Make sure you're prepared for the new VFD part 2 with Dr. Tony Martin

by SuperUser Account

MFA Director of Animal Health Dr. Tony Martin has spent plenty of time on the road recently to answer questions about the upcoming implementation of the Veterinary Feed Directive. Here we highlight some of the top questions Dr. Martin took at producer meetings. The rule takes effect Jan. 1, 2017.

1. What about VFDs for rabbits or other minor species? FDA is considering this issue, but has yet to offer a final answer on the subject. The consideration includes allowing the use of a similar claim from a comparable species to be written as a VFD for a minor species. That idea carries with it some controversy as it would essentially be allowing Extra Label Drug Use (ELDU), which has always been illegal for feed additive medications.

2. Can a VFD be written for a feed antibiotic (tetracycline) for use to control or treat foot rot or pinkeye? No. There are no feed additive antibiotics that have a legal use claim for use against foot rot or pinkeye. Chlortetracycline, the most commonly used antibiotic in such instances, only has feed-use claims for anaplasmosis, bacterial enteritis and bacterial pneumonia. Therefore, a VFD written listing the use claim for foot rot or pinkeye would be illegal and not allowed to be filled.

3. Many producers have heard that purchasing product from a valid VFD will have very specific limits as concerns the amount of medication per pound or ton of feed with absolutely no overage allowed. Is that true? According to FDA explanations, no. The use of the term “approximate” in the number of animals listed on the VFD form provides a level of flexibility in the amount of product that can be purchased. Just as we do today, the VFD and conversations with veterinarians to get it, provide an opportunity to discuss the amount of product actually needed and to discourage gross over purchases. From the perspective of the producer and the veterinarian, overpurchase makes no sense. Overpurchase can be poor management in the sense that you spend money on an excess product that might go out of condition or lose nutritional or medication effectiveness. From the veterinarian perspective, it risks feeding medicated product longer than needed or directed by the VFD and the legal requirement to quit feeding any remaining VFD product on hand after the VFD expires.

4. What “teeth” are written into the law. What repercussions will be enforced as the rule is launched? The “teeth” are potential fines and, more importantly, the ability to designate treated animals as “adulterated” and prevent their sale or movement in the marketplace. But remember, the initial inspection effort will be to gather information about how the process is going and to educate producers and veterinarians.

5. Will VFD documents also be sent to the FDA? Will these VFD documents be subject to Freedom of Information requests? The answer to both is no.

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