This Blog has been pointing out the risk of Superbugs in both community and hospitals for two years, risks mainly caused or contributed to by CAFO factory farms (see here, here, here, here, here, here, here, here, here, here, here, here, here, here, here, here, here, here, here, here, here, and here).
Twenty-two posts in 2 years, just on Superbugs and antibiotics. Now I clearly see why I'm behind on getting my farm chores done. It's not that I am trying to be a broken record. This is a critical issue, and a complex issue. These two simultaneous factors create many issues that need to be examined in great depth to properly understand the overall subject of Superbugs and antimicrobials.
The CAFO CaperCAFO (Concentrated Animal Feeding Operations), both within and outside of Supply Management for chickens, turkeys, and dairy, are the epicenter of causing or contributing to Superbugs that infect &/or kill Canadians.
CAFO's are well known for creating Superbugs, usually due to the crazy, indiscriminate, or illegal use of antibiotics so as to make higher profits for these greedy CAFO operators and their Big Food partners.
CAFO's are known reservoirs of Superbugs, CAFO's store Superbugs they created themselves, and/or Superbugs imported from elsewhere. These Superbugs are stored inside CAFO's due to the dysfunctional processes of CAFO's. Slowly & continuously, these Superbugs bleed out into the community as unwelcome hitchhikers on the movement of the CAFO animals, the CAFO employees as they go back and forth from home to work, and on suppliers who visit the CAFO.
As Superbugs from CAFO's bleed out into the neighbouring communities, people get sick from those Superbug infections. When you suddenly get sick, it's natural to go to the nearest hospital to seek help. Hospitals are continuously bombarded by Superbugs, one wave after another. Most of the Superbug bombardments of hospitals originate from dysfunctional CAFO's.
Some hospitals have effective programs to prevent and control pathogens in hospitals. However, when these "state of the art" infection control systems are continuously swamped by a tsunami of Superbugs, those hospital systems become overwhelmed. With an unseen, microscopic Superbug enemy, it is hard to keep focused and effective vigilance by all staff and all patients on a 24-7-365 basis.
Most hospitals are far from perfect on their infection control systems, ending up adding to the resistance and strength of the Superbugs that continuously arrive at the doors of these hospitals. Half-hearted disinfection efforts in these hospitals strengthens the resident Superbugs more and more each day, helping them gain experience at surviving all chemical disinfectants and methods that are used superficially. Eventually, even if the hospital moves from superficial to best available disinfection, the stronger and more experienced Superbugs are resistant to even the best efforts. The strong and experienced Superbugs can no longer be defeated by the best available methods. More and more patients and hospital staff are infected, and some die.
Canada's Auditor-General FindingsCanada's Auditor General reported:
"... the Department [Health Canada] has not strengthened existing regulations to prohibit farmers from importing unlicensed non-prescription antimicrobial drugs that are important to human medicine for use in their own animals. The Department does not assess these drugs for quality, safety, or efficacy. According to the Department, the use of these drugs in food animals may have serious public health implications, including the development of antimicrobial resistance. Furthermore, the Department allows certain antimicrobials that are used to treat serious infections in humans to be sold without a prescription for use in food animals"and
"Health Canada is aware that regulations presently do not prohibit the importation of non-prescription antimicrobial drugs important to human medicine that have not been licensed for sale in Canada, on the condition that these drugs will not be resold. As a result, farmers are able to import these drugs and use them in their own animals. This is often referred to as “own-use importation.”Note that the AG's statement "import these drugs and use them in their own animals" refers to farm animals that subsequently become food for Canadians (eg. beef, pork, chicken, turkeys, lamb, etc.).
"The Department is also aware that there are few regulatory controls over the importation of veterinary active pharmaceutical ingredients — including ingredients used in antimicrobial drugs important to human medicine. Health Canada has concerns about the importation and direct use of these ingredients in food animals."Note that "veterinary active pharmaceutical ingredients" referenced above are bulk drugs immediately prior to being packaged into veterinary drugs (eg. pills, vials, ampules, etc.). Buying bulk drugs are significantly cheaper, and mainly escape regulatory controls though loopholes used by CAFO farmers, Big Food, and/or their henchmen.
