The required veterinary feed directive that limits “medically important” antibiotics to therapeutic purposes went into effect on January 1, but according to three people who spoke at the Iowa Pork Congress, the devil is in the details. The National Pork Board, veterinarians, and livestock media outlets worked hard to make sure producers were informed, but until it was actually time to implement the processes, some issues couldn’t be anticipated. Dr. Chris Rademacher, ISU Swine Extension veterinarian; Dr. Jeff Verzal, compliance investigator, Iowa Department of Agriculture and Land Stewardship; and Dr. Paul Thomas, a veterinarian with AMVC, Audubon, Iowa, shared their unique perspectives on the transition during a panel discussion at the Iowa Pork Congress.
As most producers are aware, the term “therapeutic purposes” means protecting animal health and well-being, which includes treatment, control and prevention, Rademacher stated. The Food and Drug Administration wanted producers to move away from non-therapeutic uses of medically important antibiotics, such as improved growth or improved feed conversion. Most importantly, FDA wanted to make sure there was veterinary oversight into all on-farm antibiotic decisions.
Since veterinarians are trusted by the public, the government, and by producers, FDA wanted to make sure veterinarians are intimately involved in any antibiotics used on the farm.
“Ninety-five percent of medically important antibiotics are in the feed or in the water, and in the water, they need to be scripted. If they’re in the feed, they have to go through the VFD process,” Rademacher said.
Products not considered “important” include ionophores, acitracin, Flavomycin, Mecadox and Denagard. Other drugs not included are Anthelmentics, beta agonists and coccidiostats, Rademacher explained.
Veterinary-Client-Patient Relationship Imperative
The most important component of VFDs is the required veterinary-client-patient relationship (VCPR).
“Make sure you have a VCPR with your veterinarian that is well documented,” Rademacher said. “That means the client (owner/caretaker) has agreed to follow instructions of the vet; the vet must have sufficient knowledge of the animals, with timely visits to premises; and the vet has recently seen and is personally acquainted with the keeping and care of the animals.”
You can’t just say you have a VCPR: “You need to do a good job of documentation – that’s what it’s really all about,” Rademacher said. “The vet, the client and the feed distributor must each have a copy of the VFD, and they need to keep it for two years.”
Additionally, the VFD must be signed by the veterinarian – not by the clinic – so there is actually a veterinarian’s name associated with the VFD.
Rademacher said practice audits were performed last fall, and the following questions were asked:
Did the client keep copies of the VFD orders for at least two years?
Did the client feed the VFD feed to the authorized number of animals on the VFD order?
Did the client feed the VFD feed for the identified duration on the order?
Did the client stop feeding the VFD by the prescribed time?
Some veterinarians or producers use pulse dosing, which is using the same antibiotic on the same group of animals at two different times. There are no refills, explained Rademacher.
“The current recommendation on pulse-dosing, is if you use a product now, and then use it again six weeks later – you need two VFDs, one for each pulse,” he said.
The veterinarian must store the VFD in its original format. In other words, if it was generated electronically, it must be kept in electronic form.
The Compliance Officer’s Perspective
“Thank you for the warm reception, which I don’t usually get when I go to a farm,” joked Dr. Jeff Verzal, compliance investigator with the Iowa Department of Agriculture and Land Stewardship, when introduced at the Iowa Pork Congress. He wants the process to go as smoothly as possible when he visits farms, so his goal is to minimize surprises by helping producers be prepared, specifically with complete and accurate medical treatment records for any medications used in their operation.
He stressed that VFD drugs are not RX drugs, even though they’re similar in concept since both are overseen through an order of a licensed veterinarian.
“Feed additive medications cannot be used in an off-label manner,” Verzal said. “Medically important antibiotic water-soluble medications made the transition from over-the-counter to prescription status.” If you have questions about which products fall within the VFD category, check with your veterinarian or feed supplier, he suggested.
Your Veterinarian’s Responsibilities
Special instructions are very important to more specifically identify the animals to be treated or fed the VFD feed, explained Verzal. They must include required information when a VFD drug is authorized for use.
“I strongly recommend you assign a sequential non-repeating number to your VFDs,” he said. “It helps minimize the variables.”
Distributor’s file a one-time notice with FDA of intent to distribute VFD drugs. They also are to notify FDA within 30 days of any change in ownership, business name, or business address, Verzal said. They also are to fill a VFD order only if the VFD contains all the required information. See sidebar for more information on compliance.
The Veterinarian’s Perspective
Dr. Paul Thomas is with AMVC, a large veterinary clinic in Audubon, Iowa. The organization offers total herd management from birth to market. The operations utilized different animal flows, have different health statuses, are geographically diverse and work with many different feed mills. He discussed how AMVC has approached the rules, and the steps they are taking to ensure compliance for themselves and their clients.
“We started months in advance and held multiple meetings with our producers,” Thomas said. “We invited experts to talk about VFDs and educate us on what to expect.”
AMVC mapped out and listed all of their sites by flow/pig source; owner; toll mill; veterinarian holding the valid VCPR; and medication used, he explained.
“We reviewed all our current feed budgets by flow and medication program, asking: Do they meet legal requirements for time and indication? And do they make sense? We also wanted to make sure we were putting the feed medication where it was really needed,” he said.
We trimmed out any questionable uses (starter diets/creep feeds that pigs receive very little of; might fit with one protocol but not another (It’s much easier to just handle one non-medicated feed).
Remember These 7 Points
Dr. Jeff Verzal, compliance investigator for the Iowa Department of Agriculture and Land Stewardship said producers are generally not “happy” to see him when he shows up at their farm, but the visit can be made faster and simpler if you make sure your veterinary feed directives include the following information:
Note: This article originally appeared in the March 2017 issue of Pork Network.