Veterinary Feed Directive Questions and Answers (Part 1 of 3)

The Veterinary Feed Directive was developed out of the concern for antibiotic resistance associated with daily antibiotic use in animal feeds.
By Rob Eirich, Nebraska Beef Quality Assurance, Nebraska Extension; Matt Luebbe, UNL Beef Feedlot Specialist; Richard Randle, Nebraska Extension Beef Veterinarian; and Dee Griffin, UNL-Great Plains Veterinary Educational Center

KEY POINTS: When the VFD regulations go into effect, they will ONLY apply to antibiotics used in the feed! They will not affect other feed use medications such as; ionophores, coccidia, other parasite and insect control drugs, or reproductive control medications. VFD regulations will not apply to antibiotics used by injection, tablet, bolus or water.

WHY HAS THE FDA DEVELOPED THE VETERINARY FEED DIRECTIVE (VFD)?
The driving force is the concern for antibiotic resistance associated with daily antibiotic use in animal feeds. Over a decade ago the decision was made to move toward removing all antibiotic use in livestock that was associated with growth and/or feed efficiency or long term use, over 21 consecutive days that allowed extended time for bacteria to develop resistance. The VFD concept became the option for allowing vital feed antibiotic use in livestock for protection of their health and well-being. Antibiotics approved for use under the VFD regulations will be for “prevention”, “treatment” and/or “control” of specific bacterial diseases.

WHAT IS THE VFD REGULATION TARGET?
Antibiotics used in livestock feed and minerals will be the ONLY drugs affected, AND THEN only the antibiotics considered “Medically Important to Humans”. Ionophores are antibiotics NOT important to humans and will not be affected. Additionally no other drugs such as parasite control, insect control or reproduction control feed additives will be affected.

WHAT EXACTLY IS MEANT BY DRUG USE FOR "PREVENTION", "TREATMENT" OR "CONTROL" IN THE VFD REGULATION?

• “Prevention of Disease” with a VFD can be approved when a known disease risk is present and the VFD antibiotic can be administered to prevent animal infections. None of the animals in the group are exhibiting clinical signs of disease but where the disease is likely to occur if the drug is not administered. 
• “Treatment of Disease” with a VFD antibiotic can be approved when animals are exhibiting disease signs.
• “Control of Disease” with a VFD antibiotic can be approved to decrease the spread of disease when a percentage of the animals in the group have exhibited disease signs and the clinically sick are being individually treated. 

WHAT IS A VETERINARY FEED DIRECTIVE?
A Veterinary Feed Directive (VFD) is a written order (paper or electronic) by a licensed veterinarian in the course of their practice approving the use of a VFD medication. The difference between a VFD and a Veterinary Prescription is a VFD isn’t governed by a state’s “Board of Pharmacy” which simplifies the inventory control, dispensing and required records. VFD regulations do not apply to injectable antibiotics. 

WHAT DOES IT MEAN FOR VETERINARIANS?
Veterinarians will become responsible for all feed use of antibiotics considered by the FDA as medically important to humans. The following bullet list outlines many of the specific tasks that will be required of licensed veterinarians to issue a VFD for a cattle farm or ranch client. 

• Veterinarians must be licensed in the state in which the cattle reside.
• Must have a proper VCPR (Veterinary Client Patient Relationship) with the cattle operation.
• Must prepare and sign the VFD supplying all the required information.
• The VFD they authorize must comply with all conditions of approved use.
• Must include required information if the VFD drug is to be used in combination with other VFD drugs.
• Must restrict or allow the VFD drug in combination with one or more approved Over-The-Counter (OTC) feed medication.
• Must assign the approved VFD expiration date and the “drug withdrawal time” following approved duration of the VFD use.
• Can indicate if a “generic” VFD drug can be substituted for the “pioneer” VFD drug.
• Must develop a mixer “flushing” or “clean-out” protocol to prevent a VFD drug from contaminating subsequent mixed feeds.
• Must provide the feed distributor or mill (if other than “on-farm” mixing) a copy of the VFD, which can be transmitted by fax, email or electronic, however, the distributor must receive a hard copy of the “VFD order” from the vet within 5 working days.
• Must provide the client (cattle operation) a copy of the VFD. If the “client” is also the “mill” they also receive the “mill” copy.
• Must keep original VFD for two years (Two year retention is also required for the client and feed distributor copies).
• Must provide VFD orders for inspection and copying by the FDA upon request.
• Some VFD medication will allow disease diagnosing by trained non-veterinary cattle care takers
  • For VFD medications that allow this, the veterinarian must develop training for the non-veterinary care takers, provide documented training and have a copy of the training outline or materials on file in the cattle operations office .

WHAT DOES IT MEAN FOR CATTLE PRODUCERS?
Cattle producers must have a relationship with a licensed veterinarian. 

• The FDA and the state’s agency regulating “Veterinary Licensure” specifically defines this relationship in their regulations as a “Veterinary Client Patient Relationship” (VCPR). It requires the licensed veterinarian writing the VFD to: 1) be familiar with the care and management cattle receive by a client including being able to make a preliminary diagnosis of the targeted concern, 2) is willing to assume responsibility for making clinical judgements and the client agrees to follow the veterinarian’s instructions, 3) the veterinarian is willing to provide treatment oversight and will be readily available for follow-up evaluation and case management, 4) case and treatment records are maintained and evaluated by the veterinarian. 
• Cattle producers will find obtaining VFD antibiotics simpler and less frustrating if they will visit with their veterinarian ahead of the need for the feed antibiotic. 
• Let your vet know about upcoming cattle management issues that may require a feed use antibiotic. Examples might include; weaning, anticipated cattle purchases or a seasonal endemic disease such as Anaplasmosis.
• Visit with your vet about how a VFD medication will be obtained on a timely basis through your feed distributor.
• In your conversation be sure to discuss other feed additives you typically use and ask about specific limitations that will have to be considered when a VFD medication is used. 

Cattle producers considering a VFD medication might find it useful to visit with their feed distributor about the details to be considered when obtaining the VFD medication from their distributorship.