When CAFO farms use 75% of all drugs manufactured (ie. only 25% are used for humans), you can better understand why CAFO farmers (and the animal feed manufacturers who sell to CAFO farmers), import, buy, and use "veterinary active pharmaceutical ingredients".
"Public Health Agency of Canada (the Agency) and Health Canada (the Department) have not fulfilled key responsibilities to mitigate the public health risks posed by the emergence and spread of antimicrobial resistance in Canada"Canada's Auditor General made a good start, but in our opinion, didn't go far enough on this critical issue that is killing Canadians.
We'd like to add some Small Flocker icing to the Auditor-General's cake.
Small Flockers RecommendationsWhile the Federal Government needed their collective noses rubbed in this growing mess they helped create, what about the CAFO farmers?
Is there no social or moral responsibility to do what is right, regardless of any loopholes that may exist in the government's regulation? Do CAFO farmers have full right and no responsibility for running amok?
I think CAFO farmers, and all others who misuse antimicrobials, need to curtail their reckless behaviours, no matter what loopholes may exist in the past, current, or future regulations.
For Supply Management regulations that enable CAFO chickens, turkeys, and dairy, there will always be a gap between available technologies newly emerged, and the regulations. Regulations will always be behind the time, and must always catch up to latest emerging technologies, or the craziness of out of control or imprudent individuals.
Small Flock Poultry Farmers of Canada recommend revising Canada's Supply Management regulations to:
- Expressly require prudent and reasonable actions by all Boards and others who are created or regulated, including the quota-bearing SM farmers;
- Expressly imposes a duty on all parties who are created or regulated to always act in the best interest of the Canadian public;
- Expressly impose a duty for all parties who are created or regulated to consider the Precautionary Principle prior to all decisions, and periodically consider it for all duties; and apply those Precautionary Principle when it is prudent to do so;
- Expressly legislate that all parties who are created or regulated have no immunity, and have civil liability for their criminal acts, bad faith, conflicts of interests, negligence, and their other tortuous actions and inactions;
- Expressly legislate that the Officers, and Directors of all Boards who are created or regulated have unlimited personally liable for their criminal, bad faith, conflicts of interest, or negligent actions and inactions that they personally do, and are done by their organization with their knowledge and their approval or acquiescence while they hold their position;
- Expressly regulate civil and/or quasi-criminal penalties for non-compliance or breach of these fiduciary duties and/or the regulations.
- Expressly regulate mandatory planning and implementation of regular internal quality and risk auditing by competent, objective, and unbiased auditors for compliance and effectiveness; and external auditing by competent, objective, and unbiased third party quality & risk management auditors at least annually; require timely remedial actions to prevent, contain, mitigate, and remedy non-compliances and significant risks; and re-auditing of all remedial actions to ensure they are completed in a timely manner, and are effective.
- Expressly regulate that any fine, liabilities, penalties or damage awards owed or paid cannot be reimbursed by the public purse; nor can an individual be reimbursed by their organization for any fine, liabilities, penalties or damage awards owed or paid by the individual; nor can any fine, liabilities, penalties or damage awards owed or paid be considered as a valid cost in calculating COP (Cost of Production), reasonable profit, overhead, levies, or other fee that gets passed on to downstream customers or retail consumers;
- Expressly regulate that any interested party can complain and/or appeal against the actions and/or inactions on these 10 issues by all parties who are created or regulated;
- Expressly regulate mandatory pro-active and ongoing disclosure in a comprehensive and timely manner by all parties who are created or regulated, so as to publicly disclose all potential conflicts of interest, and be fully open, transparent, and accountable; including but not limited to the internal and external quality & risk management audits.
Let it be so.