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From:
Jerry Bromenshenk <[log in to unmask]>
Reply To:
Informed Discussion of Beekeeping Issues and Bee Biology <[log in to unmask]>
Date:
Wed, 11 Oct 2017 20:21:48 -0400
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Austin


I agree with you that FDA specifically lists three antibiotics with respect to bees, and some of us were surprised to see three named, rather than two.  My original comment was intended to be sarcastic.  However, if you carefully read the entire FDA directive, it's overall purpose is to reduce antibiotics in human diet and the environment, so that could be construed to include any  antibiotics detected in the human diet.   It's only in the follow on interpretations that one begins to see assertive statements intended to 'clarify' the directive.


I know my comment was a stretch, but the FDA regs were vague and deliberately broad with respect to application to ANIMALS, and there were initially hang-ups about fumagillin, and whether it was permitted.  Even the word antibiotic has two definitions - one applies to a wide range of microbes, which would include fumagillin, usually termed a fungicide and not an antibiotic, and the other more commonly (in the case of bees) that applies to the specific control of bacterial diseases.  In that case, fumagillin would not be an antibiotic - so it  depends on how the word is defined.  FDA just tosses the term out as if everyone should know that  they only mean.....
   
Still, any agency who doesn't understand (or acknowledge) that the listed antibiotics are used to control two foul broods, not just AFB, and then uses a picture of a drone fly and calls it a bee, can't exactly be known for accuracy.  AFB is a mandatory burn order in many states, but not all.  Most of us would just burn, given that there is an antibiotic (TM) resistant foul brood. 


The big question that is being interpreted in different ways by different states and even by different animal groups, is whether antibiotics can be used prophylatically.  That's of particular concern for the productivity of commercial apiaries with respect to EFB.  That discussion, and the interpretation, varies from state to state.  FL put out a survey about whether bee inspectors recommend prophylatic treatment.  Yet, if one looks to the cattle industry, the NE web site clearly states the idea that it is not only permitted, but even defines the criteria for use with cattle.  Our own MT Veterinary Board's members who serve the cattle industry, considered this to be a non-issue - of course there is a known need for prophylatic treatments for cattle.



Our own state Veterinary Licensing Board admits that many of these Food Directives are subject to interpretation at the state level.  It looks to me like FDA's Directive is a bit of a moving target - with  fine tuning of what it says or means changing from time to time.


J.J. Bromenshenk
Bee Alert
Missoula, Mt







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