Peer Benchmarking

Antibiotics July 25, 2012 – DRAFT

Peer & Competitive BenchmarkingAntibiotic Positions

• Large Processors & Suppliers – Cargill– Tyson – JBS Swift– Seaboard– Prestage Farms– Hormel– Sara Lee– Smithfield

• Niche Processors– Applegate Farms– Coleman Natural

Foods

• Restaurants– McDonalds– Burger King– Wendy’s– Compass Group– Wolfgang Puck– Bon Appetit– Starbuck’s– Panera– Chick-fil-A– Arby’s– Chipolte– YUM! KIF, Taco

Bell and Pizza Hut

– Subway

• Grocery– Walmart– Kroger– Supervalu– Target– Safeway– Wegman’s– Whole Foods

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Glossary of Terms

• Antibiotic: A substance produced by microorganisms that kills or inhibits other microorganisms

• Therapeutic: Treatment, control and prevention of bacterial disease

• Sub-therapeutic: Administration of an antibiotic at a low level for an extended period of time to promote growth and prevent illness in animals

• Antimicrobials: An agent that kills bacteria or suppresses their multiplication or growth. This includes antibiotics and synthetic agents. It exclused ionophores and arsenicals.

• Antiobiotic resistance: A natural biological process that enables bacteria to outmaneuver the very drugs designed to kill them.– Is transferred via two methods:

• Intrinsic transfer, in which pre-existing resistance only is transferable to the progeny of a bacteria

• Acquired, which develops through mutations or from DNA transfer among bacteria

• Medically important antibiotics: Antibiotics used in both animal and people that are important to treat human infections

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Administered only to animals exhibiting signs of disease

Administered to a group of animals when a proportion of the animals in the group exhibit clinical signs of disease

Administered to a group of animals, none of which are exhibiting clinical signs of disease, in a situation where disease is likely to occur if the drug is not administered

Administered to growing, healthy animals to promote increased weight gain. Such uses are typically administered continuously through the feed or water in a herd- or flock-wise basis.

Four categories of FDA-approved food animal antibiotic uses

Growth Promotion

Disease Treatment

Disease Control

Disease Prevention

The FDA considers treatment, control, and prevention all to be "therapeutic" uses targeting a specific disease or agent, whereas growth promotion is what some call a "sub-therapeutic.“

Where does Oscar Mayer belong?Public positions on antibiotics

Comply with FDA guidelines

Only used to prevent, treat & control

disease

Offers choice Antibiotic-free

*Residue-free, no hormones added (which in pork isn’t allowed any ways)

*

CBS News reports on costs

• “Meat prices in Europe have not risen dramatically since the EU's ban. Danish authorities estimate the total costs for pig farmers increased by just 1 percent, or about $1.35 for every pig slaughtered -- far below food industry estimates.”

• “U.S. health experts suggest the increase here would be modest, too. The Institute of Medicine, a non-partisan nonpartisan group of medical experts who advise the federal government on public health issues, estimates the average U.S. consumer would spend between $5 and $10 more per year on meat if antibiotics were restricted.”

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• No antibiotics, EVER! (Whole Foods)

• “First national restaurant company to serve 100% naturally raised meat, all of which comes from animal that are raised in a humane way and never given antibiotics or added hormones.” (Chipolte)“• Do, on occasion, incur unpredictable and short-term

supply disruptions

• “Strives to provide ‘clean” food at a reasonable price…” (Panera)• Serves antibiotic-free chicken• Added some antibiotic-free roasted turkey• Serves a growing portion of pork products

• “Does not sell any meat that was produced with antibiotics” (Applegate Farms)• “Works with a network of nearly a thousand family

farmers who use common-sense animal husbandry practices like a clean environment, enough space and 100% vegetarian diet, and as a result, we’ve managed to have less than 1% of our producers’ animals fall ill.”

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Position: Antibiotic-free

• Raised add’l concerns (Bell&Evans):– DDGS: Estimates are that more than 50% of all

US ethanol plants use antibiotics to control bacterial contamination. There is concern that not all antibiotics are metabolized during production and remain in the DDGS protein, and so the animals may be ingesting add’l antibiotics

– Hexane gas: Commonly used process that separates oil and vitamins from soybeans. EPA categorizes hexane as hazardous air pollutant and residuals potentially remain in the meat

– Arsenic: Arsenic-containing animal feed additives have been used in poultry. FDA found small amounts in chicken livers (the International Agency for Research on Cancer determined inorganic arsenic is carcinogenic to humans).

