The National Pork Producers Council (NPPC) has submitted comments to the Food and Drug Administration (FDA) about concerns regarding FDA’s ‘Draft Text for Proposed Regulation on the Veterinary Feed Directive’ (VFD).

The FDA’s draft text published in April, states its goal to increase veterinarians’ role in on-farm antibiotic use by transitioning all feed grade antimicrobials to a ‘Veterinary Feed Directive’ status.

The objective would require a veterinarian to be involved in the decision-making process when it comes to utilizing feed grade antimicrobials on the farm.

In its comments, NPPC requests changes or clarification on seven areas of the draft regulation “in an attempt to make the transition of all feed antibiotics to VFD smoother”. The seven areas of concern include the following:

1. Refills – The draft text states that the veterinarian issuing a VFD is responsible for listing the number of refills allowed during the time the VFD order is in effect. NPPC asks FDA to remove this requirement because it is likely to cause confusion among producers, veterinarians and feed mills.

2. Approximate number of animals – The draft text states that the veterinarian is responsible for approximating the number of animals to be treated on the VFD order. However, FDA does not provide a scientific rationale for requiring this information or how they would utilize this data.

3. Expiration date – The draft text states that a VFD cannot be written for a period longer than six months. NPPC believes a six-month expiration period will disproportionately affect small producers and those located in remote areas. NPPC asks FDA to allow VFDs to be written with a 12-month expiration date.

4. Category I and II products –It would be helpful if FDA could clarify when current Category I products change to a VFD marketing status whether they will keep their Category I designation.

5. Floor stock –The requirement for notification of FDA to distribute VFD products could discourage distribution and sale of floor stock. NPPC suggests that FDA seek input on the issue of product distribution, retail sales and floor stock during its listening sessions to help address the complexities of this situation.

6. Education efforts –NPPC suggests that in addition to working with the veterinary organizations and the feed industry FDA work with the producer groups to help reach producer audiences with this information.

7. Reporting – While the draft text does not indicate that FDA is considering VFDs to be reported, NPPC would ask that they not become reportable. VFDs will not be an

Read the full letter here.