In the last few years, it has been nearly impossible to open and read any Ag news
publication and not see an article about the Veterinary Feed Directive (VFD) and the changes by the Food and Drug Administration. When the Veterinary Feed Directive went into effect in 2017, it impacted nearly everyone in the livestock industry. Depending on whom you ask this has been a good and a bad thing.
Typically, the new regulations are not well received by the producer, who has been using
these over the counter products for years in an effort to raise healthy animals. As of January 1, 2017, every livestock producer who uses an antibiotic that is considered important to human health, such as penicillin or tetracycline, now has to comply. The regulation covers not only antimicrobial drugs administered via feed, but also water, but does not include injections. This also covers animals not intended for food consumption (AVMA, 2016). This rule change has even affected every retailer that sells these products and every veterinarian as well as any feed mill.
In short, a veterinarian now has to see the animal and diagnose it before the animal can receive the antibiotic. The feed provider keeps a record of every sale that contains antibiotics. This does not leave out the feed manufacturers, who are busy reformulating much of their feed and mineral products to comply. This regulation affects literally every person in the production of livestock in one way or another. The livestock producer is certainly the person who will feel the biggest impact from this mandate. As they are the last person in the line of production who cares for these animals, the producer has the ultimate responsibility to take care of their animals to the best of their ability. This mandate takes control of freely feeding antibiotics out of the hands of the producers, and puts this responsibility on the backs of the veterinarians. By doing this the vet-to-client relationship has strengthened immensely. The feeding practices of producers are being forced to change also. The antibiotic is no longer to be fed as a preventative feed, to keep the cattle healthy, but rather as a prescription feed, to be fed after the animal is already ill. This is hard for livestock operators to see, because as a producer, the main goal is to keep the animals as healthy as you can at all times. Now instead of preventing illness and keeping the herd from suffering, the producer must wait until an animal is ill to have a veterinarian come to the farm and diagnose and prescribe the use of antibiotics. The old adage “an ounce of prevention is worth a pound of cure” is more of a golden rule that a livestock producer lives by; the VFD is going against this time old tradition.
According to the VFD final rule, a producer’s veterinarian will fill out the form,
specifying the farm and animals to be treated, the drug to be used, its feeding rate, and the duration of treatment. The veterinarian will also indicate an expiration date on the VFD, which can’t exceed six months. Some drug labels may allow for a number of refills.
It will function similarly as when you go to your doctor because you are sick. Your
medical doctor then writes a prescription that you take to your local pharmacy. However, when the VFD drug category was created, the Federal Food, Drug and Cosmetic Act (the Act) made it clear that VFD drugs are not prescription drugs. This category was created to provide veterinary supervision without invoking state pharmacy laws for prescription drugs that were unworkable for the distribution of medicated feed (FDA, 2015).
Once the producer has secured the copy of the VFD, they will have to show proof of the veterinary approval to the feed salesmen or whomever they are purchasing their feed from. After the feed salesman provides the producer with the appropriate feed additive, the feed salesmen will have to keep a copy of the VFD, along with a sales receipt of sale of the product in his or her personal store record.
This puts an added expense on the farmer, having to pay for a vet visit or farm call along with the paperwork required for these essential antibiotics. It also places a toll on the small town rural veterinarian who is short staffed.
This also puts added pressure and liability on to the veterinarian, because they are now responsible to formalize this very simple task. If a vet does not actually see the animal that they are prescribing the antibiotics for, they are then breaking the law. In addition, the VFD limits extra label use. “Extralabel use” (ELU) is defined in FDA’s regulations as actual or intended use of a drug in an animal in a manner that is not in accordance with the approved labeling. For example, feeding the animals a VFD for a duration of time that is different from the duration specified on the label, feeding a VFD formulated with a drug level that is different from what is specified on the label, or feeding a VFD to an animal species different than what is specified on the label would all be considered extralabel uses. Extralabel use of medicated feed, including medicated feed containing a VFD drug or a combination VFD drug, is not permitted” (FDA, 2015). In some ways, this ties a veterinarian’s hands because the minor species of animals have very few labeled products available to use.
This issue is not only of concern to the people who are feeding and selling the product; it will also raise many questions for the companies who manufacture the products. Companies like Zoetis, a drug company and Purina a feed manufacturing company, have to change their whole supply of products. Now that the producer cannot buy a product freely, these companies are limited in what they are able to produce. The VFD forces these companies to discontinue some of their products that were conveniently combining antibiotics with other types of feed.
The impact of the VFD was first seen in common over the counter products sold in feed
stores. Medicated milk replacer was one of the first feed-grade antibiotic products to fall under the Veterinary Feed Directive. Typically, after the initial feedings, a dairy calf is placed on milk replacer, which is often medicated. When the new rules started, for any dairy farmer to put a calf on medicated milk replacer, he is now required to get a VFD from his veterinarian, fill it at a distributor who has registered that specific prescription with the FDA and ensured every qualification of the directive is met, then keep the records of that transaction for two years. Instead, most companies that manufacture milk replacer have changed their formulations to make it over the counter ready, without antibiotics.
So, what happens when the dairy producer suddenly has a calf that requires medicated
milk replacer over a long holiday weekend? It certainly isn’t the same-day process of
walking into the local farm store and buying it off the shelf; the dairy farmer isn’t able to call distributors with last-minute requests under the new regulations.
One can see that the final ruling from the Veterinary Feed Directive is affecting everyone in the livestock industry and will continue to due so for years to come. While the VFD is not a new thing it has certainly made some changes to the way people are used to doing things. This regulation is all in attempt to meet the ongoing concern and fear that the public has towards the use of feeds containing antibiotics in livestock production. Even though this ruling has come with much discussion and debate, the end result was an implementation date of January 1, 2017 (Zoetis, 2016).
A little about me
My name is Luke Daniels, I am a junior at Western Illinois University majoring in ag science with a minor in animal science. I grew up on a small farm near Shelbyville Illinois raising beef cattle and quarter horses. This is where my love for animal agriculture was started. I am a member of a few organizations on campus a few of those being Hoof and Horn club, Ag Vocators, and Lutheran Student Fellowship. Western Illinois has been a great learning environment for me and I am thankful for all the people who have helped me along my journey. I hope you enjoyed my blog and thanks for your time.
American Veterinary Medical Association. 2016. The 123’s of VFD’s. Available at: https://www.avma.org/KB/Resources/Pages/VFD123.aspx
Food and Drug Administration 2015. (Released December 17, 2015). Fact Sheet: Veterinary Feed Directive Final Rule and Next Steps, FDA. Available at: http://www.fda.gov/AnimalVeterinary/DevelopmentApprovalProcess/ucm449019.htm
Zoetis. 2016. Helping you understand the changes. Available at: https://www.zoetisus.com/responsible-antibiotic-use/vfd.aspx