Debriefing: Retrospective on the VFD experience
By Clayton Johnson, DVM
Carthage Veterinary Service
Integrated Veterinary Network
I remember the year 2016 very well. We were relieved that porcine epidemic diarrhea had been largely under control for the past year. And we were looking ahead at the next big wave of change in our industry.
FDA guidance documents laid out a roadmap for our new reality regarding the use of in-feed antibiotics. Judicious use of medically important antibiotics was spelled out. Pathways for animal drug-company compliance were defined. Perhaps most important to pork producers and veterinarians was the updated veterinary feed directive (VFD) rule that would take effect in January 2017.
In many ways, the last months of 2016 could be compared to the last months of 1999. In 1999, we had the “Y2K” scare and feared a calendar-formatting bug would cause our computers to crash, throwing our veterinary practices and pork producer businesses into chaos. At the end of 2016, there were serious concerns among many veterinarians and producers about their ability to comply with the updated VFD rule.
Minimal drama
As it turned out, there was very little disturbance when the calendar rolled from 2016 to 2017. No black helicopters circled farms. No FDA agents swarmed feed mills. Admittedly, a few of us were scrambling to get VFD procedures in place, but all in all it was a smooth transition. Producers, veterinarians, drug sponsors and providers of information systems such as Global Vet Link did a great job preparing for the change. VFDs have become a routine part of our business.
Implementation of VFDs has had a positive impact on our industry. Some producers needed to reevaluate their “standard” feed-medication schemes, and the updated VFD rules provided an opportunity to initiate those discussions.
One important change in all the herds and systems I work with has been the elimination of antibiotic pulse treatments. In some cases, they were replaced with vaccinations, management changes or simply a different route of antibiotic administration. In many cases, however, antibiotic pulses were eliminated. It turns out that for many herds, they may not have been needed to begin with.
Part of the anxiety the updated VFD regulations initially caused was FDA enforcement plans, which include inspections. The agency started slowly and reasonably with “practice audits.” This helped producers and veterinarians by encouraging them to review their procedures, and it helped educate the FDA auditors about what to look for and how to efficiently ensure compliance.
Auditing experience
During the summer of 2017, our practice was randomly selected for an audit. An FDA auditor showed up unannounced at the clinic one morning, asking to speak with a veterinarian. The auditor was patient and courteous — and terribly naive about the pork industry and the VFD process. He seemed shocked when I pulled up Global Vet Link and showed him on the computer how we stored and shared VFDs among our veterinarians, producers and feed mills all on one simple website.
He didn’t ask for a specific VFD. He asked that I pick one and show him our copy, the copy sent to the producer and the feed-mill copy. I picked the first one that came up on the screen. We printed copies of the VFD paperwork for him, then I accompanied him to the producer’s feed mill where we repeated the process of logging into Global Vet Link and printing off the VFD.
We spoke for maybe an hour. The conversation consisted of normal chitchat, and he asked a lot of questions about our process. As we departed the feed mill, he assured me we were in compliance and was appreciative we were patient with him since he was learning about the VFD process. All in all, it was a pretty painless ordeal.
VFD revisions
This year, the FDA has been working on revisions to VFD directives. Producers and veterinarians have been given the opportunity to share concerns and ask questions regarding the clarification of important areas of compliance.
One focus of discussion at various industry group meetings with FDA representatives has been about VFDs for feed-medication strategies involving use of the same medically important medication at the same dose and indication more than once in a group of pigs. Can veterinarians simultaneously write two VFDs for the same medication, dose and indication for the same group of pigs if they believe the pigs will need two rounds of treatment? The answer is “no.”
The first round of medication should be finished before a veterinarian determines that a second is needed, although it’s fine to repeat the same medication, dose and indication in the same group of pigs if needed. We can’t just assume the first round won’t work and plan for two rounds of treatment. The VFD, of course, must authorize a duration of use that is consistent with the medication’s label.
We should expect more regulatory oversight on the use of antibiotics in food animals in the coming years. Antibiotic resistance is a global public-health concern, and we veterinarians have a role to play in the discussion about the smart utilization of antibiotics, which are an amazing resource.
There is a vocal minority who are disgruntled with VFD requirements and believe it’s an exercise in “smoke and mirrors.” Personally, I’m proud of how our industry has collectively responded to growing health concerns about antibiotic resistance. We heard the concerns and responded with proactive and often voluntary measures.
Change is always hard but consider what we’ve already accomplished. We are protecting pig health and producing safe, wholesome food. We are protecting human health. We are preserving the efficacy of antibiotics for future generations of farmers and consumers — and that’s tremendously rewarding.
Editor’s note: The opinions and recommendations presented in this article belong to the author and are not necessarily shared by the editors of Pig Health Today or Zoetis.
Posted on August 7, 2019
