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18 Questions About the New VFD Rules

Are you ready? The U.S. Food and Drug Administration (FDA) has implemented the Veterinary Feed Directive (VFD) – new rules regarding the use of medically important antibiotics in livestock. The rules require a written statement issued by a veterinarian for feed-additive antibiotics. Additionally, all water-based antibiotics become prescription medications. These rules impact livestock producers, as well as their veterinarians and feed providers.

Chris Rademacher, swine Extension veterinarian for Iowa State University, collects frequently-asked questions about the new VFD rules. Here are basic interpretations of common questions. For the official FDA clarification of the rules, please visit the Iowa Pork Industry Center at ipic.iastate.edu. 

1. What drugs are a part of the rules?

See table below.

antibiotics

2. What drugs are NOT a part of the rules?

Antibiotics that are not medically important, such as Flavomycin, Mecadox, BMD, Denagard, and monensin, and drugs that are not antibiotics, such as Ivermectin, coccidiostats, and ractopamine.

3. I buy medicated feed from two mills with different owners. Does my veterinarian need a VFD for each mill? 

Yes. 

4. Do I need to tell my veterinarian exactly how many animals I am treating with these medications?

Yes. A veterinarian must include on the VFD the approximate number of animals to be treated. The veterinarian is expected to have knowledge of the capacity and normal animal turnover of the facility. This includes animals the client acquires during the time the VFD is valid, but is not meant to allow the retreatment of the same group of animals.

5. I produce feed for my own use on the farm. Do I need a VFD to purchase product?

Yes.  

6. Will my veterinarian have to visit every site I operate to do a VFD?

Probably, depending on your state. A veterinarian needs to have a valid veterinary client patient relationship (VCPR) for all animal locations in order to issue a lawful VFD. The client-patient relationship rules are defined by the state. Check your state regulations.

7. I want to give one dose of antibiotics at the beginning of the nursery phase and another dose at the end. How many VFDs are required for this group of pigs?

Two. A veterinarian must issue a VFD for a duration of use consistent with the product labeling. However, if the veterinarian reassesses the animals after a single course of therapy, he or she may decide that additional therapy is warranted. In such case, a new VFD is needed.

8. My daughter is exhibiting a pig at a jackpot show. Does she need a copy of the VFD or prescription in her possession at the show?

Yes. The rule requires that all involved parties must make the VFD and any other records available for inspection and copying by the FDA upon request. 

9. Do the new VFD orders allow a window of treatment days?

No. Even veterinarians cannot change the duration of feeding. All VFD drugs must be fed according to the label directions.

10. I ordered 12 tons of feed, but only 10 would fit in the bin. Can I put the leftover medicated feed in another bin nearby?

Generally speaking, delivery of the authorized medicated feed to one or more bins on the premises specified on the VFD order is acceptable, provided the total amount of VFD feed delivered is equal to the number of animals listed on the order. The feed mill and livestock producer should take into account the feed-storage capacity at the farm in determining whether the entire amount on the VFD should be manufactured and delivered at once, or over multiple deliveries.

11. Is there a difference in a label that says “Feed for ‘X’ days” vs. “Feed up to ‘X’ days?”

A label that states “Feed for ‘X’ days” means the VFD feed must be fed for that exact number of days. A label that states “Feed for up to ‘X’ days” indicates that the veterinarian has some discretion in selecting any number of days up to the “X” day when writing the duration of use on the VFD.

12. What if my animals are still sick after the first course of treatment?

The veterinarian may use his or her medical judgment to determine that an additional course for a VFD drug is needed. The veterinarian would need to issue a new VFD to authorize this additional treatment.

13. I use a veterinary clinic with five veterinarians. Can any of them write a VFD for my animals?

No. In order for the VFD to be lawful, the veterinarian issuing the VFD must have a veterinarian-client-patient relationship. The veterinarian must have sufficient knowledge of the animals and be readily available for follow-up in case of adverse reactions or failure of the therapy. The veterinarian must have recently seen and be personally acquainted with the keeping and care of the animals by examination or through timely visits to the premises.

14. What is a timely visit?

That varies by state. It has been generally suggested that it be between six and 12 months. Contact your state to get official clarification.

15. Is this just a way for veterinarians to get rich?

Writing VFDs involves a large amount of time, paperwork, and resources to ensure clear communication, accuracy of drug label requirements, completeness of information, and compliance with regulations. 

“I don’t know one vet who is looking forward to this,” says Rademacher. “This means more paperwork and less time spent solving problems. Nobody is saying, ‘Oh goody, I’m going to make money on this’.”

16. How much do I need to document?

If in doubt, says Rademacher, document everything. “The FDA has been doing mock audits since last August in large feed mills. The agency will look closely at how the rule is working.”

17. Will this ruling make a difference in the industry?

“Most likely we will see a decrease in the use of medically important antibiotics due to the ban on growth promotion uses of these products,” says Rademacher. 

Utilizing feed medication for sick pigs remains a challenge, he says, because “When a pig is sick, the first thing it does is stop eating.” One pig may be getting too much medication and another none at all.

“In these down markets, there may be an opportunity to evaluate and eliminate the use of growth-promoting antibiotics in finishing, which reduces costs without sacrificing performance,” says Rademacher. “Many producers may be able to drop growth-promoting antibiotics in finishers and not see a change in performance due to better facilities, sanitation, and pig health.”

Another opportunity will be to explore increased usage of mass injections of long acting antibiotics in disease outbreaks to have a more targeted impact. This would result in each pig getting the targeted dose, independent of how much it is eating or drinking. The end result would be better efficacy with reduced total amounts of antibiotics, says Rademacher.

18. What other production practices help with decreased use of antibiotics?

1. Increase vaccinations.

2. Invest in biosecurity and surveillance.

3. Increase weaning age.

4. Decrease stocking density. 

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Federal Register

Iowa Pork Industry

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