By Dr. Donald Sanders
For Rural Life Today
URBANA — The biggest news to hit livestock owners in recent decades started on New Year’s Day. I’m talking about VFD. No, not a venereal disease. Nor a nutritional disorder. Rather, I’m talking about the Veterinary Feed Directive, mandated by the Food and Drug Administration (FDA) which took effect Jan. 1, 2017.
The VFD is an advanced step that:
• Prohibits giving food animals oral antibiotics to promote growth and feed efficiency. The VFD allows antibiotic use for food animals only to promote their health and welfare.
• Reduces the risk of pathogens developing resistance to antibiotics, by regulating use of medically important antibiotics (those used to treat human disease) and restricting their use in food animals. Significant evidence shows that overuse of antibiotics contributes to the development of drug-resistant genes in common pathogens. Drug resistance in pathogens threatens human and animal health.
• Puts licensed veterinarians in charge of directing antibiotic use for food animals, to make sure the animals receive only drugs that are necessary for their health. Formerly the vet was often circumvented from developing the diagnosis and recommended therapy.
A VFD is a document that a veterinarian presents to an animal owner and his feed distributor, prescribing antibiotics that are to be administered orally to treat sick food animals or prevent illness. Feed mills will prepare feed formulations, per the VFDs prescribed by veterinarians. The feed mills will be required to keep detailed records, as will veterinarians and animal owners.
Frankly, I look for this to be an administrative Excedrin headache for feed mills because of the multiple roles they must assume. The feed mills will be required to label, monitor, inventory and keep tabs on raw antibiotic ingredients, antibiotic premixes and completed feed mixes.
The VFD will impact everyone in food animal agriculture except, perhaps, dairy herds. Regulations have been in place for many years banning use of oral antibiotics for dairy cows.
A key component of the new VFD regs has been in place for many years. That is, that food animal producers – even 4-Hers who show livestock at the county fair – must have an established veterinary-client-patient relationship (VCPR).
A VCPR is defined as a relationship established by a food animal owner or farm manager with a veterinarian who has visited the facility, is familiar with the production system or individual animals, keeps records of medications prescribed and, in the case of large production operations, maintains regular communication. A VCPR is kind of old news. And for many years, the FDA has mandated that veterinarians prescribe injectable medication for food-producing animals.
However, the VCPR regulation was loosey-goosey – as far as how it was followed and enforced. Producers might purchase antibiotics from a local feed store or order from a catalog or traveling “snake oil” salesman without demonstrating they had a VCPR with a licensed veterinarian.
Also, drug wholesalers had company veterinarians who would prescribe medications from afar. Those days have been over for several years. However, violations still occurred occasionally even after the FDA plugged gaps in VCPR enforcement.
Now, under the VFD, the FDA is mandating that no oral antibiotic medications may be used for growth promotion, under any circumstance. And that all oral antibiotic medications must be prescribed by a veterinarian who has a VCPR with the farm owner/manager. Plus, the medication must be prescribed for a health benefit.
In years gone by, food animal producers were permitted to feed livestock low-level antibiotics (referred to as sub-therapeutic levels) to increase growth rates while reducing the incidence of chronic diseases.
In 2014, the FDA banned all antibiotic feeding for growth promotion. Immediately, all major pharmaceutical companies began phasing out antibiotics for this purpose. Pharmaceutical companies removed growth promotion claims from their FDA product licenses and product labels.
But it took some time for the ban to be fully enforced – until the market pipeline and retail shelves could be cleared of these banned products. In general, pharmaceutical companies have been very cooperative with FDA.
Oral antibiotics can still be used for livestock, but only to prevent or treat a disease condition – and only when the antibiotics have been prescribed with a VFD by a veterinarian who has an established VCPR with a farm’s owner/manager.
And please note: Medications can no longer be recommended or prescribed by a veterinarian to cover an indeterminate time period. The farm management must confer with the veterinarian of record for each new group of animals that are placed in the facility. This can happen every six or eight weeks. Sometimes more often.
Farms must maintain medication records for at least two years, in the potential event of an FDA audit. Veterinarians must demonstrate similar accountability with their own record systems.
It is anticipated that only 20 percent of these records will be maintained on paper. The bulk of the information will be stored digitally. The veterinary world has had computer software programs available for several years to manage such records. Now it will be more important than ever for vets to be tech savvy. Old fogeys like me question whether we could survive in this generation.
Now here’s a wild card I’d like to throw in: Bees – as food-producing animals, like cattle and pigs, but a lot smaller and often airborne – also fall under the FDA’s new VFD regulations. To obtain antibiotics for their colonies, beekeepers will also be required to establish a VCPR with a licensed veterinarian, who will issue VFDs for prescribed treatments.
For years, apiaries have been “free-range,” with no regulations regarding antibiotics. You’ve likely read about the colony collapse disorder (CCD) that destroys about 40% of bee hives each year. Fortunately, the causes of CCD are being identified and solutions are being developed.
In a vacuum of information and ready solutions for CCD, apiarists used antibiotics, sometimes indiscriminately. The FDA has mandated that these practices be organized under supervision of veterinarians to reduce – like with other food animal species – the risk of antibiotic resistance.
I can only imagine the chagrin beekeepers will feel when they learn they must consult a vet if they want to give antibiotics to their bees.
I must confess, I don’t know billy bejesus about bees, other than to avoid their pointy end. And I’m not alone. Thankfully, the Ohio Veterinary Medical Association has organized a bee symposium for veterinarians at their annual Midwest Conference in February.
Who knows, I could learn how to pregnancy check a queen bee.