As of January 1, 2017, new FDA rules mandate that medically important feed-grade antibiotics used in feed or water for any food-producing animal will require a Veterinary Feed Directive (VFD) order. The term “medically important antibiotics” means medications that are important for the treatment of human diseases; among antibiotics currently in use, chlortetracycline, chlortetracycline plus sulfamethazine, neomycin plus oxytetracycline, oxytetracycline, tylosin, and virginiamycin now fall under the VFD regulations.
In addition to ending over-the-counter purchases of these antibiotics, the VFD rule also expands the definition of “food-producing animal”. Under the new regulation, any animal that is part of a food animal species will require a prescription for medicated feed, even if the individual animal is not intended for food production. In other words, the rule applies not only to large livestock raised on farms but also to backyard poultry and even pets such as rabbits and pigs.
Producers and pet owners will likely have a lot of questions about these changes. In fact, a recent news article from the AVMA highlights the need for better education to prevent requests for illegal VFDs. So we’ve pulled together some important points and resources to help guide your clients and your staff through the new rules.
The first thing the new regulations call for is a formal veterinarian-client-patient relationship (VCPR). This relationship needs to be established before a VFD order is written. The exact definition of a VCPR will vary from state to state, but generally speaking, you will need to meet with each client to assume responsibility for making clinical judgments about the health of their food-producing animal(s). You will also need to perform patient examinations or site visits to livestock facilities for all of your clients’ food-producing animals and conduct any necessary follow-up evaluations or treatment. If the state in which your practice is located doesn’t have specific state-level VCPR requirements, you’ll need to follow federal requirements.
In terms of paperwork, VFD orders need to specify the animal(s) to be treated, the specific antibiotics to be used, and the dosage, duration, and reasons for use. Medicated feeds need to be used as directed by their labels, so VFD orders need to match exactly what is listed on the product label.
If your clients purchase medicated feed, the new VFD rules stipulate that it must be used within six months; for remaining feed to be used legally after the six month period, you will need to prepare a new VFD order. Similarly, your clients can still use medicated feeds purchased before January 1, but a VFD order will need to be prepared for those older feeds as well.
Animal producers and owners, vets, and feed producers will need to retain their VFD records for two years and could be subject to FDA inspection. You should set up a standard operating procedure for your staff to follow in the case of such an inspection, including some type of documentation and filing system that will make all of the necessary records easy to find.
The FDA has stated that it intends to focus on education and training during the first phase of the program’s roll-out in order to help vets and animal and feed producers comply with the new requirements.
Here are some further important resources about the new VFD:
AVMA Instructions for Completing a VFD Order (available for AVMA members only)
Full list of drugs covered under the new VFD rule