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Position: Antibiotic-free

Position: Aims to reduce “routine use” of antibiotics

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“Seeking to reduce its purchasing of products raised with routine usage of antibiotics, and now offers its guests poultry and beef products that are produced without routine use of antibiotics.”

Position: Offer consumer choice

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• Provide a wide variety of fresh and frozen choices, including antibiotic-free products for our customer who want them and understand why there may be a higher price • Shows a detailed chart that outlines which products are

produced without antibiotics, antibiotics only for disease treatment, antibiotics for treatment and control and routine use of antibiotics (Wegmans)

• All meat is free from unacceptable levels of residues, whether the antibiotic was administered for disease treatment or disease control (Wegmans)

• Supports responsible use which includes• Supports all FDA, USDA guidance (withdrawal times, random

residue testing)• Under supervision of certified veterinarians• Witholding antibiotics from sick animals is nhumane and

doesn’t comply with our animal welfare program• Safeway’s Rancher’s Reserve Beef Program – animals

removed from the program if antibiotic treatment administered twice in animal’s life span

• Current limitations are due to “limited availability of raw materials” (Safeway)

Position: Only used to prevent, treat, control illness; no growth promotion

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• Antibiotics used for three purposes (Smithfield/pork):• Prevent disease• Control disease• Treat disease • Not continuously fed• Not used for growth promotion purposes

• Small portion of hogs raised without antibiotics for niche market (pay up to 30% more) (Smithfield)

• Does not permit use of antibiotics for growth promotion or to improve feed efficiency (Chick-fil-a; YUM! Brands (verified through annual supplier certification process); Burger King – 100% for chicken; beef and pork are not known due to the fact that the animals come from thousands of farmers )

• Working with suppliers to ensure that these new FDA recommendations are fully reflected in supplier practices (Yum! Brands)

Position: May not use human antibiotics in animal growth promotion

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• Disapproved the purchase of poultry in which antibiotics that belong to classes of compounds approved for use in human medicine have been used for growth promotion (Compass Group)

• Expect products which adhere to specific criteria developed in partnership with Environmental Defense Fund. Has guidelines in pork regarding the use of non-therapeutic antibiotics – supplier is gradually reducing use (Compass Group)

• Suppliers much meet our policy or present a plan on how they will work with us to achieve our goals in the future (Compass Group)

• Preference is to use antibiotic-free meat whenever possible. In Feb 2012, initiated commitment to source 25% from Certified Humane sources (Compass Group/Bon Appetit)

Policy: Restricting Antibiotic Use

McDonald’s global minimum standard prohibits the use of antibiotics belonging to classes of compounds approved for use in human medicine when used solely for growth promotion purposes. This applies to all global suppliers where McDonald’s has a direct relationship in the meat purchasing supply chain process. Today, this means that poultry suppliers and our direct-relationship poultry suppliers (approximately 60% of our poultry supply) around the world acknowledge their compliance with our antibiotics policy.  For suppliers with whom McDonald’s does not have a direct relationship, compliance with this policy is a favorable factor in purchasing decisions. Some McDonald’s markets have government regulations that supersede McDonald's policy. In Europe, for example, use of antibiotics for any purpose other than disease treatment or prevention is prohibited for all products.

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Key Policy Aspects

• Recognize importance of antibiotics for food animals and the need to combat antibiotic resistance and supports work on sustainable use of antibiotics

• Input from physicians, suppliers, animal welfare scientists, veterinarians, retail representatives and environmental experts

• Key points: – Limits sub-therapeutic use of certain antibiotics

to promote growth in livestock. – Prohibits the use of antibiotics belonging to

classes of compounds approved for use in human medicine when used solely for growth promotion purposes

– Enforced through supplier certification and assurance programs or regular audits.

– Gave suppliers 18 months to phase this in (June 2003 – Dec. 2004)

• Knows that scientific understanding about antibiotic resistance continues to grow, will adjust policy as necessary

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Guiding Principles for Sustainable Use of Antibiotics

• Quality & safety

• Animal welfare

• Antibiotics for animals

• Supervise use

• People first

• Limit exposure

• Record keeping

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Guiding Principles for Sustainable Use of Antibiotics

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Position: Use according to FDA’s regulations

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• Food safety is our top priority

• Complies with all applicable laws and regulations (FDA, USDA and FSIS)

• Support best practices and where applicable “require suppliers”

• Meet or exceed government regulatory requirements (Hormel increased monitoring of residues)

• Expects suppliers look to industry assurance programs

• Supports the changes being implemented by FDA (phase out sub-therapeutic use and phase in veterinary oversight for all medically important antibiotics)

• Hope to identify new practices that could eliminate their use

Using but Following FDA’s Regulations

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• Respectfully disagrees with premise of Rep. Slaughter’s position on antibiotic use in animal agriculture. According to the American Veterinary Medical Association, “based on available science, the likelihood that human consumption of animal products will lead to an infection with resistant organisms is negligible” and “there is little to no evidence that restricting or eliminating the use of antimicrobials in food-producing animals would improve human health or reduce the risk of antimicrobial resistance to humans.”

