February 2017 Articles

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Are You Prepared for the VFD Changes?

Are You Prepared for the VFD Changes? Heidi Ward, DVM, PhD, Assistant Professor - Veterinarian, University of Arkansas The changes to the Food and Drug Administration Veterinary Feed Directive regulations took effect on January 1, 2017. Resources are available through the National Cattlemen’s Beef Association website (www.beefusa.org/antibiotics) and the American Veterinary Medical Association website (www.avma.org) that outline the responsibilities of producers regarding the changes, but are producers actually prepared? Below is a series of questions that every producer should be asking himself/herself right now. Do you have a veterinarian who works with your animals? You can only answer “yes” if the veterinarian is licensed in Arkansas and the veterinarian has either examined at least one of your animals or has visited your farm in the past year. The veterinarian must also have medical records of the exam or visit to be compliant with the Arkansas Veterinary Medical Practice Act. If you have animals in Arkansas and another state, you must either arrange to have your veterinarian licensed in that other state or you will need a different veterinarian from that other state write a VFD order for your animals. The bottom line is that a VFD order can only be written by a veterinarian licensed in the state where the animals are located. Do you know if any medicated feed on your property contains drugs that will change to VFD status on January 1, 2017? A complete list of drugs can be found at www.fda.gov when you search “drugs transitioning to VFD status.” No matter when the medicated feed was purchased, the feed will require a VFD order from a veterinarian prior to feeding it to your animals. Otherwise, you could be found in violation of the federal regulations. Do you know if you have any antibiotics that are meant to be mixed with water on your property? Medically necessary antibiotics fed to animals through water will require a prescription from a veterinarian starting January 1, 2017. A complete list is on the FDA website and can be found by searching “drugs transitioning to prescription status.” The difference between a VFD drug and a prescription drug is that the FDA directly regulates VFD drugs and the state pharmacy boards regulate prescription drugs. Do you have a plan for how you will store copies of your VFD orders? If you are using VFD feed to treat animals, you must keep a copy of the VFD order for two years. A copy of the order must be made available to the FDA inspector if requested. The veterinarian will keep the original copy of the VFD order. Do you have a plan on how to handle feed with expired VFD dates? VFD orders will have a maximum of 6 months expiration date. Any feed in possession when the VFD expires must not be fed to animals until a new VFD order is written by a veterinarian. Meanwhile, a system should be in place to keep feed stored away from the animals until the new VFD order is obtained. Do you manufacture feed for yourself or for other clients? Do you have a Medicated Feed Mill License to manufacture Category II VFD feeds? Category II feeds contain drugs that require a strict, no tolerance withdrawal period. Category I feed has no withdrawal period. Do you plan to mix your own VFD feed or distribute VFD feed to other clients? If so, have you submitted an Intent to Distribute VFD Feeds form to the FDA? If you are mixing VFD feed for your own animals, you are considered to be a distributor by the FDA even though you are distributing to yourself. The FDA recognizes three types of feed. Type A feed is the raw, unmixed VFD drug. Type B feed is the VFD medication mixed with feedstuffs and requires dilution prior to feeding to animals. Type C feed is a final feed product that does not require further mixing. Producers who mix their own feed can purchase a Type B feed without a VFD order; however, a VFD order is needed for the producer to feed the final Type C feed to his/her animals. The bottom line is that anyone feeding a VFD feed to animals must obtain and keep a copy of a VFD order from a veterinarian.