Location, location, location: How FDA defines ‘premises’
When issuing a veterinary feed directive, swine veterinarians are expected to provide the physical location of pigs receiving feed with VFD medication.
That sounds like a simple request, but what if there isn’t a street address for a remote farm or the address of a facility isn’t specific enough to determine the animals’ exact location?
FDA says veterinarians can use their discretion to provide a better description, such as the site, pen or barn.1
Veterinarians, however, should be sure to ask producers if pigs will remain in the same place until the VFD expiration date. If there’s a chance they’ll be moved — such as moving weaned pigs from the nursery to a grow-out facility — it’s acceptable to include multiple but specific locations on the VFD.
One caveat: When a VFD is intended for multiple locations, the medicated feed must be supplied by a single manufacturer or distributor, FDA says.
1. #120 Guidance for Industry Small Entity Compliance Guide Veterinary Feed Directive Regulation Questions and Answers. FDA. http://www.fda.gov/downloads/AnimalVeterinary/GuidanceComplianceEnforcement/GuidanceforIndustry/UCM052660.pdf Accessed December 15, 2015.