Causal regulations vs. political will: why human zoonotic infections increase despite precautionary bans on animal antibiotics.

Using precautionary principles when facing incomplete facts and causal conjectures raises the possibility of a Faustian bargain. This paper applies systems dynamics based on previously unavailable data to show how well intended precautionary policies for promoting food safety may backfire unless they are informed by quantitative cause-and-effect models of how animal antibiotics affect animal and human health. We focus on European Union and United States formulations of regulatory precaution and then analyze zoonotic infections in terms of the consequences of relying on political will to justify precautionary bans. We do not attempt a political analysis of these issues; rather, we conduct a regulatory analysis of precautionary legal requirements and use Quantitative Risk Assessment (QRA) to assess a set of policy outcomes. Thirty-seven years ago, the Joint Committee on the Use of Antibiotics in Animal Husbandry and Veterinary Medicine (the Swann Report) warned that uncontrolled use of similar antibiotics in humans and food animals could promote the emergence of resistant strains of foodborne bacteria that could endanger human health. Since then, many countries have either banned or restricted antibiotics as feed additives for promoting animal growth. Others, including the United States, have relied on prudent use guidelines and programs that reduce total microbial loads, rather than focusing exclusively on antibiotic-resistant bacteria. In retrospect, the regulatory strategy of banning or restricting animal antibiotic uses has had limited success: it has been followed in many cases by deteriorating animal health and increases in human illnesses and resistance rates. Conversely, a combination of continued prudent use of antibiotics to prevent and control animal infections, together with HACCP and other improvements, has been followed by large improvements in the microbial safety of chickens and other food animals in the United States, leaving both animals and people better off now than they were decades ago. A quantitative risk assessment model of microbiological risks (Campylobacter because of data availability) suggests that these outcomes may be more than coincidental: prudent use of animal antibiotics may actually improve human health, while bans on animal antibiotics, intended to be precautionary, inadvertently may harm human health.