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Initial Comments
A. Themes and Approaches
B. General Recommendations
C. Structure and Process
D. Specific Recommendations by Item
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Structure,
Process and Points of Clarification
- The Action Plan would benefit from stating explicitly the
overall goal which guides the objectives in each of the separate
sections. The overarching goal of the Action Plan could appropriately
be: to minimize the emergence and transmission of antibiotic
resistance. Likewise, a general Action Plan objective which
needs to be highlighted at the beginning could be: to minimize
the unnecessary use of antibiotics in people, animals and plants
so as to decrease the overall selective pressure leading to
increased resistance.
- The bulk of the plan focuses on antibacterial resistance.
To enable concerted action, the stated focus throughout the
Action Plan should be bacterial resistance rather than all antimicrobial
resistance. Fungi and antivirals may require the attention of
a different set of resources and approaches.
- It would be helpful if the Action Plan includes a baseline
assessment of all related activities and resources of each Federal
agency working in this area, and of major private, academic,
and non-profit organizations with related missions. Based on
this assessment, recommendations could include the need for
additional statutory authority and funding for both the Federal
and non-Federal entities to conduct a sound program. And finally,
to avoid duplication of effort, these findings and recommendations
would delineate the interrelationship between the Federal government,
state governments, non-profit organizations, academia and others,
acknowledging appropriate additional roles each contributes
to this important problem.
- The Final Action Plan should include measurable objectives
for assessing whether and when the goals are reached. We believe
such accountability needs to be agency-neutral and vested in
the highest level of government. We suggest this structure since
it is our understanding that single agencies within any one
department do not have authority over other agencies within
the Federal government.
- Because of the urgency of the problem, several known interventions
and certain essential data collection should begin immediately
rather than within the larger time frame suggested. For example,
public health approaches such as the CDC "hand washing campaign"
should be strengthened and emphasized as preventative programs.
Also, there is a major need to mandate and collect adequate
antibiotic use data in order to guide current FDA deliberations.
- In order to improve readability and provide a more immediate
understanding, we suggest a glossary and definitions section
near the beginning of the Action Plan and a more thorough reference
section at the end.
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