The Food and Drug Administration (FDA) establishes the regulations and is in charge of enforcement. The U.S. Department of Agriculture (USDA) does the actual testing at slaughter through its meat inspection service (FSIS). One per cent of all livestock and poultry are tested at USDA laboratories. This works well for poultry because most of the poultry comes from large flocks that are treated together. With beef, some of the smaller herds are missed, but the system catches up with them eventually.
My own involvement concerned investigation into violations, averaging about one a month. I also did annual inspections of dairies, feed lots, and poultry producers that included checking on drug regulations. The producer had to maintain records of all medications used, with dates, route of administration, and withdrawal time. Medicated animals were supposed to be kept separate from the rest of the animals. Most dairies had a separate hospital barn where the medicated cows were milked. Those without a separate hospital barn milked the medicated cows last to keep the milk out of the milk tank. Medications for calves and adult cows had to be separated and clearly labeled. Nearly all antibiotics used in human medicine aren’t allowed for livestock and poultry. By far the largest amount of antibiotics used in livestock and poultry are used for growth promotion and shouldn’t even be called antibiotics. At the levels used they have no antimicrobial action.
The FDA did their own investigations of violators and fined repeat violators. Producers usually told me the FDA investigator had also visited them, but I never did meet one. My own investigations were aimed at helping the producers correct the situation. The state had no enforcement provisions.
Pesticides are a different matter. The laws prohibiting pesticides in food still exist, but the tests for detecting pesticides became so refined that micro levels could now be detected. Low levels were being found in five per cent of everything we ate, including organic food. The regulations were modified, establishing maximum levels that could be tolerated. At one time the state of California maintained two laboratories devoted exclusively to testing for pesticides, but these were closed by budget cuts over 20 years ago.
This has never been a significant problem in livestock and poultry. The only pesticides ever approved for use in livestock and poultry are the same ones approved for household use, and they have never showed up in meat or milk. Newer developments of fly control that don’t use pesticides have reduced the use of even these pesticides.
The only case involving pesticides I was ever involved in came with the discovery of DDT in a cow sent to slaughter. The owner was feeding cull carrots to cows in two large fields, dumping the carrots on the ground. The field the cow came from had been planted to grapes 20 years earlier, and we suspected they had been sprayed with DDT. I took soil samples throughout the field but didn’t find any DDT. Then Feed and Fertilizer informed me that they were the lead agency in pesticide investigations. I had never heard of Feed and Fertilizer before. They came out and took more samples but still didn’t find the source of the DDT.
In the meantime the owner moved all of his cows to the other field. Then the meat inspection service told him that he couldn’t sell any more cows to slaughter until they were tested for DDT at his own expense. That could come to more than $50,000! He finally convinced my department to do the testing at state expense. What a hassle that was! The owner’s chutes and squeeze were antiquated and barely working. The cows weren’t used to the squeeze and nearly died in the heat and commotion. We cut a back fat sample from each cow and sent them in. They were all negative for DDT. Much ado about nothing.
Few people realize how closely regulated and inspected antibiotics, drugs and pesticides are. Rather than complaining about antibiotic resistance, we should be complaining about cutbacks in funding for regulation.
copyright Robert C Hargreaves