Abstract
The use of subtherapeutic doses of antibiotics in food-producing animals has been linked to antibiotic resistant infections in humans. Although this practice has been banned in Europe, the U.S. regulatory authorities have been slow to act. This paper discusses the regulatory hurdles and ethical dilemmas of banning this practice within the context of the risk analysis model (risk assessment, risk management, and risk communication). Specific issues include unethical use of scientific uncertainty during the risk assessment phase, the rejection of the precautionary principle leading to ineffective risk management, and the criticality of risk communication to build consensus and force action. The underlying root cause is a conflict of values (Type I ethical problem) among key stakeholders, which is examined in depth along with an ethical analysis using public health ethical values