Preparing for the Veterinary Feed Directive
May 6, 2015
If the veterinarian isn't already on speed dial, now would be the time to get their number handy.
Updated regulations from the Food and Drug Administration (FDA) will transition some over-the-counter livestock antibiotics to Veterinary Feed Directive (VFD) status at the end of 2016, requiring a veterinarian-signed approval on file at the clinic, the feed distributor and the ranch before animals are fed medicated products.
Montana's state veterinarian, Marty Zaluski, DVM, said the key to a smooth implementation will be a relationship between each of the entities required to track the VFD approval.
"Producers work with their veterinarians on health issues, whether it's footrot, pinkeye, breeding programs, BVD, a whole host of things, so just adding us into the picture of the feed-grade antibiotics will hopefully just be another part of a comprehensive health management program," Zaluski said.
Bruce Hoffman, DVM and technical consultant for Elanco Animal Health's U.S. beef unit, said the VFD will require some thinking ahead for livestock producers, but agreed that it should be an easy procedure to incorporate into normal health protocols.
"If you don't have a relationship with a veterinarian in your area, seek them out now and start talking about this," Hoffman told nutritionists at the 2015 Montana Nutrition Conference. The conference was hosted by Montana State University in Bozeman April 29.
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"The first thing we need to understand is, it's not an option. It's happening," Hoffman said. "I'm very positive about this, though, because it allows us to keep the antibiotics we use in animal agriculture."
The Animal Drug Availability Act was passed back in 1996, in which a new regulatory category was established for distributing certain new animal drugs for use in or on animal feed – the Veterinary Feed Directive. More recently, the FDA released three more clarifying documents that provide antibiotic guidance with the FDA goals to "protect human health and curb the development of antimicrobial resistance." The Guidance for Industry (GFI) documents modifies the use of medically important antibiotics in food-producing animals.
"We didn't ask for this rule, we didn't look for this additional responsibility. But at the same token, I think it's reasonable for veterinarians to be involved in the administration of antibiotics to livestock," Zaluski said. "We wouldn't ask non-medical professionals to be involved in medicating people, so I think it's reasonable to have a veterinarian involved in that process for livestock."
The two areas of focus for the modifications will deal with use labeling on certain antibiotics and added veterinary oversight on the use of any feed- or water-grade antibiotics. Antibiotics will still be labeled for therapeutic uses – for disease control, disease prevention and disease treatment – but performance indications for certain antibiotics will be phased out.
"So we're not losing these products, we're just losing them if we're only using them for gain, performance potential," Hoffman said.
Another important distinction is antibiotic classifications: more than 90 percent of the antibiotics currently used in the livestock industry are available over the counter, Hoffman said. Of that, 30 percent are ionophores – the class of antibiotics that are for animal-use only. Those will not be affected by these regulations, nor will injectable antibiotics at this time.
Only antibiotics that are considered shared-class – approved for use in livestock and humans – will be impacted. When feeding those antibiotics, producers will be required to have a signed VFD in place – essentially, an approval for prescription use – along with a corresponding VFD on file with their veterinarian and at the point of purchase, whether that be a feed mill or store.
Feed stores will still be able to stock medicated feeds and have them on the display floor, Hoffman said, but must have the VFD paperwork from the producer at the point of purchase. The same is true even if the mill delivers directly to a ranch.
Most of the forms are electronic, which expedites the process. Veterinarians can sign a VFD on their smartphone, making the approval almost instantaneous, Hoffman said. Veterinarians will not have to inspect every animal, he said, but may approve the labeled use of a product to a producer based on the operation's proven and inspected standard operating procedures.
"As veterinarians and nutritionists, we still, have never and will never have the ability to recommend off-label use of feed-grade antibiotics," Hoffman said.
The two agreed that the key to successfully navigating the VFD requirements will be better working relationships between veterinarians, producers, nutritionists and perhaps even consumers.
"If we can use this to prove that we are judicious in the use of these products, that we are already doing this right, then I see it as a real win for the industry," Zaluski said.