19
Feb
Take Action: Stop Antibiotic Use in Citrus Production
(Beyond Pesticides, February 19, 2019) At the request of Beyond Pesticides, the Environmental Protection Agency (EPA) has extended its public comment period on antibiotics in citrus production until March 14. With this extra time, please share this action widely to stop this threat.
If you have already written your member of Congress to comment on this, please consider distributing this action broadly and submitting a comment to EPA.
We have a two-part action for you to take.
- Use our online form to send a letter to Congress.
- Leave a comment on the EPA docket at regulations.gov.Please personalize our messages by adding your own story, or that of a loved one. Let your representatives and the EPA know why you want to prevent bacterial resistance!
Background
Despite the building national and international crisis of deadly bacterial resistance to antibiotics, this new allowance would expand on an emergency use decision the Environmental Protection Agency made in 2017. It permits up to 480,000 acres of citrus trees in Florida to be treated with more than 650,000 pounds of streptomycin per year; 23,000 citrus acres in California will likely be treated annually.
The World Health Organization has called bacterial resistance “one of the biggest threats to global health, food security, and development today.” The two approved antibacterial chemicals to be used as pesticides in citrus production are streptomycin and oxytetracycline. Their use was permitted by the U.S. Environmental Protection Agency (EPA) under an emergency exemption in May, 2017 for a citrus greening disease caused by the bacterium Candidatus Liberibacter asiaticus (CLas) in Florida citrus crops through December of 2019.
The Environmental Protection Agency announced March 15, “EPA is issuing these tolerances without notice and opportunity for public comment as provided in FFDCA [Federal Food, Drug and Cosmetic Act] section 408(l)(6).” EPA states, “[T]ime-limited tolerances are established for residues of streptomycin in or on fruit, citrus, group 10-10, at 2 ppm, and the dried pulp of these commodities at 6 ppm.” For oxytetracycline, EPA is allowing residues “in or on all commodities of fruit, citrus, group 10-10, at 0.4 ppm.” [See below; organic standards do not allow antibiotic use.] Now, EPA is moving forward with a permanent allowance of these chemicals.
See Agricultural Uses of Antibiotics Escalate Bacterial Resistance. Beyond Pesticides, with other organizations, led a successful effort to remove antibiotics from organic apple and pear production because of their contribution to antibiotic resistance and the availability of alternative practices and inputs.
As bacteria become resistant to the most commonly prescribed antibiotics, the results are longer-lasting infections, higher medical expenses, the need for more costly or hazardous medications, and the inability to treat life-threatening infections. The development and spread of antibiotic resistance is the inevitable effect of antibiotic use. Bacteria evolve quickly, and antibiotics provide strong selection pressure for those strains with genes for resistance. Both antibiotics proposed for expanded use are important for fighting human disease. Tetracycline is used for many common infections of the respiratory tract, sinuses, middle ear, and urinary tract, as well as for anthrax, plague, cholera, and Legionnaire’s disease, though it is used less frequently because of resistance. Streptomycin is used for tuberculosis, tularemia, plague, bacterial endocarditis, brucellosis, and other diseases, but its usefulness is limited by widespread resistance (U.S. National Library of Medicine, 2006).
Exposure to antibiotics can disturb the microbiota in the gut. In addition to interfering with digestion, a disrupted gut microbiome can contribute to a whole host of “21st century diseases,” including diabetes, obesity, food allergies, heart disease, antibiotic-resistant infections, cancer, asthma, autism, irritable bowel syndrome, multiple sclerosis, rheumatoid arthritis, celiac disease, inflammatory bowel disease, and more. Furthermore, the human immune system is largely composed of microbiota.
Actions
- Using this form, Tell your U.S. Senators and Representative to urge EPA to reject the use of antibiotics in food production, including citrus production.
- Please put your comment in the EPA docket at REGULATIONS.GOV (a few extra clicks!)
You can cut-and-paste the language below (“Comment to EPA”) and submit it to the EPA docket at Regulations.gov. If you have a personal story with antibiotic resistance, please begin your comment with that. Reach out to others, including medical personnel, who can share their experiences with EPA.
Comment to EPA (cut-and-paste in EPA’s REGULATIONS.GOV; add personal perspective)
I write to urge EPA to reject the use of antibiotics, including streptomycin and oxytetracycline, in citrus production. This creates a public health threat that EPA must consider in real terms, as it relates to longer-lasting infections, higher medical expenses, the need for more costly or hazardous medications, and the inability to treat life-threatening infections. Antibiotic resistance is a real and urgent public health threat and represents an existential threat to modern civilization.
Antibiotic resistance kills over 23,000 people each year, according to the Centers for Disease Control and Prevention (CDC). In addition to the CDC, the World Health Organization has cited this escalating problem as one of the biggest public health challenges of our time.
“By 2050, resistance is estimated to add 10 million annual deaths globally with a cumulative cost to the world economy of US$100 trillion,” said Jack Heinemann, PhD, University of Canterbury’s School of Biological Sciences. Exposure to antibiotics can disturb the microbiota in the gut. In addition to interfering with digestion, a disrupted gut microbiome can contribute to a whole host of “21st century diseases,” including diabetes, obesity, food allergies, heart disease, antibiotic-resistant infections, cancer, asthma, autism, irritable bowel syndrome, multiple sclerosis, rheumatoid arthritis, celiac disease, inflammatory bowel disease, and more. The human immune system is largely composed of microbiota.
Note that it may not be widely appreciated that use of antibiotics on fruit trees can contribute to resistance to the antibiotic in human pathogens. The human pathogenic organisms themselves do not need to be sprayed by the antibiotic because movement of genes in bacteria is not solely “vertical,” that is from parent to progeny—but can be “horizontal”— from one bacterial species to another. So, a pool of resistant soil bacteria or commensal gut bacteria can provide the genetic material for resistance in human pathogens.
Consider the real cost to the American people and internationally and prohibit the use of streptomycin and oxytetracycline in citrus production by setting a tolerance or allowable residue of zero.
Thank you.
