Do pork producers need a VFD for each on-farm feed mill?
Part 7 in a series
In an exclusive 90-minute interview with editors from the VFD News Center, William Flynn, DVM, MS, deputy director for science and policy for FDA’s Center for Veterinary Medicine, clarified some hazy points of the new veterinary feed directive (VFD) regulations that took effect January 1, 2017. In this installment, Flynn discusses the obligations pork producers have for on-farm feed mills.
Q: Many pork operations have on-farm feed mills and manufacture feed for their pigs only. The complexes are all at one site. Do these on-farm mills need any special paperwork to obtain premixes containing the VFD medications?
WF: Basically, to obtain a VFD premix (Type B medicated feed) or a finished Type C feed, you either need to have a VFD from a licensed veterinarian or you need to provide an acknowledgment letter to the supplier indicating that you will not feed it to your pigs without a VFD.
You do not need a VFD or an acknowledgement letter to obtain a Type A medicated article containing a VFD drug. However, regardless of whether obtained as a Type A article, or as a Type B or C feed, a VFD is required in order to administer medicated feed containing a VFD drug to your animals.
Q: So, if there’s an individual owner of this feed mill, and he’s going to manufacture feed that he’s going to send to his farms on another site, possibly in another state, will the producer need a distribution letter?
WF: No. If you’re manufacturing medicated feed solely for the purpose of moving it from point A to point B, where you own the animals, you’re not selling it or “distributing” it to another person, so therefore you are not considered a distributor.
In those situations, a single VFD authorization could cover that, provided that the various locations/premises to which the feed is going are listed on the actual VFD order.
The only exception occurs when there’s a large operation that has more than one feed-manufacturing site supplying feed to the various locations/premises. You need to have a separate VFD for each manufacturing site.
Q: In summary, if there’s one feed mill producing VFD feed going to various sites but still owned by that company, only one VFD is required. But if it’s the same company with two feed mills, they would require two VFDs.
WF: Yes. As long as you can identify the locations where the feed is going, that’s fine. You can cover it all under one authorization, as long as it’s tied to one manufacturing site. If at any time you’re planning to sell some of that medicated feed, now you are a distributor and you would need a distributor letter.