Therapeutants in Aquaculuture

Agriculture vs. human use and the development of bacterial resistance

Scale: Abx used 100 times more in food animals than in humans.

The problem of aquaculture

Aquatic "pollution" - widespread drug exposures: OTC (Ca chelation, breakdown times, water vs. sediments)

Pharmaceutical companies view many aquaculture ventures as small potatoes; i.e., not worth the risk of development.

BOTTOM LINE: Control versus spread of disease

Currently available applications

FDA-approved drugs - Approved only for specific diseases

MS222

Formalin (fish, fish eggs, shrimp)

Romet-30 (sulfadimethaxine, ormetoprim) (salmon, catfish)

Sulfamerazine – recently removed from list

Oxytetracycline (salmon, catfish, lobster)

FDA-unapproved Low Regulatory Priority Treatments

Primarily topical treatments for fish eggs, simple parasitic treatments

17 products ranging from acetic acid to ice to urea:

Acetic acid, CaO, NaCl for protozoa, monogenes

MgSO4 for monogenes

Garlic, onions against crustaceans

EPA-registered products

Algicides – chelated copper, copper-based compounds

Herbicides – shade control, organic bromides, endothall, fluidone, glyphosate, 2,4-D based compounds (large ##)

Fish toxicants / piscicides – rotenone, antimycin

USDA-licensed biologics

Bactericins – available for Aeromonas, Yersinia, Vibrio, Edwardsiella

Diagnostic kits – available for Renibacterium

Feeds – unregulated? Probiotics, glycans

What is the process for a new drug?

Drug must be effective and safe (GRAE, GRAS)

Approved new animal drug application or

Have an investigational new animal drug exemption (INAD)

INAD Exemptions

Emergency Exemptions

Extra-label use policy for veterinarians (limited basis, not for large scale, can't be mixed in feed, nor use by public, including fish pathologists specifically!)


Compassionate Exemption : Allows pharm company to do research on an unapproved drug prior to approval.

Must collect supporting data for NADA approval

Must have framework: sponsor, monitor, investigators

Sponsor, veterinarian, scientists, aquaculture facility

Sponsor important to guarantee QA/QC of drug! Not all OTC are alike?!

Must have safety and efficacy information (human and environmental)

Can use FARAD (Food Animal Residue Avoidance Data Bank) and National Coordinator for Aquaculture NADAs.

Minor Use Animal Drug Program (NRSP-7).

Request a compassionate exemption from FDA

Must have letter of response/approval from FDA's CVM (100 days).

Annual basis only.

Sponsor: aquaculture facility, association or pharmaceutical company, responsible for all communications with CVM, must develop protocols, notifys CVM of shipments. Pharm company ultimately sponsors NADA….

Monitor: veterinarian; provides QA/QC of data, does not participate in data collection, can work on behalf of sponsor.

Investigators: scientists, concerned aquaculture facility; conducts trial, manages daily aspects, directs administering of drug

Upon approval:

Sponsor and monitor prepare clinical trials

Investigators undertake trials according to protocols.

Sponsors notify FDA/CVM of each drug shipment

Data analysis and submission of data to FDA/CVM.

Sponsor holds the INAD exemption.

Issues to consider

At least 2 adequate and well-controlled efficacy studies are required.

Phase I: Dose-titration studies (3 doses, 1 control, 2 water temps or water quality conditions), optimal dose

Phase II: Clinical field trial at 3 sites

Sources, batches, lot numbers must all be recorded.

Residue depletion and environmental safety data must be generated.


Treatment Schedules

Initial targeting - efficacy studies, control groups

Types of drug studies

Whole animal

Cell or bacterial culture

Batch vs. individual

Route of administration

Oral, bath, injection (im, ip, subq)

Dosing interval & Duration

Criteria for evaluation: morbidity, mortality, adverse reactions, etc.

Tissue-residue analyses – use highest dose group

Hinton-Mueller agar & Bacillus cereus

HPLC

Delvo-P test kit for OTC

Environmental residues

How much drug is left in the water or sediment

How much remains in the water after filtration (if used)

How much drug is excreted.

Fate and effects data:

Photolysis/hydrolysis

Biodegradation

Adsorption

Sed tox

Fish and invert LC50

Chronic toxicity in fish and invert

NPDES permit (National Pollutant Discharge Elimination System) via EPA.

Integrated Pest Management (Schisto or Onchocerca examples if time permits)

Management at each level

Cultural changes

Breaking the life cycle