Upcoming changes in rules regarding the use of medicated feeds likely will cause a few headaches among producers and veterinarians, but in the long run, should promote stronger, beneficial veterinarian-client-patient relationships (VCPR).
The changes relate to the FDA’s new veterinary feed directive (VFD) rule, which will require veterinarian oversight for the use of medically important antibiotics used in livestock feeds. The new rule takes effect on Oct. 1, 2015, and will immediately apply to those drugs which already require a VFD. It will apply to a much longer list of new VFD drugs when their new labels are phased in during December 2016.
Producers, accustomed to purchasing medicated feeds over the counter will need to begin working with their veterinarian to secure a VFD order that specifies how the medication will be used, on which animals, for what purpose and for how long. The rule specifies that veterinarians must write VFD orders within the context of a valid VCPR, and the veterinarian, producer and feed distributor are accountable for following label specifications for the use of medicated feeds. Extra-label use of feed-grade antibiotics is prohibited.
According to Farm Foundation, which has been hosting VFD workshops around the country this summer and fall, it has become apparent that many livestock producers, especially small, independent producers, have no awareness of the changes taking place. So now is the time for veterinarians to begin reaching out to their clients and other producers in their area, building awareness of the VFD rule and to begin assessing how producers use medicated feeds and what products they use that will fall under the new rule.
Carie Telgen, DVM, is a dairy veterinarian, owner of Battenkill Veterinary Bovine, Greenwich, NY and District 1 Director for the American Association of Bovine Practitioners (AABP). Telgen presented at one of the Farm Foundation workshops that took place in New York in September. She says feedback during the workshop mirrored what she has observed among her clients, showing the majority of producers have little or no awareness of the upcoming VFD rules.
Most veterinarians, Telgen says, seem aware of the upcoming changes but at this stage are not treating the issue with a great deal of urgency.
The key for veterinarians over the next year, and in the months following enactment of the rules, will be communications with clients, nutritionists and feed distributors. Nutritionists in particular are key players in the transition, she says. Currently on many operations, the nutritionist is the person working between the client and the feed distributor in supplying medicated feeds. The veterinarian typically is aware of drug use within the herd, but leaves the details and execution up to the nutritionist and producer. That process will change with release of the new VFD drug labels in December 2016, requiring direct oversight of a veterinarian within the context of a valid VCPR.
“It will change the dynamics of how we work with clients,” Telgen says, “especially smaller clients who typically do not see their veterinarian often.” Veterinarians, she adds, will need to understand the VCPR requirements in the states in which they practice. The rule specifies that if a state has a veterinary practice act that defines VCPR, that state regulation will govern a veterinarian’s responsibility for VFD orders in that state. If the state does not have a VCPR law, the veterinarian needs to apply the federal definition. That, Telgen says, is the case in her home state of New York.
By establishing a VCPR with more clients, Telgen believes veterinarians will have an opportunity to become more involved in their overall animal-health programs, including establishment of preventative protocols to reduce the need for medicated feeds. Clients who currently just call their veterinarians to address emergencies and use their nutritionist for obtaining and administering medicated feeds will need to bring a veterinarian into the process. She also notes that for many veterinarians, the VFD rule will force them to learn more about medicated feeds, their uses and label requirements, since they haven’t worked extensively with those products.
Producers, Telgen says, will in many cases need to plan ahead more than they do currently. Many now do not contact their feed mill until the day they want the feed. The requirement for a VFD order from a veterinarian will add time to the process. She hopes electronic VFD orders accessible with mobile devices will create efficiencies, but she expects those first few months under the new rule to be hectic for all involved.
FDA plans on-farm drug-use data collection
In addition to the upcoming VFD rules and enactment of Guidance 313, which removes performance or production claims from medically important antibiotics, FDA plans to ramp up its monitoring of antibiotic use and resistance trends.
According to a recent release from FDA, gathering information on the way medically important antibiotics are used is essential to measuring the impact of the agency’s judicious use strategy. The FDA currently collects sales data on antimicrobial drugs sold for use in food-producing animals and data on antimicrobial resistance (collected under the National Antimicrobial Resistance Monitoring System (NARMS)). However, the agency recognizes that additional information is needed about on-farm use practices to adequately understand links between usage patterns and trends in resistance.
The FDA, U.S. Department of Agriculture, and the Centers for Disease Control and Prevention are working together to develop and implement a plan to collect additional data on antibiotic use in food-producing animals and will conduct a jointly sponsored public meeting to obtain input on approaches for collecting on-farm antimicrobial drug use and resistance data. The public meeting will be held on September 30, 2015, from 8:00 a.m. to 4:30 pm in Washington, DC. More information is available on the FDA website at fda.gov/AnimalVeterinary.
On-farm use data collection is consistent with objectives outlined in the National Action Plan for Combating Antibiotic-resistant Bacteria to enhance monitoring of antimicrobial-resistance patterns, as well as antimicrobial sales, usage, and management practices, at multiple points in the production chain for food-producing animals and retail meat.
This data collection plan, according to FDA, is intended to provide the data needed to:
· Assess the rate of adoption of changes outlined in the FDA’s Guidance #213.
· Help gauge the success of stewardship efforts and guide their continued evolution and optimization.
· Assess associations between antimicrobial use practices and resistance trends over time.