Ready Or Not: 2017 Will Bring Changes To VFD
for Tri-State Livestock News
As of Dec. 31, 2016, the livestock industry better be ready for the Food and Drug Administration’s (FDA) amendments to the Animal Drug Availability Act of 1996 pertaining to the regulation and implementation of veterinary feed directive (VFD) drugs.
So what do producers need to be in compliance with the rule? It starts with a veterinarian-client-patient relationship (VCPR).
“If there’s an illness you need to treat with feed, livestock producers will need to talk to their veterinarian before heading to the feed dealer; relationships with a veterinarian are best built before a wreck happens on the ranch,” said Dustin Oedekoven, DVM, South Dakota state veterinarian and South Dakota Animal Industry Board executive secretary. “If producers are using antibiotics in their livestock feed now, starting Jan. 1, 2017, the expectation will be that they visit with their veterinarian and obtain a VFD to present to the feed dealer.”
The new rules will go into effect Jan. 1, 2017, and there are two primary changes that will be implemented as part of the VFD rule. These changes include the need for producers to have an established VCPR and a written VFD from a veterinarian to purchase any VFD feed, which includes commonly used feeds such as CTC crumbles, Tylan, Rumension or AS700, to name a few.
Transitional labeling has already been underway with feed companies removing any references to “improved growth rates” or “enhanced feed efficiency.” As the rule is written, antibiotics in feed should be used only to prevent, control and treat and will be prohibited from extra-label use. Feed purchased before the Jan. 1 date doesn’t need to be disposed of, but a VFD will be required for continued use of the product.
“The changes that will happen on Jan. 1 are really a culmination of a series of changes the FDA began making several years ago,” said Oedekoven. “The framework has been in place for a long time, but there have only been three drugs that have been labeled as a VFD up to this point.”
Under the new guidelines, the list of VFD feeds is much longer now, and Oedekoven said that record-keeping will be a critical component to following the new rules.
“Any time there’s change, there’s fear of the unknown, and I understand the concerns about the level of records that will need to be kept,” said Oedekoven. “For producers, it will be pretty simple. All records need to be kept by the veterinarian, producer and feed mill for two years in case of an audit by the FDA. These changes are going to necessitate more cooperation between livestock producers and their veterinarians. They will have to talk more than they have in the past, and instead of veterinarians charging for products, they may have to charge for time spent at the kitchen table discussing options and offering advice to producers.”
Electronic versions of the VFD can be filled out by veterinarians at sites such as http://www.globalvetlink.com. Per the rules, it’s important to maintain printed records of these VFDs regardless of whether or not they were electronically submitted.
At the feed dealer level, feed mills will also be experiencing changes. Jarvis Haugeberg, Form-A-Feed vice president of marketing and nutrition, explains what is required of feed dealers in order to be in compliance with the updated changes to the VFD rules.
“Feed dealers need to make sure they have filed with the FDA their intent to distribute,” said Haugeberg. “Letters of intent can be filed on the FDA website, and starting Jan. 1, 2017, they will no longer be able to sell any medicated feeds (Type B or C) unless that business has filed an acknowledgement to distribute, or directly to a producer with a valid VFD. Manufacturers are also not legally able to sell to any feed dealerships unless they have received that letter of acknowledgement. The letter simply states that the dealer is aware of the changes to the VFD and that they are accepting responsibility to comply with VFD regulations.”
Haugeberg served as chairman of the Feed Legislative Regulatory Affairs Committee for the National Grain and Feed Association (NGFA) and had an opportunity to have direct input with FDA, in making sure the VFD rule was not only effective, but easy to follow for producers.
“The FDA worked hard to reach out to producer groups, feed organizations and the veterinarian community,” said Haugeberg. “They made every effort to make the rule as easy as possible for the industry to follow. For example, the NGFA submitted statements to the FDA, and virtually every suggestion we made was inserted into the final rule, almost verbatim. Now as an industry, we all need to pull together and make sure we are in compliance.”
Public perception has played a large role in the implementation of these new rules. With growing concerns about antibiotic resistance in humans, the livestock industry is now being called upon to help reduce this problem and judiciously use antibiotics in meat and egg production.
“The American public has been putting pressure on the FDA for a very long time for more stringent regulations on medically important drugs that are used in both people and livestock. The general perception is that continuously feeding antibiotics as growth promotants in livestock is unnecessary and dangerous to the public. The FDA and the public aren’t saying we can’t use these products, but they want to see these antibiotics used under the guidance of a veterinarian and only for the use of illness,” said Haugeberg.
Oedekoven added, “The discussion of antibiotic resistance in human medicine has been a worldwide discussion that impacts people, livestock, pets and even horticulture. The recognition of antibiotic resistance is pretty evident. Any time we use antibiotics, we run the chance of some bacterial populations becoming resistant to these antibiotics. So how do we reverse this problem? It’s important to recognize that even in South Dakota, the state’s two major hospital organizations are paying close attention to antimicrobial resistance and trying to limit it in their practices, and on the livestock side, we must do the same. These changes have been inevitable, and we’ll have to reconcile with these changes in the way we do business and maintain animal health and immunity.”
Both Oedekoven and Haugeberg agree that prevention and management might play a key role in avoiding antibiotic use in livestock.
“On a preventative level, the industry may have to start paying closer attention to the timing and selection of vaccinations and other management changes that will promote a healthy immune status in livestock,” said Oedekoven. “In treating sick calves, it’s good to remind everyone that while feeding antibiotics may seem easy and appropriate, in some cases, it might not be as effective to feed. Sick animals don’t always consume feed, so if they go off feed and you’re hoping to get the drug in the animal, you might need to sort that one off and give him a dose with a needle. Nothing is changing in regards to the use of injectables, and your veterinarian can continue to prescribe medicine as needed in those situations.”
Livestock producers may be looking for ways to stay ahead of illnesses, and Haugeberg explained how natural immunity boosters may come into play. He said, “We’ve been working hard to create and market various holistic products that will help our producers keep their animals healthy thereby reducing the need for antibiotics. There’s a big push for that, and it mirrors what we are doing in human health, too. Products such as yeast and chelated minerals help our animals nutritionally, so antibiotics and vaccines work more effectively. If we increase the nutritional plane, especially on stressed animals, it will improve their immune function and reduce the need for antibiotics.”
Ready or not, the latest changes to the FDA’s Animal Drug Availability Act are coming your way. If producers don’t have a good, ongoing relationship with a veterinarian, it might be time to stop in the clinic and say hi.
“The sky is not falling,” said Haugeberg. “What seems cumbersome, awkward and impossible now will become second nature shortly. We just need to work together, and it will be just fine.”