June 7, 2010 - ASM Comments on Antimicrobial Resistance

Department of Health and Human Services
HHS Hubert H. Humphrey Building
200 Independence Avenue, SW,
Washington, DC, 20201

Re:  HHS Stakeholder Listening Session on the Trans-Atlantic Task Force on Antimicrobial Resistance

The American Society for Microbiology (ASM) appreciates the opportunity to provide initial informal comments for the June 7 Department of Health and Human Services Stakeholder Listening Session, convened to discuss the work of the Trans-Atlantic Task Force on Antimicrobial Resistance (TATFAR). We commend the establishment of a transatlantic task force on urgent antimicrobial resistance issues and very much look forward to working with the Task Force on this important topic. The ASM, which represents approximately 40,000 members in microbiology related professions, strongly believes that microbial resistance to therapeutic drugs threatens public health worldwide, and that aggressive and prompt action on a global scale is needed to decrease damage done to human medicine by microbial resistance.

Infections caused by resistant pathogens result in higher morbidity and mortality from treatment failures, as well as increased healthcare costs as newer, more expensive therapeutics are needed to treat common infections. As multi-drug resistance has spread, we are already encountering infections that cannot be treated with any available antibiotics. Recognizing the imperative to address this issue internationally, the ASM is very pleased by the efforts of the US government to coordinate preventive activities and share information with other countries.

The evolution of antimicrobial resistance among microorganisms is both inevitable and persistent, caused by spontaneous microbial mutations or horizontal gene transfer and the natural selection of resistant organisms that survive in the presence of specific drugs. Forty years ago most clinically important pathogens could be killed by available drugs. Today, the therapeutic situation is quite different as an ever increasing number of pathogens evolve resistance mechanisms. Natural and human-caused factors have accelerated the evolution and spread of drug resistance.  Key among these factors are the overuse and misuse of antimicrobials to treat both human and animal infections.

Antimicrobial resistance related to food production has potential for serious economic and health consequences, not only in human medicine but in the prevention of infections in animal and plants. Because the United States imports many foods, antibiotic usage outside the United States presents a great challenge in controlling the problem in this country. It is, therefore, essential that meaningful international standards be established and that the US play a role in developing policies for antimicrobial use set by other governments and the World Health Organization.

Increased attention to, and support for prevention, detection and control of antimicrobial resistance are needed. Public education and prudent antimicrobial use practices are important to decrease the current prevalence of drug resistant pathogens. It is critical to achieve appropriate antimicrobial use and prevent the spread of drug-resistant infections in both clinical and community settings. Adequate funding and personnel will be needed to achieve these goals. Greater support will also be needed for basic, clinical and epidemiologic research programs to discover optimal ways to prevent transmission and to develop countermeasures against drug resistance. Private industry must also be encouraged to increase the pipeline of new products to replace or reinforce diagnostics, treatments and prevention measures that have become outdated by multidrug resistant pathogens.

The ASM believes that policy related to antimicrobial resistance should be science based and therefore is supportive of research that will help guide future policymaking and identify features of resistant bacteria that might not be fully appreciated today. The need for further research does not mean that immediate actions cannot be taken, but additional research is prudent in that it might influence the path of policy in the future. Only through well-supported research programs will we find alternatives able to curtail the spread of newly resistant pathogens.

We recommend that the Task Force review the lessons learned by the global community, most notably the experience of European countries that have maintained low levels of MRSA and minimized problems with resistant foodborne pathogens through the banning of antibiotics as animal growth promoters. Because policies and use vary widely among European countries, especially between the northern and southern countries, it is possible to conduct informative research there on patterns of antimicrobial use, research that would be difficult in the US where usage tends to be more similar from place to place.

The ASM has been involved in this critical issue for years, both in the United States and in cooperation with international groups, working toward prevention and reduction of antimicrobial resistance. In 1994, ASM formed a Task Force on Antimicrobial Resistance to analyze the best available information related to this issue and to assist in making well-informed public health policy. ASM also has provided extensive expert commentary on the DHHS interagency Antimicrobial Resistance Action Plan, as well as comments on federal legislation related to antimicrobial resistance. The ASM is well aware that antimicrobial resistance will never entirely disappear, but is confident that specific actions can be taken to ameliorate the problem. These actions, however, must be predicated on the understanding that there are multiple causes and that each must receive appropriate attention and financial resources.

The ASM is very supportive of the TATFAR and wishes to assist in any way possible. In the short time available, we have submitted these preliminary comments and welcome the opportunity to provide more extensive testimony on the many aspects of antimicrobial resistance. It would be helpful to know specifically how the ASM can interact with the Task Force as it proceeds with its work on antimicrobial resistance.

Sincerely,

Roberto Kolter, Ph.D., President, ASM
Ruth L. Berkelman, M.D., Chair, Public and Scientific Affairs Board
Gail H. Cassell, Ph.D., Chair, Committee on Biomedical Research
Stephen M. Ostroff, M.D., Chair, Committee on Public Health

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