Advocacy in action
Getting results from regulatory agencies: Is it possible?
Perhaps a more pertinent question is, can the AASV impact regulatory decisions? Or, more bluntly stated, can a group of 1500 members with a
small staff and limited budget and resources affect United States policy and regulations?
Not only can the AASV positively affect the outcome of regulatory decisions, it
has. Historically, the AASV has positively
influenced the outcome of regulatory decisions on many issues. Swine veterinarians
benefit every day from these successes. For example, what would practice be like
without the ability to prescribe extra-label drug
use for medicated early weaning and segregated early weaning of pigs to avoid morbidity
or death loss that may occur before clinical signs appear? The AASV successfully
advocated for such appropriate preventive extra-label use during the FDA's
proposed rulemaking process for the Animal Medicinal Drug Use Clarification
Act (AMDUCA).
The Veterinary Feed Directive (VFD) is a category of veterinary drugs that was
advocated for and led by the AASV as an alternative to a prescription-only status that
was originally discussed by the FDA. Inclusion of the VFD category ushered in
another avenue of drug approvals that led to a new veterinary feed additive for swine.
There are other examples of the AASV's impact on the regulatory process.
Granted, some are less visible in terms of impact,
but no less important to swine veterinarians.
Adopt a David-versus-Goliath mentality
How does a small association make an impact on regulatory decisions? The
AASV's success is related to its characteristics as
a whole. Those attributes are passion for the profession, healthy ability to question
authority, rebel-with-a-cause attitude, innovative problem-solving skills, tenacity,
and persuasiveness. With issues that have been around so long they are called "career"
issues, the high dose of energy and enthusiasm of swine veterinarians is an added
bonus.
Missed opportunities are worse than no opportunities
However, those attributes are worthless if the AASV chooses to sit on the
sidelines. There's a joke about a person who tells
everyone he wants to win the lottery, but he never buys a lottery ticket. The AASV
must be involved in the decision-making process to have any expectation of having an
impact.
There are plenty of opportunities to be a player regarding regulatory issues. In
the fiscal year ending September 30, 2003, the FDA Center for Veterinary Medicine
requested public comments on 14 documents. Those documents included an
advance notice of proposed rulemaking, proposed rules, draft guidance
documents, and food additive petitions. The AASV drafts and submits comments to the
appropriate federal agency when the proposals will affect swine veterinarians. AASV
members can substantially help the collective effort by submitting comments individually.
The AASV and its members are stakeholders from whom governmental agencies
must solicit opinions and feedback. Requests for comments, proposed agency rules, and
new regulations are published in the Federal
Register. These notices are required to
provide contact names and telephone numbers and information about how to submit
comments, including deadlines for comments. Written comments from stakeholders
who explain why they care about the issue and how they will be affected are
encouraged and considered by the agencies.
AASV members can increase the impact of their comments by forwarding them,
when appropriate, to their elected officials who, in turn, may decide to write a letter to
the agency as well. Although government agencies are independent agencies,
Congress still creates them, oversees how they address public policy, and determines
their budgets. The FDA's Center for Veterinary Medicine received 10 inquiries from
Congress during the fiscal period ending September 30, 2003. Some agencies
receive thousands of Congressional inquiries a year; in some cases, Congress is the
most frequent pen pal of some federal agencies. It's not unusual for elected officials to
take up a cause at the request of a constituent.
Answer the call
The AASV anticipates asking members to submit comments in the future. The
AASV office would provide members with background on the issue and details on how
to submit comments. Members can substantially add to the AASV's formal
comments by providing their individual comments. Take the opportunity!
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