The Veterinary Feed Directive (VFD), which kicks in January 1, 2017, regulates the use of medically important antibiotics in the feed and drinking water of U.S. livestock. While some practitioners wonder how their world will change under the new federal rules, the answers depend on who does the talking. Experts say the switch shouldn’t hit food-animal veterinarians very hard as long as they pay attention to the details. The U.S. Food and Drug Administration will require veterinary oversight whenever medically important antibiotics are administered to food animals via feed or water. Why? Antimicrobials used to improve the efficiency of livestock feed or to fatten animals can raise the risk of antibiotic resistance in people and animals. More Responsibilities To be sure, antibiotics may still be used in feed or water for medical purposes, but a veterinarian will be involved in the decision-making. “For most vets working with food animals, the changes in drug status—OTC to VFD or Rx—for medically important antimicrobials will require at least one additional step of writing and issuing a Veterinary Feed Directive or prescription,” said Christine Hoang, DVM, MPH, CPH, assistant director of the Division of Animal and Public Health at the American Veterinary Medical Association. “Others may already have electronic systems in place that can accommodate the changes and be relatively unaffected,” Dr. Hoang added. “For some veterinarians, it could provide an opportunity to learn more about a different area of veterinary medicine and work with a new species.” Atop the must-know list conveyed by Harry Snelson, DVM, director of communications at the American Association of Swine Veterinarians, is the requirement of a valid veterinary-client-patient relationship before the veterinarian can legally issue the VFD. “This ensures that the veterinarian is familiar with the client’s animals and their health status and that the producer agrees to comply with the veterinary instructions,” Dr. Snelson said. This, of course, also will require more time spent prescribing drugs. “All of this means more work on the part of the veterinarian regarding oversight, record-keeping and compliance with the regulation,” Snelson said. “It may well necessitate the need for additional veterinarians to meet producer needs.” What Vets Should Know Veterinarians should become educated not just about what’s changing but also about what’s staying the same. That’s the advice of Roger Saltman, DVM, group director of cattle and equine technical services at drug maker Zoetis Inc. To help inform their clients and the rest of the veterinary industry, Dr. Saltman and Zoetis have been busy reaching out to answer questions, of which there have been many. “We’ve been very actively dispensing information about the VFD to veterinarians and members of the agriculture community,” Saltman said. Zoetis staff has hosted webinars, distributed materials and given presentations at national and local veterinarian meetings, he said. “We’ve participated in over 360, to date, local meetings with livestock customers,” he added. While apprehension may be growing among some veterinarians, the VFD process isn’t as alien as it may sound. “What I’ve found is they see how similar it is to writing a prescription for an injectable medication,” Saltman said. Among the initial steps to writing a VFD is figuring out the class of animal, where the animal will be located and the duration the medication will be given. On the latter subject, it’s important to be mindful that a VFD is good for up to six months. Beyond that, a second VFD must be written, Saltman said. The process also requires copies of the VFD for the veterinarian, the producer and the veterinary feed manufacturer. Fortunately, electronic forms are available. Copies of VFDs must be kept on file for two years. Snelson sees all this new recordkeeping as a possible hurdle. “Proper recordkeeping may also be a challenge depending on how the practice maintains its records,” Snelson said. “There are electronic third-party systems that can, for a fee, facilitate the VFD/prescription process and may be worth exploring, particularly for vets unfamiliar with what information is needed to issue a valid VFD.” M. Gatz Riddell, Jr., DVM, MS, Dipl. ACT, sees an upside to the new forms. Dr. Riddell, executive vice president of the American Association of Bovine Practitioners, believes that the forms will improve veterinarian-client lines of communication. “There’s going to be some additional paperwork, but this also may generate some additional conversation between producers and veterinarians,” Riddell said. “Now’s a really good time to have a conversation so everybody knows what products have been used and what products may be needed to be used in the future.” Along those lines, getting good drug histories will be even more important going forward. “Veterinarians should make sure they discuss with their clients what products the clients have been using the last couple of years,” Riddell said. Challenges The new VFD rules require some time and patience to learn, but they warrant a thorough read. A few changes can land a practitioner in trouble if he sticks to the old way of doing things. This is why Saltman offered a cautionary warning: Pay close attention to labels. “Veterinarians need to be aware of the new label indications,” the Zoetis group director said. “One of things that is very important about the Veterinary Feed Directive compared to writing a prescription is that the