º£½ÇÉçÇøapp

Centers for Disease Control and Prevention
Attn: One Health Office
1600 Clifton Road NE, Mailstop H16-5
Atlanta, Ga. 30329

Re: National One Health Framework To Address Zoonotic Diseases and Advance Public Health Preparedness in the United States: A Framework for One Health Coordination and Collaboration Across Federal Agencies, Docket: CDC-2023-0075

Dear Sir/Madam:

The º£½ÇÉçÇøapp (ASM) is one of the largest life science societies, composed of 36,000 researchers, infectious disease physicians, medical microbiologists, veterinarians and other health professionals. Our mission is to promote and advance the microbial sciences. º£½ÇÉçÇøappis also a global society with programs and members engaged in One Health work across the world. Microbes know no borders and we appreciate that this framework will strengthen U.S. participation in relevant international fora and will be coordinated with international efforts. We commend the interagency group’s efforts to develop a One Health framework, and we appreciate the opportunity to provide input on the plan. Because viruses, bacteria, fungi, parasites and other microbes are interconnected with humans, animals and our environment, º£½ÇÉçÇøappis committed to a One Health approach to tackling some of our most daunting global challenges, from climate change to antimicrobial resistance (AMR). º£½ÇÉçÇøappadvocates for public policies that support human, plant, animal and ecosystem health. As shifts in temperature, precipitation, humidity, CO2 concentrations and nutrient availability due to climate change are likely to increase the risk of zoonotic diseases, increased surveillance and coordination between federal agencies, state and local agencies as well as regional and global coordination is needed.

We understand this framework was developed in response to language in the accompanying report for the fiscal year 2021 and 2023 appropriations bills, and that Congressional support in the form of funding and authorizations will be key to implementing this framework. º£½ÇÉçÇøappis committed to being an advocate with Congress for this federal investment.

We also are pleased to see that the framework was developed to align and complement the National Biodefense Strategy and Implementation Plan and the HHS National Framework for the Prevention and Control of Vector-borne Diseases in Humans. º£½ÇÉçÇøapphas been closely engaged with the White House on policies related to biosafety and biodefense, and also weighed in last year on the Vector-borne Framework.

What attributes and characteristics of the proposed framework will most likely lead to success?

º£½ÇÉçÇøappappreciates the collaborative approach described in the proposed framework and the formalization of One Health coordination across the U.S. federal government. Collaboration and coordination is crucial to success since the issues under One Health are multi-pronged and complex. In particular, given the work º£½ÇÉçÇøappmembers do in the soil and animal microbiology disciplines, º£½ÇÉçÇøappis pleased to see the inclusion of the U.S. Department of Agriculture (USDA) in drafting and presenting this framework. USDA’s perspective and programmatic resources are critical to ensuring that agricultural health concerns are addressed. Another important part of this framework is coordination with academia, non-governmental organization and private sector partners, which will allow experts outside of the federal government to contribute to zoonotic disease outbreaks investigation, response and recovery. 

º£½ÇÉçÇøappalso appreciates that strengthening and coordinating surveillance for zoonotic disease is a key part of the proposed framework and we strongly support its inclusion as it will lead to success. Surveillance studies can help inform the public health responses to zoonotic and emerging diseases. As humans and animals increasingly interact, surveillance studies allow for tracking of “spillback” events in which humans reintroduce pathogens back to wildlife. One powerful example is the CDC’s National Wastewater Surveillance System (NWSS) established during the COVID-19 pandemic, which helped notify local communities of upcoming rises in COVID-19 cases, affording them more time to prepare. This program’s value goes far beyond detecting COVID-19 strains and is proving important to vector-borne disease surveillance, influenza monitoring and detecting re-emerging diseases like polio and mpox. º£½ÇÉçÇøappis concerned about the future of this program, given it is at risk due to a lack of permanent authorization and a sustainable funding stream. 

º£½ÇÉçÇøappstrongly supports the CDC’s Advanced Molecular Detection (AMD) program, which also is essential to success. This program brings cutting edge genomic sequencing technology to the front lines of public health by harnessing the power of next-generation sequencing and high-performance computing with bioinformatics and epidemiology expertise to study pathogens, including zoonotic pathogens. We appreciate the reference to this program under goal #6, as the use of this technology is an essential core capacity in advancing One Health.

Are there any specific barriers or gaps to achieving success?

