Editor's note: The following column appeared in the January 2016 issue of Dairy Herd Management.
The final rule for the Veterinary Feed Directive (VFD) was released in October 2015, and will go into effect in December 2016. This U.S. Food & Drug Administration (FDA) regulation changes the way veterinarians authorize the use of medicated feed additives considered medically important to humans. Veterinarians and dairy/beef producers should prepare now for how these new rules affect their use of some products.
There are two overarching principals FDA has established for the use of these products in animal feed:
1) Judicious use of these products is limited to treatment, prevention or control of disease. Therefore, growth promotion and feed efficiency indications will no longer be on the labels of these products.
2) Use of these products will require a valid Veterinary Client Patient Relationship (VCPR), and the veterinarian must write a VFD enabling the producer to use these products.
It is important to recognize what products are affected by these rules. For cattle, the main products will be tetracycline, tylosin and neomycin. Products not affected include over-the-counter (OTC) injectable antibiotics and feed grade products not used in human medicine, such as ionophores (Rumensin® and Bovatec®). Drug manufacturers will change labels on these products to remove growth promotion and feed efficiency claims by December 2016. At that point, all OTC products will have new labels with an indication for treatment, prevention or control of disease, with specific instructions for use.
How should farmers prepare? Meet with your veterinarian to discuss the products you are currently using, and how they will be used in the future. Preparing now will prevent a lapse in the use of these medications that may be necessary on your farm.
It is also important to understand the legalities of feed-grade antibiotics. It is illegal to use these products in an extra-label manner. This is not a new rule; it has been illegal since 1994. This means the products cannot be fed to a production class of animal not on the label, cannot be used for a longer period of time than on the label, cannot be used for a different disease than is on the label, and cannot be used at a different dose than is on the label. Examples of illegal use of these products would include feeding chlortetracycline to dry cows, feeding chlortetracycline for pinkeye prevention or foot rot, or feeding the product as a continuous use if the label says to feed only for a certain number of days.
Another thing to consider is use of combinations of drugs in your animal feed. It is illegal to feed a drug product in combination with another drug without a specific approval for such use. The best example is feeding an antibiotic product such as chlortetracycline to heifers when Rumensin® exists in the feed, since there is not an approval for such use.
What are some examples of how these rules might affect dairy farms?
1) Medicated milk replacers. Use of these products will require a VFD from your veterinarian. Furthermore, FDA does not envision a situation where these products would be approved for continuous use feeding. Therefore, farms must use the products only for the duration approved on the label.
2) Tetracycline products fed to heifers for pneumonia treatment/prevention/control. There are several products labeled for this use. However, in December 2016 it will require a VFD from your veterinarian to use the product. Users must adhere to product labels for duration of use, as well as dosage. Talk with your veterinarian about any other feed additives in the heifer mix to prevent feeding an illegal combination product.
3) Tetracycline powder for topical hoof treatment. The powder will be a prescription product, since it is water soluble. Talk with your veterinarian and hoof trimmer about how you will use this product in the future. These products can be used extra-label, since it is a prescription water-soluble product. Your veterinarian can provide a prescription and directions for use.
Plan ahead and work with your veterinarian to develop proper drug use guidelines for your farm. Discuss what products you use in the feed, milk replacer and topically, so your health care team can develop a plan best suited to your needs.
Fred Gingrich, DVM, is a practicing veterinarian and owner of Country Roads Veterinary Services, Inc., in Ashland, Ohio. Contact him via e-mail: [email protected].