The changes instituted by the FDA are part of a voluntary program by the agricultural pharmaceutical and livestock industries to phase out certain antibiotics labelled for use as growth promotion in production animals. The use of antibiotics in feed or water at low levels has the potential to create antibiotic resistant bacteria. Antibiotics targeted in the rule changes are those considered important or critically important for human health. Less than judicious use of antibiotics in both people and animals undoubtedly contributes to the problem of bacterial mutations and antibiotic resistance. Eliminating antibiotic use purely for growth was believed to be a fast and efficient way to reduce non-judicious use of antibiotics in the food animal industries. Ultimately it is hoped that this action will slow the development of resistant bacterial strains.
Antibiotics in feed or water can still be used in specific circumstances to improve animal health, especially when targeted for a short time during stressful periods or feed changes. The use of oral antibiotics for disease prevention or control will still be allowed. Disease control or prevention can lead to better herd or flock health and can produce increased weight gains and decrease the cost of production for animals. This is different than a pure growth promotion use. The FDA rule change will put the use of antibiotics in feed or water under the control of veterinarians. A veterinarian must have a valid client patient relationship (VCPR) with the farm before he or she can write a VFD for oral antibiotic use on a farm. Records will be required to be kept by the veterinarian, the feed mill, and the producer for two years.
This rule change will put extra responsibility on producers, feed mills, and veterinarians. For veterinarians both federal and state professional regulations will be affected. In PA only licensed veterinarians will be able to write VFD under a VCPR. Veterinary professionalism and VCPR are regulated in the PA Code, Title 49, Professional and Vocational Standards. These regulations are administered by the State Board of Veterinary Medicine under the auspices of PA Department of State (PA Code, 1965). The FDA has given discretion to states to enforce VCPR rules if state guidelines meet or exceed federal standards.
Antibiotic resistance can be reduced through more judicious use of antibiotics by both public and animal health sectors. The CDC recommends four key components to reduce the spread of antibiotic resistance:
1. Infection prevention and control, including practices with greater attention to biosecurity
2. Tracking of antibiotic resistance
3. Improving antibiotic prescribing and use-stewardship
4. Developing new drugs and diagnostic tests for resistant bacteria (CDC, 2013)
Producers and their veterinarians should develop protocols for common infectious disease scenarios.
• Use antibiotics only when indicated under a valid VCPR
• Whenever possible use a narrow-spectrum antibiotic
• Use antibiotics for the shortest time necessary
• Use accurate estimates of weight to calculate dose properly use approved routes of administration
• When treating livestock, use non-human antibiotic categories when possible
• Use cultures and sensitivity tests to guide therapeutic decisions and reduce resistance
Rule changes to the VFD are predicted to balance public health, humane treatment of animals, food safety, and reasonable costs of production.