G/SPS/GEN/1751  
 
14 November 2019  
(19-7753) Page: 1/2 
Committee on Sanitary and Phytosanitary Measures  Original: English  
 
 
FLOOR STATEMENTS  
NOVEMBER 2019 WTO SP S COMMITTEE - FORMAL  MEETING  
AGENDA ITEM 4(E)(I): CODEX TASK FORCE ON ANTIMICROBIAL RESIST ANCE  
Communication from the United States of America  
The follow ing communication, received on 12 November  2019, is being circulated at the request of 
the Delegation of  the United States of America . 
 
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1.  The United States is strongly committed to addressing the important issue of anti -microbial 
resistance —or AMR—through sound science and collaboration in Codex. We take the floor to call 
attention to work undertaken by the Codex Task Force on AMR  (TFAMR) , particularly the Draft 
Guidelines for Integrated Surveillance (GLIS) at Step 2/3.  
2.  We are concerned that the GLIS is currently written to a more aspirational leve l than what 
scientific understanding, and therefore, a Codex document, should espouse, rather than focusing on 
practical guidance for countries to prioritize and survey for known foodborne AMR risks.  
3.  According to Article 5.1 of the SPS Agreement, measures must be based on an assessment, as 
appropriate to the circumstances, of the risks to human, animal or plant life or health, taking into 
account risk assessment techniques developed by the relevant international organizations.  
4.  Codex developed relevant inter national guidance for risk assessment through the Codex 
Guidelines for Risk Analysis for Foodborne AMR (CAC/GL 77 -2011).  
5.  While it is important for countries to consider the various sources of foodborne AMR as described 
within CAC/GL 77 -2011 to assess risk,  it is not necessarily appropriate to address all potential 
hazards from all sources within the Codex forum and develop surveillance guidance for them.  
6.  On this matter, we recall the mandate given to the Committee in Paragraph 4 of Article 12 of the 
SPS Agr eement, to monitor the use of international standards, and the direction given in 
G/SPS/11/Rev.1, that the Committee should help identify, for the benefit of the relevant 
international organizations, where a standard, guidance or recommendation was needed or was not 
appropriate for its purpose and use.  
7.  Noting a lack of scientific justification to include crops, the environment, and biocides in TFAMR 
work, the TFAMR requested scientific advice. The FAO/WHO fulfilled the request in 2018 and some 
findings incl ude:  
− Data regarding dissemination of AMR organisms from crops that are consumed raw 
impacting human health is sparse;  
− Systems to record antimicrobial use (AMU) and AMR organisms on fruits and vegetables at 
the national level are virtually absent;  
− A key ch allenge will be determining an appropriate standard denominator to characterize 
AMU; and that  G/SPS/GEN/1751  
 
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  − The magnitude of the public health threat posed by AMR organisms and genes in the 
environment, and the effects of antimicrobial residues on soil ecosystem servic es, such as 
biogeochemical cycles, are still unknown.  
8.  The FAO concluded that to develop science -based recommendations to mitigate AMR, the use of 
antimicrobials in plant production resulting in occupational exposure, food, and environmental 
contamination n eeds to be assessed.  
9.  The United States calls attention to the fact that despite the lack of information, the current draft 
GLIS includes text proposing surveillance for crop AMR and AMU. There is no demonstration of any 
reliable data establishing plant pat hogens are transmissible to humans, or that AMU in crop 
production has resulted in any foodborne AMR human health concerns.  
10.  The current draft GLIS appears to confuse hazards with risk and overstates what a surveillance 
system can do. For example, it states  surveillance data will identify "burden of illness " and 
"interrelationship between AMR and AMU " and that "whole genome sequencing can allow for 
determination of the epidemic source ". Case -control studies, targeted studies, epidemiological 
evidence, and ot her information are necessary beyond surveillance data to do any of this.  
11.  Countries with high levels of resources currently conduct AMR surveillance for human clinical 
foodborne illness, retail meats, and food animal at slaughter, as described in the World Health 
Organization 's (WHO) Advisory Group on Integrated Surveillance of Antimicrobial Resistance 
(AGISAR).  
12.  Recognizing that most countries have limited resources and some countries are especially 
challenged, it is important that resources be expende d for surveillance on areas that address actual 
public health needs. Data and knowledge gaps should be filled before science and risked -based 
guidance can be developed for additional sectors.  
13.  We strongly urge Members to base any, and all, future work of th e TFAMR in sound scientific 
risk-based principles, and to ensure that that the GLIS not obligate countries to set up surveillance 
for theoretical hazards, which may be better handled through research and special studies to help 
identify national priorities . This approach is protective of public health, and consistent with Members ' 
WTO obligations.  
14.  Chair, we appreciate the discussions in this Committee on actions to improve transparency , and 
support greater shared understanding of concerns raised in  this Committee. We will therefore submit 
this statement to the Secretariat and request its issuance as a GEN document.  
 
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