Veterinary feed directives cause concern among livestock producersWritten by Saige Albert
In June 2015, the Food and Drug Administration (FDA) issued a final regulation updating the veterinary feed directive (VFD) – an action that could have impacts across the agriculture industry.
John Hallberg, director of regulatory affairs at Zoetis, comments, “The VFD is a recommendation about how vets should use antibacterial drugs in feed. It is similar to a veterinary script for prescription compounds. A VFD will be required for all medically-important antibacterial drugs found in medicated feeds.”
The VFD will not be implemented in full until December 2016, but Hallberg urges veterinarians and producers to begin preparing and planning for the action.
Wyoming State Veterinarian Jim Logan comments, “There will be an impact, to an extent, on some Wyoming producers and veterinarians.”
“An understanding of the changes in the use of feed additive medications is important for livestock producers and veterinarians,” adds North Dakota State University (NDSU) Extension.
“A VFD is a written statement issued by a licensed veterinarian in the course of the veterinarian’s professional practice that orders the use of a VFD drug in or on an animal feed,” says NDSU Extension. “This written statement authorizes the client to obtain and use the VFD drug in or on animal feed to treat the client’s animals only in accordance with the directions for use approved or indexed by the FDA.”
Hallberg further explains that the goal of FDA is to promote judicious use of those drugs that are important in human medicine.
“They are going to phase out the use of medically important antibacterial drugs for growth promotion and feed efficiency,” he explains. “Essentially, they will bring all of these compounds under the jurisdiction of a veterinarian.”
Those drugs defined as medically important antibacterial drugs are listed under Guidance Document 152.
Four categories of drugs fall under the critically important category, including third-generation cephalosporins. Other drugs included as highly important and important also include other cephalosporins and sulfa drugs.
“Those not included in the medically important drugs are the coccidiostats, ionophores and bacitracins,” Hallberg says. “This list was created by FDA on the human side to list drugs they thought were important for use in people.”
Using a VFD drug
While they are listed as VFD, these drugs can still be utilized to treat livestock animals. The VFD allows disease treatment, disease control and disease prevention.
“Disease treatment is where we are treating sick animals,” Hallberg says. “We also have disease control, where we might have a group of animals with some showing clinical signs. The rest are most likely incubating disease.”
Finally, disease prevention allows treatment of healthy animals where there is a history of disease outbreak that is likely.
Use of VFD drugs for growth promotion and feed efficiency will no longer be allowed for the medically important antibacterial drugs.
Additionally, the VFD does not allow for any extra-label use of medicated feeds.
All VFDs have a three-month expiry date from the date of issuance, which is an additional change, Hallberg says.
In addition, the record of the VFD will have to be maintained for two years by the veterinarian, the feed mill or distributer and the client.
Hallberg also notes that it will be important to have an established relationship with their veterinarian.
“States that have veterinary-client-patient relationship language in their veterinary practice acts are largely modeled off FDAs regulations and definitions,” he says. “Those states that don’t will revert to definitions in 21 CFR 520.”
A veterinary-client-patient relationship will be imperative in issuing the VFD.
Logan comments, “If a veterinarian is prescribing drugs affected by the VFD, the client utilizing them will have to have a valid veterinary-client-patient relationship. They can’t just call the vet and ask for the prescription. If the vet issues a VFD without the relationship, he is putting both his vet license and his FDA drug license in jeopardy.”
“The removal of the growth claims and removal of products from over-the-counter to VFD-based will occur in a three-day period in 2016 – Dec. 8-10,” Hallberg says. “FDA will implement this rule on Jan. 1, 2017. There will not be a gradual phase in.”
Logan also notes that it will be important for veterinarians to be well versed in the drugs that are subject to the VFD, and producers should be aware of the products they use that will be affected.
For those producers who don’t utilize antibiotics in their feed or water, the VFD will have no impacts.
“I don’t think the VFD will be as bad as what people are anticipating, but it is going to require a little pre-planning and some paperwork,” Logan adds. “Before producers panic, they should have discussions with their veterinarian and do some research on the VFD.”