In late March, FDA released its draft Guidance for Industry 120, which aims to address questions that emerged since implementation of the current Veterinary Feed Directive rules in 2017. This week, Global VetLink (GVL) hosted a webinar for veterinarians featuring members of its Expert Council, reviewing some key updates from the draft guidance.
- Tyler Holck, DVM, an independent swine veterinary consultant and owner of Feed His People, LLC, who also serves as leader for the GVL Expert Council.
- Michael Apley, DVM, PhD, Professor of Production Medicine / Clinical Pharmacology in the Department of Veterinary Clinical Sciences at Kansas State University.
- Matt Frederking, Vice President of Regulatory Affairs and Quality at Mid America Pet Food.
- Christopher Rademacher, DVM, Senior Clinician and the ISU Swine Extension Veterinarian in the Veterinary Diagnostic and Production Animal Medicine (VDPAM) department at the Iowa State University College of Veterinary Medicine.
Part 1 of this series summarized several of the questions and answers the panel discussed. This follow-up article addresses questions not covered in Part 1.
Q: Can I assign an extended withdrawal to a VFD medication even though the producer will be using the VFD feed as labeled?
A: Yes, but the withdrawal time listed on the label must be included on the VFD. If the client’s protocols indicate a longer withdrawal time, such as for export or specialty markets, the veterinarian can include that information in the special instructions.
Q: Our veterinary clinic has multiple veterinarians. Can any of our veterinarians write a VFD for any of our clients?
A: Yes, as long as the federal requirement for a valid veterinarian-client-patient relationship (VCPR) is met. In states with their own VCPR specifications, veterinarians should verify the state VCPR requirements before issuing a VFD.
Q: Can I work with a feed distributor, nutritionist, or other animal health professionals in order to write a VFD?
A: Yes, the system works best when stakeholders work together for compliance, to achieve antibiotic stewardship goals and protect animal health. The veterinarian, however, is ultimately responsible for compliance with VFD regulations.
Q: Do I need to have a laboratory confirmation of disease prior to writing a VFD?
A: No, the VFD regulations do not require laboratory diagnoses. The FDA has given veterinarians discretion to make decisions regarding VFD drugs based on their clinical and diagnostic evidence, along with a valid VCPR.
Q: My client has requested a new VFD to replace the former VFD that will soon expire. Can I fill out the new VFD ahead of time and date it to begin when the previous VFD expires?
A: The veterinarian can issue a new VFD to continue treatments after an existing VFD expires. However, the date the veterinarian signs the VFD is the effective date, and any extended treatment must comply with specifications on the product label.
Q: If a veterinarian makes a mistake on a VFD and wants to go back and make corrections to the VFD rather than fill out a new VFD, can the veterinarian do that?
A: If the VFD has been signed and issued, either in paper or electronic form, the veterinarian needs to cancel that VFD and issue a new version, and notify the client and feed distributor. The FeedLINK system simplifies this process with a “void” option that automatically notifies all parties while enabling the veterinarian to issue the new VFD.
Q: If ownership of a group of animals changes during the course of a VFD treatment, does the veterinarian need to issue a new VFD?
A: If the animals remain under the care of the same caretakers, such as feeder cattle changing ownership while in the feedlot, the existing VFD remains valid. If the cattle move to a new caretaker, the veterinarian must file a new VFD and meet the requirements for a valid VCPR.
Q: If the rations for a group of cattle will change during the course of the VFD treatment, and the client will obtain those rations from different feed distributors, is a separate VFD required for each treatment period?
A: A single VFD can cover those changes in rations and in distributors. The veterinarian should note those changes in the special instructions on the VFD form.
For more about the VFD rules and compliance, see these articles on BovineVetOnline: