Veterinarians are finding themselves in the choppy waters of changing drug regulations that in one instance seems like a slippery fish to grasp, and in another a shark ready to take a bite out your ability to make scientifically-based decisions in practice.
Navigating through the intricacies of some of the drug regulations and understanding their importance can be a challenge for veterinarians.
What are some of the issues? The Food and Drug Administration (FDA) has tightened regulations on some drugs used in food-producing animals, the Food Safety Inspection Service of the USDA has instituted new broader-based residue testing schemes; the American Veterinary Medical Association (AVMA) has approved modifications to the Model Veterinary Practice Act involving the veterinarian-client-patient-relationship (VCPR); and many veterinarians still struggle to come to terms with provisions under the Animal Medicinal Drug Use Clarification Act (AMDUCA).
The ultimate goal of regulations for drugs used in food animals is to produce a safe, wholesome food supply, but getting through the intricacies of some of the regulations and understanding why they are important (even debatable), can be mind-numbing. One logical place to start is with the VCPR, which should be the underpinning of a relationship between a food-animal veterinarian and his/her client.
The FDA defines a valid veterinarian-client-patient relationship (21 CFR 530.3(i)), as one in which:
a. A veterinarian has assumed the responsibility for making medical judgments regarding the health of (an) animal(s) and the need for medical treatment, and the client (the owner of the animal or animals or other caretaker) has agreed to follow the instruct tions of the veterinarian;
b. There is sufficient knowledge of the animal(s) by the veterinarian to initiate at least a general or preliminary diagnosis of the medical condition of the animal(s); and
c. The practicing veterinarian is readily available for follow-up in case of adverse reactions or failure of the regimen of therapy.
Such a relationship can exist only when the veterinarian has recently seen and is personally acquainted with the keeping and care of the animal(s) by virtue of examination of the animal(s), and/or by medically appropriate and timely visits to the premises where the animal(s) are kept.
Recent changes in wording of the definition of a VCPR by the AVMA has created some issues with food-animal veterinarians. As of its August 2012 annual meeting, the AVMA House of Delegates approved recommendations by a task force examining the VCPR definition for the AVMA Model Veterinary Practice Act. This definition is now slightly different from that embodied in federal regulation relating to extralabel drug use.