In 2009, the Wisconsin Veterinary Medical Association (WVMA) learned Wisconsin was leading the nation in drug tissue residues in dairy beef.
This did not sit well with the WVMA, and it formed a task force that then enlisted the cooperation of the professional Dairy Producers of Wisconsin (PDPW) to launch a non-regulatory, three-phase, joint effort to educate veterinarians and dairy producers in Wisconsin about decreasing tissue residues. What resulted is the WVMA HACCP For Proper Drug Use, a six-step plan addressing not only food safety, but long-term proper drug use on dairies.
Using the principles of hazard analysis and critical control points (HACCP), this program has not only decreased tissue drug residues, but in August it received the prestigious 2012 American Veterinary Medical Association’s (AVMA) President’s Award, which recognizes individuals and groups inside and outside veterinary medicine who have made a positive impact on animal, human or public health, veterinary organizations and the profession.
“Our work started with examining the information supplied by FSIS and FDA and noting that the drugs found as tissue residues were the likely result of extralabel drug usage without having the proper withdrawal times applied before the animal was harvested for food,” says Dave Rhoda, DVM, University of Wisconsin, who heads the task force.
This information was shared with all stakeholders of the meat industry and the science behind extralabel usage of these drugs and how to establish the proper withdrawal time was also shared with stakeholders from the dairy industry. “The attentive attitudes of producers and veterinarians at those meetings demonstrated their desire to correct the residue situation and the results demonstrate they have applied what they learned,” Rhoda says.
VCPR critical to success
Having a veterinary-client-patient relationship (VCPR) is the basis for a successful program like this. “The FDA, Farmers Assuring Responsible Management Manual, Dairy Animal Care Quality Assurance Manual, and organized veterinary medicine have all accurately identified the VCPR as the key for allowing drug usage on a dairy,” Rhoda says.
“Laws exist defining the VCPR and the veterinarian roles. The WVMA recognizes that satisfaction of the statutory VCPR is an obligation, but the committee has always recognized that each individual dairy’s VCPR is unique and the HACCP program emphasizes the importance of identifying all the members of the VCPR team and defining the individual person responsibilities in the use of drugs on that dairy.”
The veterinarian needs the active role by developing sufficient knowledge about the dairy for planning the medical care and culminates with oversight of the drug usage by that veterinarian, Rhoda says. “The veterinary component in the VCPR is complicated by the fact that multiple veterinarians have roles on modern dairies. Establishing the communications, identifying the roles of these veterinarians, and most importantly defining the roles of responsibility for oversight of the drug usage on the dairy from this group can be done.”
The HACCP program is a comprehensive approach to assure food safety, but it also builds a plan for appropriate drug use. “The reduction in residues is the easy portion of applying the science of drug withdrawal from the system,” Rhoda explains. “The HACCP program is the evolution of this work so the VCPR team develops a plan that improves responsible drug usage application through identification of effective label applications first, assuring appropriate withdrawal time when extra-label treatment is necessary, and finally concentrating on appropriate drug usage.”
The WVMA HACCP For Proper Drug Use is based on farm-by-farm implementation. The WVMA says it positions the veterinarian at the steering wheel, but makes it necessary for them to work closely with owners, managers and employees when defining specific roles within the VCPR, protocols and SOPs. The organization has been active in presenting this plan to various stakeholders in the Wisconsin dairy industry as well as in other states.
The WVMA HACCP For Proper Drug Use has six clearly defined steps:
1. Veterinary-client-patient-relationship (VCPR) – identifying the VCPR team
2. Drug List – finding all drugs used on the dairy and how they are used
3. Protocols – developing protocols based on the farm and skill sets of employees
4. Standard operating procedures (SOPs) – developing SOPs based on the farm and skill sets of employees
5. Records – defining what needs to be recorded
6. Oversight – veterinary oversight to evaluate drug use, protocol/SOP drift, and management/economic information
Rhoda says implementation of this program has resulted in decreased tissue residues. While there is not currently a baseline to determine of milk residues have decreased, he says it is assumed reductions in tissue residue will also correlate in milk with decreases.
Making good treatment decisions is by itself a good welfare strategy. The HACCP plan includes protocol and SOP development and includes development of a record plan customized to the uniqueness of the dairy. “The big side benefit is to develop a plan for the oversight of the records to find opportunities where current drug usage is not likely to be effective and where they are unnecessary,” Rhoda says. “The HACCP program emphasizes detailing the responsibilities within the VCPR team, identifying drugs in use, planning how to use them, and who will use them.”
This then leads to the development of fundamental records which can be used for food safety. “Food safety is a primary objective, however an additional objective is improved drug usage and elimination of unnecessary usage so preferably we desire a management level record plan,” Rhoda suggests. “This leads to the ability of the veterinarian to routinely oversee how drugs are being used for not only accountability of food safety but also for appropriate drug usage.”
The VCPR is an example of why the emphasis of the WVMA is improvements in drug usage needed a non-regulatory approach because of the diversity within the industry. The VCPR is statutory and the regulatory application is to be complied with, but the non-regulatory approach of the WVMA HACCP plan revolves around developing a team of the members of farm personnel and the veterinarians involved into a team. “Drug residues are a people issue not a drug issue. It is critical that the veterinarians supply the knowledge for science-based use of drugs and the veterinarians then oversee drug use compliance and the welfare of treated animals.”
For more information, visit www.wvma.org.