As of Jan. 1, 2017, the feeding of anti-microbial medicated products to any livestock that are in the human food chain can be authorized only by a licensed veterinarian.
Those products, which are also known as feed antibiotics, have been popular for enhancing animal growth and improving feed efficiency — reasons that will no longer be acceptable under the new federal Veterinary Feed Directive set to take effect in about three months.
How ready some of the growers of such livestock are in complying with the VFD is a concern of Sarah Mills-Lloyd, a former practicing veterinarian who is the Extension Service agriculture agent in Oconto County. In particular, there's no doubt that many livestock growers do not have the appropriate professional relationship with a licensed veterinarian, she said.
All livestock affected
The VFD affects not only all dairy and beef cattle but also hogs, poultry, sheep, and goats, Mills-Lloyd reminded attendees at the recent farm management update for ag professionals sponsored by the Extension Service offices in east central Wisconsin counties.
To comply with VFD, all owners or caretakers of livestock that are part of the food chain for humans must have a valid existing veterinarian client patient relationship (VCPR), Mills-Lloyd said. A VCPR implies that the veterinarian is familiar with the livestock, owner and facilities, but unlike some other states, Wisconsin does not have a definition of what constitutes a valid VCPR.
While attending a recent conference, Mills-Lloyd learned of a survey which indicated that 100 percent of the dairy operations with at least 500 cows had a VCPR and that 94.5 percent of those with 31 to 100 cows did but the percentage fell to 78.4 for owners of dairy herds with up to 30 cows. There's no similar data for hobby farms which grow livestock or for 4-H and FFA youth animal projects - - all of which are also required to comply with the VFD, she noted.
History of VFD
Mills-Lloyd traced the history of what has evolved into the VFD to federal legislation in 1994 that addressed the extra-label use of drugs by veterinarians on all animal species. Guidance for a policy on “the judicious use of medically important antibiotics” in food production animals was established by the federal Food and Drug Administration in April of 2012, leading to the Jan. 1 effective date of the VFD.
The medically important antibiotics governed by the VFD apply to eight classes of antibiotics that are also administered to humans, Mills-Lloyd said. The intent of the VFD protocol is to prevent the overuse of the antibiotics or anti-microbials with food production animals because of the possibility that this could lead to human resistance to organisms that were once susceptible to those antibiotics.
Antibiotics are used to treat bacterial diseases, not viruses, Mills-Lloyd stressed. She noted that the antibiotics can be administered by injection, ingestion or topical application.
Under VFD, the owners or caretakers of all food production animals will need a written authorization (paper or electronic, not verbal) from the VCPR veterinarian in order to obtain medicated feeds from a feed mill or other supplier.
That authorization will have to be very specific regarding the drug name, duration of use, the animals involved, the premises, the withdrawal time for putting the animal into the food chain and other factors, Mills-Lloyd said. She noted that veterinarians are still allowed to prescribe the drugs governed by VFD in specific situations to prevent, control or treat diseases.
The VFD approvals do not allow any substitutions of drugs or unapproved combinations of antimicrobial products, Mills-Lloyd said. In addition, all or the parties — livestock owner, veterinarian and medicated feed supplier — must keep a record of each of the authorizations for two years, probably resulting in an increase in the cost of services to livestock owners.
Mills-Lloyd warned livestock owners to avoid the temptation of stocking up on any remaining medicated feeds on December 31. She noted that the drug suppliers are also required to update their labels to comply with VFD, which is a starting point for veterinarians only to authorize an extra-label use of that drug either on a different species, dose variation, frequency, or manner of administration.
When asked how prepared the affected parties are for the legal changes they will face Jan. 1, Mills-Lloyd said there are definitely differences in preparedness in those groups. She suspects that a number of affected parties, particularly the owners of small groups of livestock, aren't even aware of the new regulations.
Feed mills and other medicated feed suppliers need to inform the FDA that they intend to distribute the products, Mills-Lloyd said. The latest information suggests that Wisconsin's feed mills are lagging on getting themselves on that list.
Instead of relying on medicated feeds for their animals, livestock owners should consider management practices that would reduce the need for those products, Mills-Lloyd advised. She cited some evidence that this is already occurring on the need to treat dairy calves for diarrhea and respiratory diseases.
National statistics for 2011 and 2014 show a gradual reduction in the incidence and treatment of those threats to calf health, Mills-Lloyd reported. For diarrhea, the infection and treatment rates dropped respectively from 25 to 21 and 18 to 16 percent for those years. For respiratory diseases, the drops in incidence and treatment were from 18 to 16 and 12 to 11 percent for those two years.
In addition to the specifics of the VFD, Mills-Lloyd observed that in general the use of antibiotic drugs creates an overlap on the interests, attitudes and concerns of government, consumers, veterinarians, the medical community and livestock owners. Within that tangle, one positive is that public confidence is high in veterinarians, doctors and nurses.
To a question on what the penalty would be for violating the VFD, Mills-Lloyd said the details are not yet available. For other incidents involving the misuse of animal drugs, the FDA has a practice of issuing a warning letter to the offender before taking more serious action on any repeated violations.
Persons wanting or needing to know more about the upcoming VFD can check http://www.fda.gov/AnimalVeterinary/DevelopmentApprovalProcess/ucm071807.htm or contact Mills-Lloyd by email at firstname.lastname@example.org or by phone at 920-834-6845.