Farmers can simply go down to the local farm supply store and buy tetracycline and many other antibiotics over the counter.
And the animals don't have to be sick. Cattle, chickens, turkeys and pigs take antibiotics to prevent them from becoming infected.
For animal producers, antibiotics are an important management tool to keep their herds and flocks healthy and profitable. It's estimated that up to 80 per cent of the world's antibiotics are used in agriculture.
But every time a bug comes up against a drug, whether it's in humans or animals, that's a fresh opportunity to evolve a new defence.
And the links are now clear. Antibiotic use on farms is creating superbug infections in humans.
The World Health Organization warns that unless antibiotic use is reined in, the world is headed for a dystopian future where routine infections are deadly.
So it's a surprise to learn that Canada has no coordinated national system to control antibiotics in agriculture.
There is no way of monitoring what drugs are being used and how farmers are using them, and no reliable statistical data on the volumes of antibiotics being given to food animals.

Label changes

I discovered all of that as I was researching what seemed to be a simple good news story: that Health Canada is about to stop letting farmers use antibiotics as growth promoters.
On the surface, it sounded like a breakthrough. Public health advocates have been calling for an end to the use of antibiotics for growth promotion for years. It's a practice that has been banned in most of Europe.
But I soon learned that many believe the change won't significantly reduce the amount of antibiotics used on Canadian farms. That’s because it’s estimated that most of the antibiotics in feed are intended for disease prevention. And that use will still be permitted.
'In other jurisdictions, they've found that, the drugs are not used for growth promotion, wink, wink, they're used for disease prevention.'- Dr. Greg Douglas
It was curious how quietly this change came about. No press release, no news conference or ministerial announcement. Just a short "Notice to Stakeholders" posted on the Health Canada Veterinary Drug Directorate website.
But one of the biggest stakeholders — the animal drug manufacturers  — didn't need any notice, because the whole thing was their idea, according to Jean Szkotnicki from the Canadian Animal Health Institute, the trade association that represents the drug companies who make and sell antibiotics for animals.
In March, the trade association approached Health Canada with an offer to change the labels on 140 animal antibiotics that are the same or similar to human drugs.
They offered to remove claims for growth promotion, to bring their products in line with the U.S. Food and Drug Administration.
Health Canada apparently agreed. But what does it mean in practice?
When I tried to answer that question, I ran up against the wall that is Health Canada media relations.
Tyson-No Antibiotics
The Chicken Farmers of Canada ruled that its members must stop injecting eggs with the antibiotic Ceftiofur, after scientists linked the use to a resistant infection in humans. But in farms, hatcheries and feedlots across Canada , food animals continue to be treated with drugs ranked as critical to human medicine. (April L. Brown/Associated Press)
Health Canada won't let me talk directly to a policy maker, so, in what has become a familiar pattern, a media person emailed me a short written response to my initial inquiries, raising more questions than it answered:
"The removal of the production claims from the labels is anticipated to eliminate such use of the relevant antimicrobials whereas other claims which are considered prudent and necessary for animal health would remain."
Translation (after making a lot of calls to veterinarians and others outside of government): this change is unlikely to substantially reduce the amount of antibiotics used in food animals, according to people who will be involved in implementing these changes.

'Wink, wink'

"We're not going to achieve anything if we stop at the growth promotion discussion," says Dr. Greg Douglas, Ontario's chief veterinarian.
"In other jurisdictions, they've found that, the drugs are not used for growth promotion, wink, wink, they're used for disease prevention."
Changing the labels will force farmers to get a vet prescription to add certain types of antibiotics to feed, because therapeutic uses require a prescription while growth promotion uses do not.
But there is little evidence that getting a vet involved will reduce the overall amount of antibiotics used on animals.
Some hope that requiring prescriptions will at least leave a paper trail that will reveal how antibiotics are being used on farms.
But Ottawa has little control over Canada's veterinarians, because they fall under provincial jurisdiction, and veterinarians can prescribe antibiotics for whatever uses they deem appropriate, no matter what it says on the product label.
Beef cow-calfs
Cows and calves graze in Warkworth, Ont. Some cattle and other livestock take antibiotics to prevent them from becoming infected. (Tamar Atik/CBC)
What's more, in many instances vets don't even get the call, because, except in Quebec, farmers don't need prescriptions to buy many antibiotics, even ones that are considered highly important to human medicine.
Adding to the problem, farmers are free to import truckloads of almost any antibiotics they like for use on their own animals, from anywhere in the world, without telling anyone what they're using or why.
It's a gaping loophole from an old law intended to let Canadian vacationers bring back up to 90 days' worth of antibiotics for their "own use," drugs they might have been prescribed while on holiday, outside the country.
For years, farmers have used the loose language to import unlicensed antibiotics, and Health Canada has admitted, in internal documentsthat this loophole poses a threat to public health.
But it's a loophole that the government can't seem to close, despite a decade of appeals from Canada's doctors, veterinarians, scientists and even the animal drug companies, who want the estimated 20 per cent share of the market that they're losing as farmers bring in antibiotics from outside the country.
On this issue, it seems Health Canada is caught between stakeholders, because Canadian livestock producers love the loophole.
It gives them access to cheaper drugs across the border, including medications that have not been approved for Canada's smaller market.

A dozen years of trying

The cross-border problem is just one chapter in the long fight to control antibiotic use in agriculture that started back in 2002, when Health Canada's own task force called for a comprehensive national monitoring program.
More than 12 years later, the stakeholder consultations are continuing, with no indication when or if a comprehensive policy will emerge.
Meanwhile, some sectors have started to act on their own to voluntarily limit the use of some drugs.
Two months ago, the Chicken Farmers of Canada ruled that its members must stop injecting eggs with the antibiotic Ceftiofur, after scientists linked the use to a resistant infection in humans.
But in farms, hatcheries and feedlots across Canada, food animals continue to be treated with drugs ranked as critical to human medicine.
And superbugs continue to emerge, as bacteria trade genes and evolve alarming superpower resistance to the most powerful antibiotics in the pharmaceutical arsenal.