Getting Prepared For The Veterinary Feed Directive
By: Jill J. Dunkel
In the winter of 2017, feed store shelves may look a little different. Gone will be the days of producers walking in a store and purchasing items like medicated milk replacer or Aureomycin crumbles to top dress on feed without veterinarian involvement. Also gone will be the days of a feed mill manager adding tylosin or other antibiotics to a ration without veterinary oversight.
December 2016 is when Guidance 213 from the FDA’s Center for Veterinary Medicine (CVM) will take affect, requiring a Veterinary Feed Directive (also known as VFD) for any feed or water-administered antibiotics classified as “medically important,” with regard to their human medical importance.
According to Mike Apley, DVM, Ph.D., Frick professor and clinical pharmacologist with Kansas State University Veterinary School, the regulations will require a VFD for several commonly used products in the livestock industry, like tetracyclines including chlortetracyclines and oxytetracyclines and sulfonamides, as well as gentamicin, neomycin, tylosin and others.
However, ionophores (Rumensin, Bovatec, Cattlyst), bambermycins (Gainpro), anticoccidials and bacitracin products (BMD, Zinc Bacitracin [Albac]) will not require a VFD. Those antimicrobials are not classified as “medically important” according to the FDA guidance documents.
“That’s one thing that I want producers to understand. They will not need a VFD for ionophores,” Apley said at the NCBA Cattlemen’s College. “They are antibiotics, but they are not medically important.” It is important to understand products such as ionophores, Deccox, and MGA, when fed alone will not require a VFD, however if they are fed in combination with a VFD regulated product will require the appropriate VFD.
Apley explained that of medically important antibiotics that are administered to food animals, 70% have feed labels and 24% have water labels. Until Guidance 213 takes affect, none of those have required a prescription. In fact, 97% of medically important antimicrobials in the U.S. sold with the label for food animals are available over the counter, he said.
“It is indefensible in the public eye that we have antibiotics available for use in food animals without a prescription from a veterinarian,” Apley said. “And I support that. There needs to be a veterinarian involved in these decisions.”
Although Guidance 213 will definitely require changes in the steps those in the livestock industry take to utilize feed and water-administered antibiotics, the regulations are not something to be afraid of says Marilyn Corbin, DVM, MS, PhD, member of the Zoetis technical services team. Instead, producers should focus their efforts in getting prepared.
“I’ve been communicating to producers if you don’t currently have a consistent veterinarian that you go to all the time, the first step is to develop a relationship with a veterinarian. That way he or she has time to become familiar with your operation,” Corbin explained.
As part of the regulations, a veterinarian must have oversight of how any medically important antibiotics are administered to food animals. Thus, a professional relationship among all parties involved needs to be established.
“That’s first and foremost. Make sure you have a veterinarian, and they are comfortable with your operation so he can write a VFD when and if it’s needed,” Corbin said.
Another step in being prepared for the regulations is building a relationship with a nutritionist. That nutritionist could be an independent consultant, work for a feed company, a co-op, etc.
“The nutritionist would be someone you could call and get answers to how the antibiotics are mixed in feed,” she said. “The VFD is written by a veterinarian, but a lot of time there’s some label language,mixing, or ration information that your vet may not have all the information about. So it’s a really good idea if producers can develop a relationship with a nutritionist.”
The third step in preparing for the regulations is getting the veterinarian and the nutritionist to develop a professional relationship with each other. “If the veterinarian has a question on a product, maybe how a product mixes, how you deliver it and so forth, then the vet has someone he can call for some quick advice,” said Corbin.
Large feedyards will likely be more prepared, with consulting veterinarians and nutritionists already in place. However, smaller operators, ranchers, backgrounders, etc. may not have established these professional relationships. Corbin believes it is very important that they start preparing.
More specific steps will need to be taken once the final regulations are published, and that is expected later in the year. Until that time, understanding what is known about Guidance 213 and getting prepared for it is one of the best things producers can do.