The Honorable Stephen Ostroff, M.D.

Acting Commissioner
c/o Division of Dockets Management (HFA-305)
U.S. Food and Drug Administration
5630 Fishers Lane, Room 1061
Rockville, MD 20852
RE: Docket No. FDA-2012-N-0447, Antimicrobial Animal Drug Sales and Distribution Reporting,
Proposed rule
Dear Acting Commissioner Ostroff:
We are writing in support of FDAs proposed rule to revise its collection and reporting of antibiotic sales
information from drug companies, under the auspices of the Animal Drug User Fee Act. We encourage
FDA to finalize the rule as quickly as possible.
We are a company with over 50 employees and we work with pork farmers from across the heartland ,
buying over 2 million pounds of pork annually to make internationally acclaimed artisan cured meats.
We value that all of our farmers raise their hogs sustainably without medically important antibiotics.
But, as you know, the commodity market for pigs is very different from our model. The proposed rule
would close a key gap in our knowledge of antibiotics sold for use in food animal production, including in
the commodity market, by requiring drug companies to estimate sales by species.
Though sales data reporting has improved, and would further improve under the proposed rule, sales
data is inherently limited in its ability to depict animal health and prescribing trends, and does not
represent actual use. We hope you will work with USDA and CDC to find additional avenues for data
collection to provide a better picture of antibiotic use, including the reasons why antibiotics are used in
food animal production. It is important that FDA work with these agencies and with all stakeholders to
swiftly pursue methods to collect quantitative on-farm data. Usage data will help stakeholders identify
trends in antibiotic administration for animal health conditions and assess the success of alternative
management practices.
We also want the FDA to further strengthen its data collection approach by announcing a framework to
collect and publish antimicrobial sales and distribution data by species, production class, and purpose of
use from manufacturers of medicated feeds. This could include collection of data from associated
veterinary feed directive (VFD) orders to provide additional information on the purpose of use for feed
antimicrobials.
We urge you to finalize this rule as quickly as possible, and to work expeditiously with USDA and CDC to
develop methods for better understanding how and why antibiotics are used in practice.
Thank you,
Herb and Kathy Eckhouse
Founders
La Quercia