Pork producers will need more than VFD forms to pass an FDA audit
Complying with the new veterinary feed directive (VFD) requires pork producers to do more than establish a veterinary-client-patient relationship and retain printed or digital versions of the VFD forms for a minimum of 2 years.
For example, did you know that producers who mix their own VFD feeds should retain samples for future audits?
That was one of many questions posed by Liz Wagstrom, DVM, chief veterinarian for National Pork Producers Council (NPPC), at a recent webinar, “How to Succeed with the New Antibiotics Regulations,” hosted by NPPC in cooperation with National Hog Farmer.
Wagstrom cautioned swine producers that several additional items should be retained to pass a Food and Drug Administration (FDA) VFD audit.
“FDA audits for VFDs will start with the feed distributors and trace the VFD back to veterinarians and producers,” she said. In addition to VFD forms, producers who mix their own feed should be prepared to provide the following in an FDA inspection:
- All feed tags and labels
- Mixing records
- Number of animals receiving the medication and when it was withdrawn
- Correspondence with the veterinarian, including call summaries, test results, autopsies
- Feed samples from VFD orders
- Close-out records for each group of pigs, with mixing and feed labels attached
She noted that privately owned mills selling feed or ingredients to other farms or owners are classified as distributors and, as such, must file a distributor notification letter with the FDA. They, too, need to maintain similar records and samples.
Wagstrom noted that early VFD pilot audits will be based on educating distributors, producers and veterinarians on proper documentation and procedures around the VFD process. However, in the future, failures to meet VFD requirements could result in fines or, in extreme situations, jail time.
Other questions for producers that could come up in a VFD audit:
- Did you feed VFD feed to the authorized number of animals on the VFD order?
- Did you feed the VFD feed for the identified duration on the VFD order?
- Did you follow the withdrawal period for the VFD ingredient?
- Did you follow special instructions or caution statements?
- Did you feed a combination VFD feed in a manner consistent with the statement on the VFD order?
- Do you have labels for VFD feeds? If yes:
- Does the feed label include the VFD caution statement?
- Did the medication level on the label match the product label on the VFD form?
- Is the medication level and indication on the VFD form consistent with the approval?
Having supportive documentation will a go a long way to answering these questions, she said.
To view the entire webinar, click here.
Posted on April 3, 2017