VFD can only be written for an indication specifically included on the medication’s label.” For emphasis he added: “It actually will be illegal for a veterinarian to write a VFD for any other use than what is specified on the label for any of these feed medications.” Snelson advised veterinarians to reach out to clients before Jan. 1 to ensure they are aware that antibiotics previously accessed over the counter may be available only via VFD or prescription going forward. “Clients should also contact their drug distributors to ensure that they plan to continue to market medicated feed products and water-soluble products that the client customarily uses,” Snelson said. “Some distributors may decide to no longer stock- pile some items.” AVMA’s Hoang directed practitioners with questions to the association’s “Veterinary Feed Directive Basics” web page: http://bit.ly/2eUBf5x. Swine Vets Up to Speed Snelson thinks some veterinarians may be quicker to adapt to the changes. “Speaking for swine veterinarians, I think our members are well-prepared for the changes,” he said. “We are fortunate in that all of the VFD products to date have been approved for swine, so veterinarians that have worked with swine have experience with the VFD process. Vets working with other species may be less familiar with the process. “The transition of water medications to prescription will be a significant change for everyone involved, although most vets will be familiar with the prescription requirements within their state,” he added. This will be easier for some than others, Saltman said. “The knowledge of the use of medicated feed additives is variable by veterinarians, so some veterinarians are well versed in the use of feed-based medications and others have not used them very much,” Saltman said. ABC’s from AVMA Here are some thoughts from the American Veterinary Medical Association on the new Veterinary Feed Directive (VFD) rules. 1. Antibiotics must be used responsibly. The increasing threat of antibiotic resistance to both human and animal health compelled the FDA to take action by removing production uses of medically important antibiotics and implementing greater veterinary oversight by transitioning OTC antibiotics to VFD or prescription status. Any antibiotic use can contribute to antibiotic resistance, so it is important to avoid unnecessary or inappropriate uses of antibiotics. 2. The VFD protects animals and people. Under the direction of a veterinarian, the responsible and appropriate ad- ministration of antibiotics reduces the opportunity for resistance to develop and helps preserve the supply of effective antibiotics for situations of true need to protect animal and human health. 3. Antibiotics will still be available. Animals will still receive antibiotics when there is a clear indication of their need. Food producers will be able to work with veterinarians to ensure that animals have the care and medication they need, when they need it. FDA Q&A The U.S. Food and Drug Administration website helps explain the new Veterinary Feed Directive (VFD) rules. Additional information is available at the FDA website. What does the VFD rule do exactly? The VFD final rule provides veterinarians with consistent standards for authorizing the use of [drugs] in feed when they are needed for specific animal health purposes. The rule also updates recordkeeping requirements and takes advantage of electronic tools to make the VFD process more efficient and flexible. How will the FDA hold veterinarians accountable for ensuring that medically important antimicrobials are used judiciously? The VFD final rule requires veterinarians issuing orders authorizing the use of medically important antimicrobials in animal feed to do so within the context of a veterinarian-client-patient-relationship (VCPR) and specifies the key elements that define a VCPR. Among these key elements is the expectation that veterinarians have sufficient knowledge of the animals for which they are authorizing the use of a VFD drug. Most states have a set of VCPR requirements and, under the VFD final rule, veterinarians will be required to follow appropriate state requirements. In states where the FDA determines that no applicable and appropriate state VCPR requirements exist, veterinarians must follow federal VCPR requirements. What could happen if a veterinarian does not comply? A veterinarian’s license is at stake if they don’t uphold the codes of practice. The FDA will work with states to ensure that veterinarians appropriately authorize the use of medically important antimicrobials and will also work with states to take appropriate action if violations do occur. If a veterinarian authorizes the use of an antimicrobial covered by this rule without complying with applicable state licensing and practice requirements, including VCPR requirements, the state may take enforcement action and the FDA may deter- mine the resulting animal food to be adulterated or misbranded. Similarly, if the federally defined valid VCPR standard is applicable and the veterinarian fails to comply, the FDA may act to enforce compliance. “Veterinarians can start by familiarizing themselves with the basic information on our site, including recognizing which animals are classified as food-producing animals—such as pigmy goats, potbelly pigs and pet chickens—and why these regulations are so import- ant,” Hoang said. Originally published in the December 2016 issue of Veterinary Practice News. Did you enjoy this article? Then subscribe today!
