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This Note explores antibiotic-resistant bacterial strains in humans and their roots in American industrial livestock practices. Factory farms promote the growth of antibiotic-resistant bacteria—or “superbugs”—by giving animals subtherapeutic doses of antibiotics to prevent the diseases that result from confinement and unhygienic conditions. Although Congress has repeatedly attempted to pass legislation to curtail the use of sub-therapeutic antibiotic dosing in livestock, those efforts have yielded little change for nearly a decade. Similarly, the Food and Drug Administration (FDA) has stood by while antibiotic-resistance in human bacteria has ex-ploded into a critical public health issue. This Note advocates for citizen action under the Administrative Procedure Act to prompt the FDA to withdraw animal approval for antibiotics that are important to human health. A citizen petition has a greater chance of success today than in past years due to the newly available scientific data and international recognition of the dangers of the overuse of antibiotics in factory farming.


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6 Sep 2022
275 kB



  • Subject
    • Environmental Law

    • Health Law and Policy

  • Journal title
    • Boston College Environmental Affairs Law Review

  • Volume
    • 37

  • Issue
    • 2

  • Pagination
    • 463

  • Date submitted

    6 September 2022