The Food and Drug Administration provided more details in its final rule on the Veterinary Feed Directive released earlier this month that may help clear up some questions beef producers had about the antibiotic changes, says South Dakota State University Extension Veterinarian Russ Daly.
In a recent SDSU iGrow column, Daly notes that first, label changes for key animal drugs must be made before December 2016. Changes will remove the labeled indications for the use of feed-grade antibiotics for growth promotion and feed efficiency.
Another change governs the "medically important" classification. Daly says feed-grade antibiotics previously available over-the-counter will change to a required VFD designation, meaning that certain drugs must be administered under the care of a veterinarian.
The list of affected drugs contains tetracyclines and penicillin along with classes of drugs more critical to human medicine, such as cephalosporins and fluoroquinolones, Daly says.
"Producers and veterinarians can still use these medications, but they will be limited to uses for prevention, control, and treatment of illnesses in food animals – and they will require a VFD form prior to their use," Daly writes.
How the VFD form and process works
Daly compares VFD forms to a prescription. Some drugs already under this requirement include Pulmotil for pigs and cattle and Nuflor for pigs and fish.
Using the form, veterinarians will specify the farm and animals to be treated, the drug to be used, its feeding rate, and the duration of treatment. The FDA has made allowances for a VFD to apply to groups of animals that may be moved to different locations, such as weaned pigs moved from a nursery to a grower, as long as the different locations are listed by the veterinarian on the VFD, Daly notes.
The veterinarian will follow the antibiotic label to determine the duration of feeding and the rate. An expiration date also will be included on the VFD form – for example, if a producer has a directive for a 14-day course of treatment and a 6-month expiration, the producer would have 6 months to complete the 14 day course of treatment, Daly says.
Some drug labels may allow for a number of' 'refills,' which (in this example) means the producer might be able to obtain feed for more 14-day course(s) of treatment if the VFD hasn't expired, Daly says.
Once a VFD expires, that authorization is gone, and a new VFD must be procured.
The feed mill or distributor is required to have a properly completed VFD form on hand before they can supply the feed. The final rule indicates that the VFD form could be sent electronically from the veterinarian to the feed mill via e-mail or an internet service, but it can't be simply "phoned in" by the veterinarian. The feed mill, veterinarian, and producer will all need to keep a copy of the VFD on file for two years.
In the case of drugs fed in approved combinations, if any of the drugs in that combination are VFD drugs, a VFD will be required for that feed.
Only authorized veterinarians
Only a veterinarian – licensed in the state where the animals are present – with a valid "veterinary-client-patient relationship" with the operation and animals is allowed to write a VFD.
The FDA will defer to each individual state's definition of the VCPR, as long as it meets some basic criteria. In cases where states do not have their own definition, the federal VCPR definition will come into play.
"The fact that the FDA does not define the VCPR in terms of specific number of farm visits or patient examinations may frustrate some, but allows for the flexibility necessary to serve the wide variety of today's food animal operations," Daly notes.
Timeline closing fast
The VFD final rule will be implemented on Oct. 1, 2015, but some feed grade medications might not have changed their labeling before that time. Once the antibiotic manufacturer applies those updated VFD labels to their products, VFD's will need to be written before they can be used.
All manufacturers will need to have those changes made by the full implementation date of Dec. 31, 2016.
What won't change
Some livestock medication practices won't change, Daly notes. Products that are non-"medically important," like Rumensin, Bovatec, most coccidiosis medications, and certain growth-promoting medications such as bacitracin will not change.
Daly says this is because they're not used very often, if at all, in human medicine.
Uses of injectable antibiotics are not slated for change, Daly notes. However, the changes outlined in 2013 will also move over-the-counter medically-important water medications to "prescription" status like many injectable antibiotics.
Current distributors and feed mills will retain the ability to supply these products to producers, but there will be more paperwork because there will be more VFD forms to keep track of.
Why it's important
"One aspect of food animal production was important prior to these changes and will remain important afterwards -- the need for veterinarians to be involved in decisions about feed-grade antibiotics," Daly says. "There is no better source of information about the proper uses of these products in livestock populations than the herd veterinarian."
A close relationship with a veterinarian means less time and money wasted on ineffective uses of these products, Daly says, and more practical advice to help prevent the illnesses that require antibiotic use in the first place.
Source: SDSU iGrow