KFB Candid Conversations: What to expect with VFD implementationPosted on Dec 14, 2016
KFB Candid Conversations presents a discussion about the topical issues facing the agricultural industry in a question and answer format with a member of Kentucky’s agricultural community. In this column, State Veterinarian Dr. Robert Stout discusses the Veterinary Feed Directive, a regulatory action taken by the U.S. Food and Drug Administration (FDA) and goes into effect January 1, 2017.
Can you provide a little background on the Veterinary Feed Directive (VFD)?
Dr. Stout: Antibiotics ushered in the era of modern medicine and have been in use for over 70 years. They have been widely used in veterinary medicine, starting with penicillin and the sulfa drugs since the 1950’s. Appropriate use in animals has long been a contentious issue whether by veterinarians or by producers. It’s taken nearly 20 years to reach the implementation of the VFD rule. FDA’s stated purpose is to phase out the use of Medically Important Antimicrobial Drugs (MIAD) for food production purposes.
Distribution of antibiotic products can be placed into three categories:
1) Over the counter (OTC) products: These include many topical and injectable antibiotics labeled for “veterinary use.”
2) Prescription products: These products are available directly from a veterinarian or by prescription at a pharmacy.
3) VFD’s products: MIAD’s for use in feed require a written or electronic document to be issued by a veterinarian and presented to the producer and the feedmill. The records are required to be maintained for two years.
What was the reasoning behind the FDA’s decision to implement this directive?
Dr. Stout: Antibiotic resistance has been recognized in both human and animal medicine for several decades, but has become a focus of public health in the last decade due to several instances of specific antibiotics becoming ineffective. This has led to the current action taken by FDA. The focus of the VFD rule regarding MIAD’s is two-fold: MIAD’s in feed will be limited to veterinary oversight of their use after January 1, 2017. The VFD outlines the process for producers, feed mills and veterinarians to follow. Off label use is prohibited; and their usage in food animals is limited to three specific areas: treatment of disease, control of disease, and prevention of disease. Use for enhancing weight gain and feed efficiency is prohibited by the rule.
How will this affect livestock producers?
Dr. Stout: If indeed the producers need to use antibiotics in their feed for any purpose, they are required to establish a veterinary-client relationship (VCPR). In other words, they cannot buy this type of feed unless they get a veterinarian to sign off on it and the veterinarian can’t issue a VFD unless he or she has been on the farm and knows the animals on that farm and the management practices. The VCPR is defined in the Veterinary Practice Act that governs veterinarians. The farmer is going to have to plan. It’s not going to be something they can wake up one morning and say I have to get this done today. It’s not going to be time consuming but it will require some planning. The other thing that is really important is that MIAD’s will be restricted to use as stated on the label by the manufacturer. That is the only thing for which producers can use it. As an example, a very common practice is the usage of CTC, Chlortetracycline, used with a mineral mix, especially in the summertime, as a preventative for pink eye. It seems like that would fit the parameters for disease treatment and control but it’s not on the label for CTC so it will not be available for that purpose.
Are only food animals affected by this regulation?
Dr. Stout: Yes, it is just that including, swine, cattle, small ruminants and bees. And the thing with bees may be problematic as veterinarians don’t know much about bees and they don’t want to know about bees and yet they are listed as the person who would have to sign off on their (VFD listed feed) use in bees. FDA may look at some way to refer that responsibility to someone that has knowledge. But that is an opinion on my part at this point in time. FDA has also been questioned about availability of some products for use in small ruminants.
In your opinion, will this put an added strain on local veterinarians?
Dr. Stout: A veterinary cannot ethically execute a VFD unless he or she has that VCPR with the farm. Is there in most cases a vet available? Yes, there is. Will it be a hardship in some cases? Yes, both on the veterinarian and the producer.
Will this be costly to livestock owners or feed manufacturers?
Dr. Stout: There are certainly going to be costs associated with the manufacturer in changing labels and the way things usually happen, those costs get passed down the line. If indeed there is an impetus to change the label, then I would think the producer could expect to participate in the cost of that. Certainly veterinarians will have to charge for their time to establish a VCPR and to issue the VFD.
Have you received many questions from producers about the directive?
Dr. Stout: Quite frankly, I haven’t. We have participated in many presentations and Q&A’s at producer meetings and at Farm Bureau, but really as far as producers reaching out to us, no. There have not been a lot of questions. I think this means they haven’t been to the feed mill on January 2 and asked for the product and told they can’t have it. My opinion is there’s going to be a lot of surprised folks. It hasn’t hit home yet and when it does, that’s when we’ll probably get the questions.