by Sally Colby
The final rule for the veterinary feed directive (VFD) became effective on Jan. 1, 2017, and many producers are still unsure of how it works, which drugs are affected and how to obtain drugs that now fall under the directive.
The VFD is a written statement provided by a veterinarian under a veterinarian client/patient relationship (VCPR). Dr. Mike Apley, professor of veterinary clinical sciences at Kansas State University, says the VCPR varies from state to state, and suggests that producers visit the FDA website to learn each state’s requirements for the VCPR.
The final rule for the VFD was issued in 2015, and some drugs have been phased out over time. The inspection program for 2016 involved examination of VFD orders, requirements for all parties involved (veterinarian, feed mill, supplier, farmer) and record keeping. Apley says the intent is to phase in compliance over a period of time. “The initial phase is going to rely heavily on education about VFD requirements,” he said. “The first step for the inspection is the distributer, and then follow back to the vet and producer from there.”
Some of the details that must be included on the VFD form include veterinarian’s name address and phone number; clients name, business or home address and phone number; and the location of the premises of the animals specified on the VFD. Other information includes species and production class of animals to be fed the VFD feed, approximate number of animals to be fed the VFD feed by the expiration date of the VFD order, the reason (indication) for the VFD, level of VFD drug in the feed and duration of use, number of refills allowed and withdrawal time, special instructions and cautionary statements regarding the drug and its approved labeling.
The form will also include the required statement ‘Use of feed containing this veterinary feed directive (VFD) drug in a manner other than as directed on the labeling is not permitted.’
The client will be expected to keep VFD orders for two years, use the feed for the number and group of animals authorized on the VFD order, feed only during the period that the VFD is valid, stop feeding the VFD feed prior to the expiration date on the order, and follow the withdrawal period for the VFD feed.
“If 2,000 animals are authorized on the VFD order, you don’t have to feed 2,000, but you cannot have fed it to 3,000,” said Apley. “You had authorization for 2,000 animals, and the number to which that VFD was fed according to the labeled VFD directions has to be for that amount or less.
One confusing aspect of the VFD involves drug combinations. “The FDA has approved concurrent feeding for some drug combinations,” said Apley. “If you are feeding a drug and wish to feed another one and their concurrent use has not been approved by the FDA Center for Veterinary Medicine, you may not feed those drugs at the same time. This also includes practices such as top-dressing one drug on top of another, or AM/PM feeding. Those are considered concurrent feeding.”
Monensin (rumensin), is an ionophore, and considered a non-medically important antibiotic that does not require a VFD if it’s in the ration alone. Tylosin is a VFD drug, and requires a VFD to be fed in rations. “To feed that combination, the VFD for tylosin will have to approve the feeding of tylosin with monensin,” said Apley. “There are several ways this can be done. First, only feeding the VFD alone is allowed — no concurrent feeding. The second is that the VFD authorizes the use of the VFD drugs cited in the order in any FDA approved, conditionally approved or indexed combinations that contain this VFD drug as a component. Third, the veterinarian may authorize specifically other FDA-approved drugs to feed with the VFD drug.”
Another point of confusion is pulse dosing, or using the same antibiotic on the same animals at two different times. “You may have a VFD drug that is approved for feeding for a certain period, and desire to, if needed, repeat that feeding period after an initial discontinuation,” said Apley. “For example, feed for five days, then after a two or three day gap we think the animals still require the medicated feed; reinstitute the therapy for another five days as a new drug regimen. The current recommendation is that that will require two VFDs, one for each pulse.”
Multiple drugs cannot go on one VFD, even for the same group of animals. Apley explains, “If a producer wants to feed chlortetracycline upon arrive in calves, then wants to use tylosin later in the feeding period, the correct way to approach that would be a VFD with all of the specifications for the chlortetracycline, then authorize the feeding of tylosin and/or Rumensin after that. But would require a separate VFD for each drug.”
Many producers have asked whether a separate VFD will be required for each pasture or pen of animals. “The answer is no, it isn’t automatically required,” said Apley. “If the pastures or pen are under the same management and fed from the same source (feed mill, on-farm preparation or a type C VFD feed purchased from the distributer) and if the multiple pens or pastures are under your management, then one VFD is required.”
In a beef feedlot that houses cattle owned by more than one individual, the manager-caretaker of the feedlot keeps a copy of the VFD and also a copy of the prescription for labeled drugs.
Apley says it’s important to understand that the veterinarian must be licensed where the cattle are located. For example, if cattle are moved to summer pasture in another state, the veterinarian must be licensed in that state so that location is covered under the VFD written for you in the state where you reside. “The veterinarian must be licensed where all animals will be receiving the feed under that VFD,” he said.
Beef producers who mix chlortetracycline with minerals for the control of anaplasmosis will no longer be able to do so. “Free choice type C feeds (including minerals) for this purpose may only be manufactured from type A feed articles by licensed feed mills, and the inclusion rate and formulation of that mineral are both approved,” said Apley. “The only one that’s publically available and published is one for 6,000 grams/ton inclusion rate in mineral with a specified formulation for that mineral. Any deviation from that formulation would require approval by the FDA Center for Veterinary Medicine.”
Producers who have not yet established a VCPR should do so as soon as possible so that they will be able to obtain prompt veterinary attention and any appropriate VFDs necessary for herd health.
Read Part One here.