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.