With the 2017 transition to new antibiotic rules quickly approaching, veterinarians and producers still have time to minimize logistic and animal-health impacts by planning ahead. Those changes, centered around the FDA’s strategy for antibiotic stewardship in animal agriculture, will remove animal-performance claims from medically important feed antibiotics and require veterinary oversight for the use of most medicated feeds.
Beginning on January 1, 2017, over-the-counter purchases for medically important feed-grade antibiotics will end, with producers and feed distributors needing to work through a veterinarian to secure a veterinary feed directive (VFD) order for purchase of those products.
This week, Global Vet Link (GVL), which provides electronic systems for generating, distributing and storing VFD orders, hosted a webinar to update veterinarians on their responsibilities and how to guide clients through the transition.
Dr. David Nolan, a veterinarian with Huvepharma, provided background on the upcoming changes, outlining a series of FDA guidance documents leading up to the transition. The FDA provides those documents and further information on the upcoming VFD rules on its Center for Veterinary Medicine (CVM) website.
Nolan says that prior to the changes, about 99% of feed-grade medications used in livestock were marketed OTC. Once the new rules are fully implemented on January 1, 2017, that total will drop to around 39%, with 61% requiring a VFD order.
Some antimicrobial products deemed unimportant in human medicine, such as ionophores, will not require a VFD order. The same applies to non-antibiotic drugs, such as anthelmintics, delivered through feed. Antibiotics delivered through water will require a veterinarian’s prescription, which differs from a VFD.
Tyler Holck, DVM, MS, MBA, with GVL, focused on three priorities for veterinarians to successfully transition into the new regulatory environment.
1. Know the requirements.
2. Make sure your clients and feed distributors know the requirements.
3. Walk through likely animal-management scenarios involving VFD drugs with clients and feed distributors.
Holck stresses that a compliant VFD order involves:
· One veterinarian – not a clinic or practice group.
· One client – the person responsible for care of the animals listed on the VFD order.
· One animal-production site, or more than one under the same owner and with a common health status.
· One feed distributor, although feed distributors operating more than one facilities can fill the order from any of them.
· One medication, or one combination product in which one medication in the feed is listed as a VFD drug.
The VFD order itself will include a variety of information including the client’s name, species, production class, number and location of the animals to be treated, the VFD drug or combination drug, indication of use, dosage, duration of use and more. The VFD order can be in paper or electronic format, but in either case, the veterinarian, producer and feed distributor must keep it on file for two years and make it available to FDA inspectors upon request.
Holck says producers have expressed concerns that the new rule will create barriers to access to drugs, prevent timely treatment of sick animals, increase the risk of audits or inspections and disadvantage producers who lack easy access to veterinary services. Feed distributors meanwhile, worry about inaccuracies in VFD orders, customer complaints due to delayed deliveries, increased paperwork and record keeping, liability and higher risk of audits or inspections.
Veterinarians, he says, can help resolve most of those real or perceived problems, and enhance their practices, by establishing veterinarian-client-patient relationships (VCPR) with producers in their practice areas and helping them plan ahead, prevent disease an anticipate when they will need VFD feeds on hand.
Shelly Hill, a customer success representative with GVL outlined how the company’s FeedLINK system provides a simplified electronic process for preparing and storing VFD orders. The digital system allows considerable automation, simplifying data entry for the veterinarian and distributing the VFD order to the client and feed distributor, and the digital format eliminates the need to retain paper VFD records. Perhaps best of all, the system’s “Smart Engine” technology electronically verifies accuracy of the VFD order and identifies errors or omissions, helping ensure the veterinarian has filed the correct information.
The recorded webinar, with additional detail on the entire VFD process, will be available later this month, and we will post a link to this site.