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Veterinary Feed Directive – Are You Prepared?

By Jessie Topp-Becker, Freelance Writer

For several months, producers, distributors and veterinarians have been hearing about the upcoming changes to the Food and Drug Administration’s (FDA) veterinary feed directive (VFD) regulation. Some changes have already been enacted; however, the biggest modifications to the VFD that will affect those in the livestock industry will occur in January 2017.

Do you know how the VFD will affect your operation? Are you prepared to make the necessary adjustments to be compliant with the VFD? Do you have an established veterinarian-client-patient-relationship (VCPR)? If your answer to any of these questions is “no” or “I don’t know,” please keep reading.

Changes to the VFD

The impending changes to the VFD rule were the subject of a National Cattlemen’s Beef Association (NCBA) Cattlemen to Cattlemen webinar Oct. 27, 2016. During the webinar, Mike Murphy, DVM, Ph.D., FDA veterinary medical officer at the Center for Veterinary Medicine, and Tom Portillo, DVM, manager of animal health and wellbeing at Friona Industries, explained how the cattle industry can prepare for the upcoming changes to antibiotic use regulations.

By Jan. 1, 2017, a VFD will be required for all medically important antimicrobials used in or on animal feed. The updates to the VFD regulation were made with the intent “to implement measures that would address the public health concern while assuring that animal health needs are met,” Murphy explained.

One of the biggest changes under the VFD is that drug sponsors will be withdrawing production uses such as “increased rate of weight gain” and “improved feed efficiency” from product labels. These production uses will no longer be legal after the label changes are made. Therapeutic uses, such as treatment, control and prevention indications, will be retained on the label, but will transition to require veterinary oversight. Starting Jan. 1, producers will need to read product labels carefully and only use the products as instructed. Portillo, who is also the current president of the Academy of Veterinary Consultants, said the VFD is very straightforward as it pertains to following product label instructions. “The VFD is simply an extension of the label, so if it’s not on the label, then it’s not legal,” he explained. However, following product label instructions has always been important, “Extra-label use of feed-through antibiotics has always been illegal,” Portillo reminded producers.

In order to follow the VFD, producers and veterinarians need to know which drugs will be impacted. Murphy explained that, under the VFD, antibiotics that are considered medically important or that are administered in feed or drinking water will be affected. Examples of affected feed-use and water-use antibiotics include Streptomycin, Tylosin, Penicillin and Chlortetracycline. A complete listing of all affected applications can be found on the FDA website. Drugs that already had VFD status will continue to require a VFD for use.

Veterinarian-Client-Patient-Relationship

A valid VCPR is also required as part of the VFD. A VCPR “boils down to veterinarians having a hand in the design and maintenance of the health program of the production facility or producer/client they’re going to execute the VFD (for),” Portillo explained. Producers should contact their veterinarian as soon as possible to develop a plan for adhering to the VFD requirements. Portillo warned producers that waiting until Jan. 1 or until they have a health problem in their herd to discuss the VFD with their veterinarian is a bad idea.

Most producers have longstanding relationships with their veterinarians, so establishing a VCPR should be fairly easy. Producers who do not have a relationship with their veterinarian should contact them immediately to determine how to establish a VCPR. Portillo encourages producers to view the VCPR as a partnership, not a burden. “Producers can see it as a liability or an investment in veterinarian expertise and partnership. Veterinarians can see it as a burden or hardship, or as part of their overall responsibility as it relates to antibiotic stewardship and animal wellbeing,” he said.

VFD Enforcement

For producers wondering if the VFD will be enforced, the answer is yes. The FDA does intend to enforce the VFD; however, the organization plans to utilize a phased enforcement strategy. “FDA has said there is a period of education, before a period of enforcement,” Murphy said. Portillo expects that enforcement will become more stringent as time progresses. “My impression is we’re going to get some warnings before we get speeding tickets, because they understand this is a learning process. There are going to be mistakes and misunderstandings,” Portillo said.

In terms of possible consequences, “The possible penalties from FDA are fact-specific, based on the facts of the situation,” Murphy said. For veterinarians, Portillo explained that failure to comply with the VFD could result in loss of license. Despite the anticipated phased enforcement, Murphy and Portillo both agreed that producers should do everything possible to prepare for the upcoming changes.

Are you Prepared?

There are many changes to the VFD that will impact livestock producers, as well as distributors and veterinarians. Producers who still have questions about the VFD should reach out to others in the industry as soon as possible. The Food and Drug Administration, NCBA and countless livestock associations have a plethora of information available to help producers prepare for the changes. Local extension agents or veterinarians are also good resources.

With the Jan. 1 deadline right around the corner, producers need to be prepared to make adjustments to their operations and operating procedures. Finding out how the VFD will impact their operation and asking their veterinarian about the VCPR are the first two steps producers should take to be ready when the VFD goes into effect on Jan. 1.

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