Responsible and prudent use of antimicrobials in veterinary practice

Vets Against Live Export (VALE) note with interest the letter from the Chief Veterinary Officer. Dr Schipp wrote, “Our work internationally also facilitates exports to overseas markets…As veterinarians, we play a role in protecting this with regard to AMR, to safeguard public health and support our export industries…” Contrary to the belief of many in the profession, veterinarians are not required by law on any export ship. By convention, veterinarians are present on select voyages, such as those to the Middle East, and on new ships. However, the only animal professional required by law is a stockperson who has completed a 2-week training course.

This is particularly relevant because much of the drug prescription and administration on board live export ships is not performed by a veterinarian. The stockpersons are not trained in pharmacology. Dosing inaccuracy has been detailed (without comment) in at least one high-mortality voyage report by the government where 5 ml Tolfedine® IM was prescribed by an on board stockman in 2016 for lame cattle in excess of 500 kg; the dose for this registered product is 1 mL/20 kg.

In addition, the very nature of shipboard transport means that treated animals are not identified by ear tag number; thus, treatment records are not kept for individual animals. Once an animal leaves an Australian ship after being treated with drugs (be it antimicrobials or non-steroidal anti-inflammatories, all of which have associated withholding periods) its treatment is not traceable, even in countries such as China, where slaughter is reported to occur within 14 days of unloading. There is no onus on Australia to provide that information to any importing country and the former Minister of Agriculture, Mr Barnaby Joyce, confirmed that such individual treatment records are not provided to any country (in answers to Question 235 in Senate Estimates on 29.11.2016).3 The individual animal treatment details are also not recorded on the Daily Voyage Reports by stockpersons or veterinarians.

VALE has been concerned about the issue of antimicrobials (and other drugs) administered to Australian animals on ships. We requested a comment from eminent Australian pharmacologist, Dr Stephen Page, specifically requesting whether this would be an issue with respect to the National Antimicrobial Resistance (NAMR) Strategy.4 Dr Page is not a member of VALE but is a passionate advocate of responsible antimicrobial use and gave VALE permission to use his response in the public forum. His full response to VALE’s question is available on request. However, in summary, Dr Page indicated that Objectives 2, 4, 6
and 7 of the NAMR were relevant to the question and that these objectives implied the following:

  • antimicrobial products should be those registered by the Australian regulator (the APVMA) and the product should be used according to the directions of the approved label directly by or under the direction of a veterinarian.
  • for animals intended for slaughter, it is particularly important to observe the withholding period (WHP) statements, which prohibit use (i.e. the label states “DO NOT USE less than…”) within a fixed time before slaughter.
  • for animals being exported, international partnerships and collaborations mean that the most conservative animal management procedures of Australia and the importing country should be observed, especially with respect to antimicrobial product use and assignment of a WHP.
  • finally, the governance arrangements of Objective 7 necessitate that accurate records of animal management and treatment
  • are kept to ensure that antimicrobial stewardship practices are followed and antimicrobial resistance is minimised.

As accurate individual records are not kept for any shipboard animals being exported to overseas countries, it is clear that the live export trade is currently not operating in accordance with Australia’s NAMR Strategy. This not only potentially threatens public health around the world but also the reputation of Australia’s meat export industry, worth substantially more than the Australian live export industry. As Dr Page concluded
“We can do better and are obliged to do better”.

Sue Foster
Spokesperson VALE

This article appeared in the January/February 2018 issue of the Australian Veterinary Journal


  1. Schipp M. Responsible and prudent use of antimicrobials in veterinary practice. Aust Vet J 2017;96(10):N23.
  2. Department of Agriculture and Water Resources. Mortality investigation Report 61: cattle exported by sea to Vietnam in March 2016. http:// regulatory-framework/compliance-investigations/investigations-mortalities/ cattle-vietnam-report-61. Accessed 13 November 2017.
  3. Vets Against Live Export. Live Ex meat could harm Australians clean green image. clean-green-image. Accessed 13 November 2017.
  4. Department of Health. Antimicrobial resistance (AMR).  Accessed 13 November 2017.

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