The following commentary does not necessarily reflect the views of AgWeb or Farm Journal. The opinions expressed below are the author's own.
The FDA’s veterinary feed directive (VFD) rules, in effect since January 2017, have caused some confusion and left some producers frustrated with fewer options in some aspects of their herd-health programs. Old habits can be hard to break, and when producers could purchase medicated feeds over the counter (OTC), some became accustomed to using feed-grade antibiotics in ways not specified on the label, such as “pulse” treatments or offering medicated feeds “free-choice” when the label specifies hand feeding.
FDA rules do not allow extra-label use of medically important antibiotics in feed, but their OTC status enabled some uses that were, and are, unlawful. Those uses were not necessarily irresponsible or risky, and in many cases achieved their goals. Today though, with the VFD rules requiring veterinary oversight, we all need to remember that drug-label specifications are legally binding, not just guidelines or recommendations.
While most producers have learned to adapt and comply with the rules, word on the street suggests some have either tried to coerce their veterinarians into falsifying VFD orders to obtain medicated feeds for extra-label use, or intentionally misled their veterinarian regarding intended use of the VFD product. Either of those practices will, eventually, result in negative outcomes for all involved.
The VFD rules specify a need for a valid veterinarian-client-patient relationship (VCPR) before the veterinarian signs off on a VFD order. This means the veterinarian must be adequately familiar with the producer and the animals in question to make an informed decision on the use of medicated feeds for a specific purpose. The purpose, dosage and duration of use specified on the VFD form must comply with the product label. A veterinarian puts his or her reputation, license and very livelihood on the line when filing these documents. Use of medicated feeds these days requires a partnership between the producer, veterinarian and feed supplier, all acting in good faith.
When the new VFD rules launched last year, the FDA indicated their initial enforcement efforts would focus on education – they would work with stakeholders to correct problems rather than imposing penalties. Eventually though, enforcement will become more strict and FDA will impose penalties for VFD violations.
Next week, on May 9, GlobalVetLink will host a webinar on the VFD audit process and FDA enforcement, featuring several expert panelists outlining the program and answering frequently asked questions. The presentation offers a good opportunity to clear up questions you might have on VFD compliance.
In any case, work with your veterinarian to find ways to protect herd health while complying with the letter, and spirit, of the VFD rules. This might involve shifting toward more management practices and products intended to enhance disease prevention and thus reduce the need for medicated feeds. In the short run you’ll help achieve the goals of the VFD rules and antibiotic stewardship, and in the long run you could see greater returns from healthier, more productive animals.