Limitations of Reporting Requirements under California’s Livestock Antimicrobial Restriction Law

Background
Antimicrobial use in livestock production is considered a key contributor to growing antimicrobial resistance in bacteria. In 2015, California became the first state to enact restrictions on routine antimicrobial use in livestock production via Senate Bill 27 (SB27). SB27 further required the California Department of Food and Agriculture (CDFA) to collect and disseminate data on antimicrobial use in livestock production.

Objective
The goal of this report is to assess whether CDFA’s data release allows us to evaluate how antimicrobial use changed after the implementation of SB27.

Methods
We combine the CDFA data with feed drug concentration ranges from the Code of Federal Regulation to evaluate the spread of plausible antimicrobial use trends. We also estimate antimicrobial consumption rates using data from the National Agricultural Statistical Service (NASS) and compare these to changes in medicated feed production reported by the CDFA.

Discussion
We show that CDFA’s reported data are insufficient to reliably estimate whether antimicrobial usage has increased or decreased, most notably because no information is provided about the mass of antimicrobials approved for use or medicated feed drug concentrations. After incorporating additional external data on feed drug concentrations, one can at best provide uninformative bounds on the effect of SB27. We find some evidence that antimicrobial use has decreased by incorporating data on national sales of antimicrobials for food-producing animals, but the weakness of this inference underlines the need for improved data collection and dissemination, especially as other states seek to implement similar policies. We provide recommendations on how to improve reporting and data collection under SB27.