Knock, knock: Swine veterinarian shares experiences from VFD audit
When Peter Schneider, DVM, heard FDA auditors were at the door to see the operation’s veterinary feed directives (VFDs), he remembers feeling a little nervous.
“It made me surprised because you don’t know what to expect, but we couldn’t deny the FDA from doing this,” Schneider, a swine veterinarian at Schneider & Schneider Pork Farms, Waterloo, Iowa, told Pig Health Today.
The auditors were randomly checking VFDs at the operation’s feed mill, which sits on the same site as the sow farm. The mill produces feed for contract growers, making it a distributor of medicated feed and subject to audits. Schneider believes this is why his mill was selected for the VFD audit.
One minor glitch
“Actually, the audit itself was pretty easy once I got over the shock of having the FDA show up,” Schneider added. “They looked at the VFDs I’d issued, the feed records, and made sure everything was in line.”
The auditors used an inspection form with boxes to check to make sure everything was covered. After filling out the form, the auditors gave Schneider feedback.
“We’d used the right amount of medication in the feed, and all the VFDs were filled out properly,” he said.
But the auditors asked for information Schneider hadn’t been keeping. Schneider uses VFD forms they developed at the farm. Investigators said wording to describe duration of medicated feed use was too ambiguous and left the exact duration up to the producer. He intends to make changes on the forms to include the additional information the auditors wanted.
“In a regulatory audit, these errors would likely result in minor citations,” he added. But at the time of this audit, FDA was still in an “educate before regulate” approach, which is expected to extend at least through 2018.
“The whole audit lasted about half an hour once it started,” Schneider reported. “But we’re in a different situation because the feed mill, the producer and the veterinarian are really all the same entity.”
That kept the audit short and simple. “I produced one copy of the VFDs to suffice for all three aspects of the audit process and shared copies of my feed records from the farm mill,” he explained.
Advice for audits
Schneider offered some advice to others facing an audit. “Stay calm and cool during the process and it will go easier,” he said. “And really, I think most people are going to be sitting pretty good as long as they’ve done a good job storing their VFDs and having appropriate contact with their veterinarian or feed mill.”
Looking ahead, Schneider said he thinks it’s important that veterinarians document their rationale for making a specific recommendation, whether it’s a laboratory or clinical diagnosis.
“Since the audit, I’ve been more aware that I need to have justification for what I’m doing so we continue to have these antibiotics that are pretty important to health,” he said.
He did ask the FDA inspector about common mistakes identified in other VFD audits. The most common mistakes by mills and veterinarians were incorrect addresses assigned to production sites. For producers, the most common error was a lack of VFD records.
But overall, compliance has been good, according to the inspector. Schneider thinks this will help FDA stay positive about the current steps taken by feed mills, producers and veterinarians to ensure compliance with the VFD rules by the swine industry.
Posted on January 2, 2019