Feed duration biggest issue under new swine VFD rule
More than a year into FDA’s new veterinary feed directive (VFD) rules, pork producers and veterinarians are finding the potential problem spots.
“Where producers may be at risk in an FDA audit is with the duration of feeding an antibiotic,” reported Chris Rademacher, DVM, Iowa State University Extension. “The other potential problem spot is making sure all the paperwork is filed.”
Potential audit issues
The issue expected to draw the most attention from FDA inspectors is how long the antibiotic is fed and whether that is consistent with the label. “Pay closest attention to the duration of feeding,” Rademacher stated. “Early indications are this must be fairly close, within 1 to 2 days of the labeled duration of feeding. But this will be somewhat auditor-dependent on how close it must be fed according to labeled directions.
“FDA has indicated they are in an education mode for the first year but reserves the right to enact enforcement on producers who are blatantly violating the law,” he added.
The other priority issue is paperwork. “FDA inspectors will make sure all the information on the VFDs is kept correctly,” Rademacher said. “If I’m feeding a medically important [antibiotic], I would document the date started and the date finished. Then during an inspection, I can go back and reconcile all the information.”
Veterinarians should consider doing more diagnostics on farm sites, Rademacher added. “Over time, inspectors will get more pressure, and veterinarians may need to do a good job to provide evidence of why feeding an antibiotic is needed.”
Monitoring correct amount of feed
Rademacher has had some questions from producers about VFDs including who’s responsible for monitoring the appropriate amount of feed issued under a VFD.
“It is a shared responsibility with the feed distributor and the client,” he said. “The quantity of feed being used should be in proportion to the number of animals listed on the VFD. However, feed distributors are familiar with FDA audits. They will call you if things don’t match up.”
Another question he hears is if one VFD can cover a medication that’s fed 7 days in a pelleted feed from one distributor and then another 7 days in bulk-bin feed from a different distributor.
“The veterinarian can write it under one VFD but should indicate in special instructions about how the medication will be fed,” Rademacher suggested. “The inspector can read the instructions and tie it all back together.”
More antibiotic regulation ahead
Expect more antibiotic regulations in the future, Rademacher stated. California and Maryland have passed laws against the routine use of antibiotics for disease prevention. A similar law is under consideration in Oregon.
Future regulations may be another reason for more diagnostics. “Some swine veterinarians traditionally don’t do diagnostics, but maybe they should start,” he said. “The more documentation you have, the better you are proving the case for antibiotics.”
For more information about VFDs, visit pork.org/production-topics/antibiotics-resource-center/.