Tl;Dr: There is only one FDA approved drug for farm animal pain in the U.S. (and that drug is not approved for any of the painful body modifications that farm animals are subjected to), FDA approval might meaningfully increase the frequency with which these drugs actually used, and addressing this might be a tractable and effective way to improve farm animal welfare.

The current state of farm animal analgesics

I was at the pain in animals workshop at NIH (I believe there will be a video of the whole conference available at some point), and was struck by the discussion of farm animal pain medication. As you probably know, farm animals in the U.S. almost never get pain medication for acutely painful procedures such as castration, tail docking, beak trimming, fin cutting, abdominal surgery, and de-horning. What I was not aware of until this morning is that there is only one FDA approved medication for ANY farm animal analgesic, and that medication is specifically approved only for foot rot in cattle. This means that if a farmer wanted to voluntarily use an analgesic on their chickens when they cut off part of their beaks or on their pigs/cattle when they castrate them, they must use drugs off label. There are plenty of such drugs available, but by using drugs off label, the farmer would risk being held responsible for any residue of pain medication in the animal's meat (One presenter mentioned that they surveyed 1187 cattle farmers and 64% reported perceiving the FDA as a barrier to the use of analgesics on cattle, but I don't have the study and people say a lot of things on surveys anyway, so take that for what its worth). In contrast, the EU, UK, and Canada have much higher standards for food residues in other domains (hormones, antibiotics, etc.) but have nevertheless approved several pain medication for several procedures in species of farm animals. As a result, these drugs are much more commonly used there.

When I hear people discuss the lack of pain medicine in the U.S. farms, it is usually in the context of farmers being irresponsible or animal welfare laws being to lenient (neither of which I deny). However, getting drugs approved is a pre-requisite for an improvement on either front.

Why aren't there more options?

I collected opinions from scientists, anesthesiologists, veterinarians, FDA representatives, USDA representatives, and representatives from Elanco (unfortunately, not from representatives of relevant pharmaceutical companies) why there are not more options like there are in other countries. Among the people I spoke to, there was near universal agreement that safe and effective drugs already existed. Some pointed out that there are logistical obstacles for implementing these drugs on the farm level. For example, factory farms spend very little time on each procedure and conduct them in an assembly line sort of fashion. Topical anesthetics, on the other hand, must be left on the skin for a couple minutes in order to work. This makes drug companies feel farmers will not adopt this practice, so they think it is not worth the trouble to get these drugs approved. A panelist from an animal welfare standards and labeling organization mentioned in their panel discussion that when pain management is mentioned on consumer labels, consumers don't buy an animal product at all (unlike when, say cage-free or other welfare metrics are labeled--which is good to know for its own reasons). Others mentioned that they don't think drug companies have had the economic case fully made to them--in other words, that it has gotten easier to pass drugs through FDA in recent years and there is a market, but the drug companies are somehow unaware of this opportunity or mistaken about the cost-benefit calculation because they don't believe there is a public or farmer level interest in these drugs when in fact there is (I am highly skeptical of this kind of reasoning but I don't think it should be ignored). A recurring theme was that there are different standards of specificity for approval in the EU than in the US. I don't have a great grasp on the nuances of these differences, but many people seemed to think this is major factor. For example, in the US, a drug must be approved as effective for a specific procedure, while in the EU, it is approved by species and category of procedure (e.g. soft tissue surgery). This might make drug companies feel hesitant. FDA representatives noted that FDA accepts foreign studies as evidence for approval in terms of residue analyses, safety, and effectiveness.

What can be done about this?

On the one hand, it is hard to understand how the economic incentives for drug companies are not there--the drugs do not seem to require serious innovation given the existing drugs in other countries and off-label uses here, and even if the drugs were used by only a very small fraction of farms, the number of farm animals is so large that seems to me it would be profitable. On the other hand, drug companies are highly rational and sophisticated, so something about this reasoning is probably mistaken or else they would have done so already.

One possibility is that the FDA needs more public pressure to speed up approvals or even recognize reciprocal relationships between farm animal medications approved in the EU/UK/Canada/etc. Obviously there is the risk of approving an ineffective drug, but in my opinion, there are sufficient drugs that seem very likely effective with no risk of human health harm from residues that this is not a major risk. I'm sure they already get pressure from drug companies, but pressure from animal welfare organizations is a different sort of pressure that might elicit more public sympathy and strike FDA officials as having less of a direct conflict of interest. Another possibility is that drug companies can be directly engaged to understand why they haven't developed these yet. If organizations that have a proven record of getting corporations to adopt cage-free eggs, for example, perhaps the missing piece is an assurance that if these drugs are approved, these same organizations will exert pressure for corporations to commit to using these new drugs. I also think more public attention to this (easier said than done) specific issue of lack of available drugs in the US is worth pursuing. Obviously, people have limited appetite for hearing about things, but it might motivate drug companies to go through the trouble of getting new drugs approved.

These strategies are not silver bullets, and I'm sure that there are people already working on this. However, I think this is worth paying more attention to from the perspective of welfare improvements.


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7 comments, sorted by Click to highlight new comments since: Today at 4:10 PM

Interesting work, thanks for doing the research. I really appreciate these posts on new topics I had no idea existed.

I'm excited about this area and only wish I had the funds to make grants in it. I think finding people to consult with who have been through the process of FDA change before would be especially helpful.

>I'm sure that there are people already working on this.

IIRC there are a couple advocacy groups but they seemed a bit orphaned due to pushback within the normal animal welfare memeplex (abolitionists vs reductionists, plays out in climate change too on the nuclear and geoengineering fronts). I think this is neglected and there's an opportunity for a motivated group to move the needle substantially.

Do you have any links to share w/r/t the advocacy groups already working on this? Or the names of particular groups?

Thanks, I'm glad to hear there have been some people looking into this. It's really unfortunate if in-fighting has stalled them.

To minimize human-caused suffering as much as possible,  it seems that farm animals should be let to live freely until they die naturally and shouldn't need to be modified in any way. A quick google search told me that cows have lifespans of 15-20 years and chickens have lifespans of 3-7 years. Since the world produces enough food to feed the global population several times over (even though hundreds of millions of people go without food), it might be that society and individual habits can be restructured in such a way (such as by using less of our food to feed farm animals and individuals not wasting any food they buy) so that we could farm in the way I just said and we would virtually eat as much as we currently do.

Analgesics are better than nothing. However, they don't erase the trauma that the animals experience from being modified. I don't know how the modifications affects the animals in the long run, but I wonder if they would cause chronic living struggles similar to what humans experience who are missing a limb, have back problems, etc. Also, the animals cannot communicate to us any secondary problems that result from their body modifications. It seems that addressing the pain caused by our modifications of them could potentially bring up all the issues I just raised plus many more that could have been avoided altogether by not modifying them in the first place.

Hi Paul, I am absolutely with you in that I think factory farms are awful and would of course continue to be awful with the widespread use of analgesics. I fully support doing everything we can to eliminate them through some combination of developing alternative proteins and moving people and institutions toward eating the plant-based alternatives we already have. I in no way support mutilating animals even with analgesics. The reason I wrote this post is because I think it would be an improvement for animal welfare over the status quo of using no analgesics, and I think that this improvement is relatively achievable.

As a side note, my position has shifted a bit since I've written this based on new technological developments. I now think efforts in this domain should be more targeted toward adoption of drugs and genetic engineering that eliminate the need for the modifications in the first place. When I wrote this, those seemed a long way off but I no longer feel that way. But to be clear, even if we could completely eliminate all forms of direct mutilation that this post discusses I will still think factory farms are horrible.