dcveterinarymedicalassociation@gmail.com
One Health is an integrated approach, which recognizes that the health of humans is closely linked and interdependent with the health of animals, plants, and the environment. Effective One Health approaches mean we communicate, collaborate, and coordinate across these sectors. And, there are multiple benefits and reasons why veterinarians, physicians, and other health and social service professionals in the DC area should work together to address health challenges.
Animals as Sentinels for People
Just over 38% of households in DC own pets and this number is likely to rise. But, not only do pets and people live close together, in the DC area people and wildlife live in surprisingly close quarters. Just last year, multiple people on Capitol Hill were impacted by a rabid fox, and the rat population in DC poses on-going concerns for other zoonotic diseases, such as hantavirus. A zoonotic disease is one that can be transmitted between animals and people.
Local wildlife and zoo veterinarians, companion animal veterinarians, and physicians can work together to streamline data sharing and concerns of any increase in diseases with zoonotic potential. With awareness of these shared health concerns, physicians and veterinarians can work together to emphasize the importance of pet vaccinations and avoiding wildlife.
Moreover, with changing climate patterns, certain vector-borne diseases are spreading into areas not previously seen before. For instance, locally-acquired malaria was recently identified in Maryland and more ticks than usual were expected in DC this past summer. Veterinarians may very well be on the front lines of an uptick in tick and mosquito-borne diseases in the area as these might show up sooner as a problem in pets and wildlife than people. If local veterinarians begin noticing higher numbers of tick-borne diseases or novel disease patterns, they can alert health authorities to share that information with physicians and their patients. Similar to when West Nile Virus was first identified in the U.S. in 1999, communication between veterinarians and human health professionals is essential to identify a potentially shared health threat before it spirals out of control.
Animals can also be sentinels for environmental health concerns. Health effects from environmental toxins or contaminants, such as lead-contaminated water, can sometimes be elusive and often linger a long time before a proper diagnosis is made. But, veterinary offices have the opportunity to thoughtfully take the time to record thorough patient histories and listen with public health in mind to offer a chance of catching an environmental health risk in pets before it has severe impacts on communities at large.
Pets are Both a Bridge & Barrier to Care
In addition to diseases of mutual concern, veterinarians and physicians should talk with each other more as pets are becoming an essential part of many people’s family — occasionally, the only family member they have. Many pet owners would benefit greatly from close collaboration between their veterinary office and their medical providers. Veterinarians can be in direct conversation with their clients’ health professionals when pet health recommendations might be in direct conflict with the physical, mental, or emotional health realities of their clients.
These conversations are even more important in times of pet owner crisis. For instance, those working on the front lines of human and pet health indicate there is a need for temporary pet foster services so people can get medical treatment they have been delaying out of concern for neglect or loss of their pet. Veterinary clinics have the potential to build on the client-patient-relationship to treat the pet in the context of their family dynamic and offer possible resources for pet owners going through a crisis. To ignore the pet as an essential part of the family can be detrimental to human health, as studies have shown the benefits of pet ownership on mental, emotional, and physical health, which is even more important for those marginalized and without robust social support systems.
For those who are traditionally less able to access health services — those experiencing homelessness, in domestic violence situations, or struggling from the limitations of poverty — offering services for their pets can often be a bridge to connecting them with services for themselves. While traumatized individuals can often be distrustful of institutions and human health care professionals, trust in veterinarians’ concern for their pets can be a gateway to eventually connect the pet owners with health services for themselves, whether that be social services, mental health treatment, medical treatment, housing, etc.
Both veterinarians and physicians value offering quality and accessible care. A key piece of ensuring care is inclusive means recognizing pets as legitimate members of the family for those who rely on them as such. Through collaboration, communication, and coordination, veterinarians, physicians, and other health professionals can create innovative care solutions that decrease barriers, increase equitable access, and offer improved outcomes for both people and pets.
Veterinarians & Physicians Face Similar Challenges
In addition to better serving our patients, collaboration and communication between veterinarians and physicians is paramount because our professions have similar challenges. Both veterinarians and physicians are facing a mental health crises, including burn-out and concerning rates of suicide. Both professions are also grappling with workforce shortages, adding even more strain on both how well we can serve our patients and our own personal well-being. Working across sectors, we can share information about what is working, what is not working, and creative solutions to these critical problems.
The list of reasons for improving communication across sectors does not end there. There are plenty of other ways veterinarians and human health professionals can collaborate, including on advocacy and policy proposals that can protect human and animal health, such as the Combating Illicit Xylazine Act.
So, how are we going to support continued and enhanced collaboration, communication, and coordination amongst veterinarians and physicians in the DC area? We are beginning communication efforts in the hopes of sparking multiple smaller conversations. Our two professional medical societies are committing to working together to host joint webinars, extending cross-sectoral invitations to our associations’ meetings, and seeking avenues for hosting joint continuing education and information sessions. We hope to plan joint health events to reach both people and pets in one venue, as well as sharing stories, data, and cross-sectoral health ideas all in one place.
All of this will take time, as nurturing lasting relationships usually does. But, please, hold us accountable. Let your health care providers know if you have a pet and how caring for that pet might impact your own health decisions. Let your veterinarians know if there are concerns you have about being able to follow through on their recommendations and request your health care providers work together as collaborative teams. Creating effective collaborative teams at the primary care level is a hard thing to ask and, while there will be many nuances to sift through, it is worth the challenge. Committing to the One Health approach can improve health outcomes across sectors — the time is right to act now.