• Discontinued use of fluoroquinolones (2002)

• According to AVMA, many antimicrobials used in human medicine are not approved for use in animals or are, quite simply, too expensive to use in animals.

Lessons learned in labeling

• As early as May 2007, Tyson was at the forefront of the antibiotic trend and introduced chicken “raised without antibiotics”

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● By fall, USDA officials reversed their position, stating the Tyson’s chicken feed ingredients including ionophores, commonly used antimicrobials

● The USDA and Tyson eventually agreed on a modified label that stated "raised without antibiotics associated with human resistance”

● Several competitors sued Tyson and initiated a class action lawsuit.

● Ultimately, Tyson agrees to settle lawsuit for falsely advertising its “raised without antibiotics” chicken brand ($5 Million) and voluntarily withdraws label (June 2008)

Chicken Policy

• Tyson Foods only uses feed ingredients approved by the U.S. Food and Drug Administration (FDA) and administers them only according to veterinary assessments and under veterinary supervision.  Each flock of birds and grow-out location typically has different animal health needs.  As a result, we may use different animal health products and feed formulations at different locations, according to the birds’ needs. Just like our finished product recipes, our feed formulations are proprietary and may vary from complex to complex, and even seasonally.  We do not disclose specific feed formulations for specific grow-out locations to the public. However, we can say that all FDA-approved antibiotics and antimicrobials may sometimes be used by Tyson Foods for the well-being of our chickens.

• Tyson Foods also complies with federal regulations prohibiting the use of added hormones or steroids in any chicken product.

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Beef and Pork Policy

It is a violation of Federal Food, Drug and Cosmetic Act (FFDCA) to sell livestock for slaughter that may contain drug residues or chemicals that exceed tolerances in meat established by the U.S. Food and Drug Administration (FDA). The U.S. Department of Agriculture’s (USDA) Food Safety Inspection Service (FSIS) Residue Monitoring Program tests meat and animal organs to ensure that livestock producers have followed safe production methods regarding any pharmaceutical use. USDA inspectors visually check each animal at the packing plant for signs that they were managed with safe production methods regarding use of veterinary drugs and hormones. In the rare instance of a violative drug residue finding, the animal’s carcass and all parts are condemned. In such cases, USDA notifies FDA of the violation, and FDA in turn contacts the livestock producer.

Tyson Fresh Meats supports the efforts of the National Cattlemen's Beef Association (NCBA) and the National Pork Producers Council (NPPC), which stress the importance of producers controlling drug residues in their livestock. A unified commitment to animal health helps maintain the critical balance between ensuring the needs of our animals are met and providing our customers and consumers with the quality food products they deserve.

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Associations

• Antibiotics are stringently regulated and judiciously used

– Safety assessment is more stringent than for human antibiotics

– Risk to human health is vanishingly small (reverse pyramid – next slide)

• Animal use contributes little, if any, to the burden of human antibiotics resistance

– Examination of specific resistant bacterial challenges are the biggest problems in clinical healthcare settings

• Antibiotics is among several tools used to help enhance food safety• Decisions must be made based on science

and risk assessment

Industry position: “Risk to human health is vanishingly small”

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Illustration from trade associations letter to Rep. Slaughte (June 2012)

http://www.louise.house.gov/images/stories/Master_List_Responses_FINAL_FINAL.pdf

EXTRA SLIDES

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Medically important antibiotics that are approved for use as growth promotants

• Carnevale estimated that medically important antibiotics make up roughly half of the total volume of antibiotics used in food animals (Richard Carnevale, DVM, the AHI's vice president of regulatory, scientific, and international affairs)

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CBS News reports on costs

• Meat prices in Europe have not risen dramatically since the EU's ban. Danish authorities estimate the total costs for pig farmers increased by just 1 percent, or about $1.35 for every pig slaughtered -- far below food industry estimates.

• U.S. health experts suggest the increase here would be modest, too. The Institute of Medicine, a non-partisan nonpartisan group of medical experts who advise the federal government on public health issues, estimates the average U.S. consumer would spend between $5 and $10 more per year on meat if antibiotics were restricted.

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