Perhaps the biggest barrier will be sustained funding for this important initiative. Without dedicated resources, the goals outlined in this framework will be difficult to achieve. 

º£½ÇÉçÇøappsupports goal #6 to strengthen One Health laboratory capacity. However, existing workforce and capacity issues may be barriers to achieving these goals. For example, the CDC’s Emerging and Zoonotic Infectious Disease labs are the world’s reference labs. But maintaining labs costs more each year, from quality and safety initiatives to the cost of shipments and supplies, to recruiting and retaining specialized and highly trained staff. 

Contributing to the staffing obstacles and maintaining laboratory capacity across the country is the current shortage of medical laboratory scientists and infectious disease laboratory professionals. In 2016, the vacancy rate for medical laboratory scientists working in clinical microbiology laboratories was 6.25% and the vacancies for supervisory positions was nearly 4%. By 2018-19, the vacancy rates had grown to 10.56% and nearly 7%, respectively. These shortages are expected to continue to grow while demand for laboratory services increases. To combat these shortages, º£½ÇÉçÇøapphas made several recommendations to Congress.

We encourage the agencies to work with other parts of the federal government, including Congress, to consider policy measures that can improve the public health laboratory workforce, including consistent and sustained funding for resources to this area. 

What additional One Health issues should be prioritized in the future?

º£½ÇÉçÇøapphas identified antimicrobial resistance (AMR) as a top public health and national security issue. As antimicrobial resistance grows, it will create increasingly complex challenges in the hospital, the lab, on the farm and in communities. A multifaceted problem like AMR requires a multidimensional, One Health approach.

The U.S. government also should prioritize accelerating research, improving laboratory capacity in developing countries, strengthening global health infrastructure, promoting antibiotic stewardship and establishing a global surveillance system to inform realistic, proactive action plans to combat the spread of antimicrobial resistance. º£½ÇÉçÇøappalso supports marketplace incentives to foster the development and marketing of new diagnostics and therapies to provide public health and patient benefit. 

Climate change is another area to prioritize. º£½ÇÉçÇøapphas increasingly focused on the impacts of climate change on microbes and the potential of microbes to help with mitigating and adapting to climate change. In late 2021, the American Academy of Microbiology, ASM’s honorific leadership group, committed to a 5-year plan to build a scientific portfolio exclusively on the topic of climate change and microbes, and º£½ÇÉçÇøappreleased
a climate policy paper in 2022. Climate change and its impacts on human, animal and plant health merits prioritization and further One Health coordination. 

Beyond state and national levels, a priority should be to incorporate One Health approaches in bi- or multi-lateral agreements because international policy is key to addressing global health threats comprehensively. Improving global coordination in response to health threats is still a significant challenge. The COVID-19 pandemic took the public health community a step further and the community can learn from the successes and failures. Considering the interdependency of human, animal, environmental health, a One Health approach is key to improving surveillance and response capacities for future pandemics. The U.S. has been a leader in global coordinating efforts and should continue doing its leadership. CDC supports laboratory capacity building around the world, not only with funding but also with tech transfer and collaborative research, as part of the Global Health Security Agenda. Specific to AMR, the Global AR Lab & Response Network, was authorized in 2022 to focus on global laboratory capacity to provide technical assistance to countries around the world to address AMR.

We thank you for your work to develop the One Health Framework and support efforts to increase coordination across agencies and sectors and strengthen laboratory capacity and surveillance efforts for zoonotic disease. º£½ÇÉçÇøappand its members stand ready to assist you in this effort as this framework moves towards implementation. If you have any questions, please contact Nicole Zimmerman, Senior Specialist, Federal Affairs at nzimmerman@asmusa.org.

Thank you.

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Allen D. Segal  
º£½ÇÉçÇøappChief Advocacy Officer  

For Further Information: 

º£½ÇÉçÇøappPolicy Recommendations to Combat Antimicrobial Resistance. July 2023.
º£½ÇÉçÇøappResponds to White House Office of Science and Technology Policy on P3CO and DURC. October 2023.
º£½ÇÉçÇøappResponds to Senate HELP Committee on Healthcare Workforce. March 2023. 
º£½ÇÉçÇøappComments on HHS's Vector Borne Strategy. Dec. 2022.

Big Problems, Microscopic Solutions: º£½ÇÉçÇøappRecommendations to Address Climate Change. July 2022.