Leslie Brooks, DVM, MPH
DCVMA Executive Director
The District of Columbia Veterinary Medical Association (DCVMA) is a non-profit professional association representing the veterinarians who serve the needs of the Washington, D.C. area. The mission of the Association is to enhance veterinary medical science, maintain the highest professional and ethical standards, provide professional enrichment, and represent the interest of the veterinary profession in the District of Columbia. On behalf of our members, the DCVMA respectfully submits these comments on District of Columbia Proposed Regulation 3805, which would make any use of 183 listed pesticides subject to additional burdens. We have serious concerns with the effect that this change would have on public health and animal health. The DCVMA joins the American Veterinary Medical Association (AVMA) and its 100,000 members to request the proposed regulations be amended to (1) ensure that veterinarians continue to access, administer and dispense EPA registered products (e.g. flea and tick control and control of other parasites) without further restriction; and (2) ensure EPA-registered “over-the-counter” products to control external parasites (e.g., flea and tick control) intended for individual animal application continue to be available to the public.
As we read it, the proposed rule would redesignate and restrict access to a number of specific pesticide ingredients used in products registered by the Environmental Protection Agency (EPA) and labeled for individual animal use for the control of external parasites such as fleas, ticks, and mites. Options for how veterinarians and animal owners could obtain products labeled for individual animal use containing imidacloprid, pyrethrins, permythrin, tetramethrin, and phenothrin would be restricted. The rule would further require that the products be applied by a certified applicator instead of a veterinarian or animal owner. Together these proposed changes will harm public health and animal health in the District of Columbia by decreasing, or in some cases eliminating, the availability and use of products that are important to the control of common external parasites.
ANIMAL HEALTH
Animal health has been greatly improved by access to safe and effective pesticides to help protect against external parasites, such as fleas, ticks, and mites. Treating external parasites helps prevent and control important parasite-borne diseases. Data from the Companion Animal Parasite Council (CAPC) shows that in the Maryland and Virginia areas abutting the District of Columbia, about 1 in 30 dogs tested are positive for a tick-borne disease agent, such as Lyme Disease or Ehrlichiosis.1 The Centers for Disease Control and Prevention (CDC) has guidance on the importance of talking to your veterinarian about flea and tick control products that are right for your pet. Furthermore, it is recommended that owners treat their pets for fleas year-round in order to kill adult fleas and prevent new ones from hatching.2 Adding an unnecessary extra burden will prevent owners from obtaining critical parasite control products and veterinarians could be limited as to which products they can administer or sell directly to pet owners in the District of Columbia. This will lead to higher rates of infection or force pet owners to seek care and products outside the District of Columbia. Animal welfare certainly will suffer as a result of the proposed changes to PR 3805.
PUBLIC HEALTH
Infestations of biting fleas, ticks, and mange mites, for example, can cause itching to both animals and humans leading to skin infections and serious allergic reactions. Fleas, ticks, mites, and other external parasites are known to carry organisms causing diseases that are detrimental to public health. Some of the diseases that fleas and ticks, for example, can transmit from animals to humans (zoonotic diseases) include Lyme disease, Ehrlichiosis, Rocky Mountain Spotted Fever, bartonellosis, and others.3
EPA RECOGNIZES THE NEED FOR UNRESTRICTED VETERINARY ACCESS
The EPA has long recognized veterinary training and the important role that veterinarians play in the control of external parasites and associated animal and public health implications. EPA regulations exempt veterinarians from the commercial applicator certification requirement when using restricted use pesticides in the course of their professional practice. 40 CFR § 171.103(e)(2). EPA regulations also exempt veterinarians from the private applicator certification requirement when using restricted use pesticides in the course of their professional practice. 40 CFR § 171.105(i)(2). Additionally, EPA regulations exempt veterinarians from the requirements for direct supervision of noncertified applicators who are their employees. 40 CFR § 171.201(f)(2). EPA recognizes the need for veterinarians to prescribe and dispense pesticides in the course of
their practice, and will exercise enforcement discretion for veterinarians who dispense these products in the course of their professional practice. 44 Fed. Reg. 62941 (Nov. 1, 1979)
We urge the district to also recognize the extensive training of Doctors of Veterinary Medicine and the important role veterinarians play in the protection of animal health and public health.
In summary, the proposed rule change would unnecessarily impede access to EPA-registered products that effectively and safely prevent and control external parasites on animals, risking animal health and public health. We ask that you modify the proposed changes to prevent these negative consequences by exempting veterinarians using restricted use pesticides from any certification requirements when using EPA-registered restricted use pesticides in the course of their professional practice. We also request that EPA-registered “over the counter” pesticides labeled for individual animal application to prevent and control external parasites continue to be generally available to animal owners in the district. We welcome a dialogue to discuss further, if needed, to ensure the District of Columbia’s companion animals and their owners are not negatively impacted. Thank you for the opportunity to comment.
1 https://capcvet.org/ (see CAPC parasite prevalence maps from laboratory testing data)
2 https://www.cdc.gov/fleas/avoid/on_pets.html
3 https://www.avma.org/resources/pet-owners/petcare/safe-use-flea-and-tick-preventive-products