Analgesics for farm animals

Tl;Dr: There is only one FDA ap­proved drug for farm an­i­mal pain in the U.S. (and that drug is not ap­proved for any of the painful body mod­ifi­ca­tions that farm an­i­mals are sub­jected to), FDA ap­proval might mean­ingfully in­crease the fre­quency with which these drugs ac­tu­ally used, and ad­dress­ing this might be a tractable and effec­tive way to im­prove farm an­i­mal welfare.

The cur­rent state of farm an­i­mal analgesics

I was at the pain in an­i­mals work­shop at NIH (I be­lieve there will be a video of the whole con­fer­ence available at some point), and was struck by the dis­cus­sion of farm an­i­mal pain med­i­ca­tion. As you prob­a­bly know, farm an­i­mals in the U.S. al­most never get pain med­i­ca­tion for acutely painful pro­ce­dures such as cas­tra­tion, tail dock­ing, beak trim­ming, fin cut­ting, ab­dom­i­nal surgery, and de-horn­ing. What I was not aware of un­til this morn­ing is that there is only one FDA ap­proved med­i­ca­tion for ANY farm an­i­mal anal­gesic, and that med­i­ca­tion is speci­fi­cally ap­proved only for foot rot in cat­tle. This means that if a farmer wanted to vol­un­tar­ily use an anal­gesic on their chick­ens when they cut off part of their beaks or on their pigs/​cat­tle when they cas­trate them, they must use drugs off la­bel. There are plenty of such drugs available, but by us­ing drugs off la­bel, the farmer would risk be­ing held re­spon­si­ble for any resi­due of pain med­i­ca­tion in the an­i­mal’s meat (One pre­sen­ter men­tioned that they sur­veyed 1187 cat­tle farm­ers and 64% re­ported per­ceiv­ing the FDA as a bar­rier to the use of anal­gesics on cat­tle, but I don’t have the study and peo­ple say a lot of things on sur­veys any­way, so take that for what its worth). In con­trast, the EU, UK, and Canada have much higher stan­dards for food resi­dues in other do­mains (hor­mones, an­tibiotics, etc.) but have nev­er­the­less ap­proved sev­eral pain med­i­ca­tion for sev­eral pro­ce­dures in species of farm an­i­mals. As a re­sult, these drugs are much more com­monly used there.

When I hear peo­ple dis­cuss the lack of pain medicine in the U.S. farms, it is usu­ally in the con­text of farm­ers be­ing ir­re­spon­si­ble or an­i­mal welfare laws be­ing to le­nient (nei­ther of which I deny). How­ever, get­ting drugs ap­proved is a pre-req­ui­site for an im­prove­ment on ei­ther front.

Why aren’t there more op­tions?

I col­lected opinions from sci­en­tists, anes­the­siol­o­gists, vet­eri­nar­i­ans, FDA rep­re­sen­ta­tives, USDA rep­re­sen­ta­tives, and rep­re­sen­ta­tives from Elanco (un­for­tu­nately, not from rep­re­sen­ta­tives of rele­vant phar­ma­ceu­ti­cal com­pa­nies) why there are not more op­tions like there are in other coun­tries. Among the peo­ple I spoke to, there was near uni­ver­sal agree­ment that safe and effec­tive drugs already ex­isted. Some pointed out that there are lo­gis­ti­cal ob­sta­cles for im­ple­ment­ing these drugs on the farm level. For ex­am­ple, fac­tory farms spend very lit­tle time on each pro­ce­dure and con­duct them in an as­sem­bly line sort of fash­ion. Topi­cal anes­thet­ics, on the other hand, must be left on the skin for a cou­ple min­utes in or­der to work. This makes drug com­pa­nies feel farm­ers will not adopt this prac­tice, so they think it is not worth the trou­ble to get these drugs ap­proved. A pan­elist from an an­i­mal welfare stan­dards and la­bel­ing or­ga­ni­za­tion men­tioned in their panel dis­cus­sion that when pain man­age­ment is men­tioned on con­sumer la­bels, con­sumers don’t buy an an­i­mal product at all (un­like when, say cage-free or other welfare met­rics are la­beled—which is good to know for its own rea­sons). Others men­tioned that they don’t think drug com­pa­nies have had the eco­nomic case fully made to them—in other words, that it has got­ten eas­ier to pass drugs through FDA in re­cent years and there is a mar­ket, but the drug com­pa­nies are some­how un­aware of this op­por­tu­nity or mis­taken about the cost-benefit calcu­la­tion be­cause they don’t be­lieve there is a pub­lic or farmer level in­ter­est in these drugs when in fact there is (I am highly skep­ti­cal of this kind of rea­son­ing but I don’t think it should be ig­nored). A re­cur­ring theme was that there are differ­ent stan­dards of speci­fic­ity for ap­proval in the EU than in the US. I don’t have a great grasp on the nu­ances of these differ­ences, but many peo­ple seemed to think this is ma­jor fac­tor. For ex­am­ple, in the US, a drug must be ap­proved as effec­tive for a spe­cific pro­ce­dure, while in the EU, it is ap­proved by species and cat­e­gory of pro­ce­dure (e.g. soft tis­sue surgery). This might make drug com­pa­nies feel hes­i­tant. FDA rep­re­sen­ta­tives noted that FDA ac­cepts for­eign stud­ies as ev­i­dence for ap­proval in terms of resi­due analy­ses, safety, and effec­tive­ness.

What can be done about this?

On the one hand, it is hard to un­der­stand how the eco­nomic in­cen­tives for drug com­pa­nies are not there—the drugs do not seem to re­quire se­ri­ous in­no­va­tion given the ex­ist­ing drugs in other coun­tries and off-la­bel uses here, and even if the drugs were used by only a very small frac­tion of farms, the num­ber of farm an­i­mals is so large that seems to me it would be prof­itable. On the other hand, drug com­pa­nies are highly ra­tio­nal and so­phis­ti­cated, so some­thing about this rea­son­ing is prob­a­bly mis­taken or else they would have done so already.

One pos­si­bil­ity is that the FDA needs more pub­lic pres­sure to speed up ap­provals or even rec­og­nize re­cip­ro­cal re­la­tion­ships be­tween farm an­i­mal med­i­ca­tions ap­proved in the EU/​UK/​Canada/​etc. Ob­vi­ously there is the risk of ap­prov­ing an in­effec­tive drug, but in my opinion, there are suffi­cient drugs that seem very likely effec­tive with no risk of hu­man health harm from resi­dues that this is not a ma­jor risk. I’m sure they already get pres­sure from drug com­pa­nies, but pres­sure from an­i­mal welfare or­ga­ni­za­tions is a differ­ent sort of pres­sure that might elicit more pub­lic sym­pa­thy and strike FDA offi­cials as hav­ing less of a di­rect con­flict of in­ter­est. Another pos­si­bil­ity is that drug com­pa­nies can be di­rectly en­gaged to un­der­stand why they haven’t de­vel­oped these yet. If or­ga­ni­za­tions that have a proven record of get­ting cor­po­ra­tions to adopt cage-free eggs, for ex­am­ple, per­haps the miss­ing piece is an as­surance that if these drugs are ap­proved, these same or­ga­ni­za­tions will ex­ert pres­sure for cor­po­ra­tions to com­mit to us­ing these new drugs. I also think more pub­lic at­ten­tion to this (eas­ier said than done) spe­cific is­sue of lack of available drugs in the US is worth pur­su­ing. Ob­vi­ously, peo­ple have limited ap­petite for hear­ing about things, but it might mo­ti­vate drug com­pa­nies to go through the trou­ble of get­ting new drugs ap­proved.

Th­ese strate­gies are not silver bul­lets, and I’m sure that there are peo­ple already work­ing on this. How­ever, I think this is worth pay­ing more at­ten­tion to from the per­spec­tive of welfare im­prove­ments.