There is only one thing for certain in our lives—change. And if you are a producer who uses antimicrobial medicated feed for prevention or treatment of disease in livestock, a modification to how you currently purchase this feed is looming on the horizon.
The Food and Drug Administration’s (FDA) Veterinary Feed Directive (VFD) and Guidance for Industry 213 took effect on October 1, 2015. It is scheduled to be fully implemented by December 2016. The VFD is not a new rule. It was originally based on the FDA Guidance for Industry 209 established in April 2012 which delineated policy for the judicious use of medically important antibiotics in food production animals. These policies were developed to protect public health and the limit the development of antimicrobial resistance.
Under the FDA Guidance for Industry 213 and VFD, all medically important antimicrobial feed medications will be used with appropriate veterinary supervision. Producers will need to have a written and valid VFD issued from their valid veterinarian-client-patient relationship (VCPR) veterinarian in order to purchase proper feed-additive medications from their feed supplier/distributor. Also, label claims of production and performance for medically important antimicrobial will be removed.
In order to have a valid VFD, you will need to work with your veterinarian with whom you have established a valid VCPR. Your VCPR veterinarian will examine and diagnose the animal condition(s) and determine if the use of a feed-additive medication is necessary. The veterinarian issued VFD is for any producer who would like to purchase feed containing antimicrobials which are medically important. Records will need to be maintained by the veterinarian, feed distributor and the producer. Antimicrobials have been used for years for the treatment of diseases in food production animals; however, those same medications are also used for treatment of human disease. The use and/or overuse of antimicrobials may have human health concerns as this usage practice may lead to the development of resistance of once susceptible organisms; thus, rendering the medication ineffective.
The veterinary profession—and only the veterinary profession, not an owner—is allowed provisions to use an FDA approved drug in a manner which is not in conformity with the product label. This is also known as extra-label drug use (ELDU). ELDU occurs when there is divergence from the label by usage in a different species, indication, dose, frequency and route of administration.
The Animal Medicinal Drug Use Clarification Act of 1994 (AMDUCA) and FDA regulations provide extra-label drug use in all species not just food producing animals. In addition, an algorithm is used to justify the usage of any approved FDA drug for extra-label drug use; however, certain medications are FDA prohibited and either may not be used at all or in an ELDU manner.