VFD: One Year Later

The VFD rule places responsibility on veterinarians to ensure producers use medicated feeds strictly according to their labels. ( John Maday )

After one year of practical experience with the new veterinary feed directive (VFD) rules from the FDA, we asked a group of veterinarians to outline key questions and concerns from producers and their expectations for future emphasis on antibiotic stewardship.

Our panel of veterinarians includes:

  • Scott Crain, DVM, VeriPrime, Kansas
  • Becky Funk, DVM MS, Nebraska
  • Tom Furman, DVM, Nebraska
  • John Maas, DVM, California
  • Glenn M. Rogers, DVM, MS, President-Elect AABP, Texas
  • David Sjeklocha, DVM, Cattle Empire, Kansas

Part 1 of this series focused on the most common questions, challenges or sources of confusion among producers.

This installment explores next steps, with veterinarians addressing the following question:

Looking ahead, what changes do you expect your clients will need to make in response to pressures for enhanced antibiotic stewardship?

Dr. Scott Crain: I am just now seeing a willingness in our client base to investigate alternative management tools such as MOS (a yeast product), beta glucans, etc. The very tools soundly rejected when presented two to three years ago.

Dr. Becky Funk: Antibiotic stewardship is certainly not a topic that is going away, and with good reason. As an industry we need to continue to emphasize our commitment to getting it right, otherwise we risk allowing individuals who are not familiar with the ins and outs of raising beef to increase their decision making power with regards to antibiotic usage regulations. I have had more than one client in the past year speculate that if we could just scrap the VFD process life would be good again. I am quick to inform them that we need to make this regulation work somehow, because the alternative is to have these products removed from our arsenal altogether. I feel that if we can't prove to our consuming public that we are willing to put in the effort, no matter how frustrating the process, we run the risk of losing these products and others entirely from our toolbox. As a veterinarian, this is the risk that scares me the most, to lose the ability to make the best decisions for the animals we care for based on science and individual situation. That is what our profession is based on, and I take that responsibility very seriously. My hope is that going forward, we can continue to impress on producers the need to work with their veterinarian to make the best decisions for their operation, because I see the days of being able to get antibiotics at the local feed and supply store without veterinary input as limited.

Dr. Tom Furman: Not just clients, but any person using antibiotics in the future needs to continue to educate themselves on the issues of resistance. They need to work with healthcare professionals to determine the proper times, reasons, and dosages for using the different antibiotics and their different administration routes. This includes injectables, orals, and feed additives.

We as a beef industry need to continue to move in the direction of disease prevention with good vaccination, nutrition, and husbandry practices. There is a large room for improvement in these areas.

Dr. John Maas: I feel most clients will work to comply with the VFD and develop a routine that works for them. Others will continue to “game the label” to keep their cattle supplied with the products that they feel are important.

On another track, I feel there is a huge potential fallacy in the FDA’s thinking. It seems they believe that lowering the use rate/amount/tonnage in livestock will directly translate into fewer problems with antimicrobial resistance. There is a tremendous need to track resistance versus the manner in which these relatively old antibiotics are used.  Does amount really matter or is it the manner/method of use—or will it matter at all given all the other potential causes of antimicrobial resistance? That is to say, will reduced tonnage of antimicrobial use in livestock make any difference given all the other variables in veterinary and human medicine antimicrobial use? I think the FDA is just taking a shotgun approach (with a “little political consideration”) to this real problem.

Glenn M. Rogers: Veterinarians will lead efforts to incorporate Antimicrobial Stewardship practices in client operations. Producers and their veterinarians should work together to seek alternative health management solutions to preserve the use and effectiveness of antimicrobials as valuable tools in a more comprehensive approach to disease management. Increased emphasis on pre-shipment health management, cattle flow and low-stress stockmanship will be necessary to make this transition a reality.

Cattle producers should consider working more closely with their veterinarian to develop a complete herd-health management plan that incorporates antimicrobial stewardship principles. Antimicrobials are a necessary tool to use appropriately when a failure occurs somewhere in the production system. Over-reliance on antimicrobials or incorporating them as a crutch for poor management should not be an acceptable option. Antimicrobial stewardship practices will be essential to preserve the availability of these precious products and ensure the production and economic vitality of modern cattle production systems.

An AABP Task Force on Antimicrobial Stewardship recently produced guidelines for veterinarians that are available on the AABP website at http://aabp.org/resources/AABP_Guidelines/AntimicrobialStewardship-7.27.17.pdf

Dr. Dave Sjeklocha: For the most part, I think we need to consider our basic animal-husbandry practices to decrease stress as much as possible. Utilize low-stress weaning techniques; low-stress cattle handling; provide clean, dry areas for the calves to rest during weaning; be aggressive with bedding; develop a good disease-prevention program in consultation with their veterinarian; limit commingling opportunities; etc. Simply asking ourselves, “What is the best thing we can do for the cattle?” can go a long way. I firmly believe that better cattle management will result in more prudent use of antibiotics.


VFD Do’s and Don’ts

Producers are learning the VFD process is more than just having a vet’s signature on a scrap of paper, says South Dakota State University Extension Veterinarian Russ Daly, DVM, MS. “Because there is no allowance for using feed-grade medications in an off-label manner, veterinarians completing the VFD’s have had to pay exquisite attention to every detail on the label, including the dose, duration of feeding, reasons (disease treatment vs. control) for feeding, and the diseases the medication could be used for.

Daly notes that for many cattle producers, the fall of 2017 was the first time they’ve encountered this new way of doing business. Weaning season on ranches and in feedlots brings health challenges, and some producers were accustomed to feeding chlortetracycline (CTC) in ways that, while well-intentioned, were off-label. Daly reminds veterinarians and producers of these points:

  • Refills: A VFD can’t provide for refills, like a prescription one might get from a family doctor. This means a producer can’t use the same VFD form to come back and get another quantity of medicine if it’s determined to be needed later on.
  • Expiration Dates: All VFD’s have expiration dates, and that’s a point of confusion as well. A VFD actually expires when the treatment is done (or the expiration date is reached – whatever comes first). Even though a VFD might not expire until February (authorizing a treatment any time until then), if a five-day treatment is finished in November, the VFD is finished too.
  • Repeat Treatments: A VFD can’t contain a statement authorizing a “retreatment as needed” or “repeat treatment in xx days.” An animal can’t show up on a VFD form more than once. If another round of treatment is necessary, a veterinarian will have to issue another VFD for the second treatment. That means that some groups of cattle might need two or three separate VFD’s written for them.
  • Animals Covered: A VFD can’t be written for more animals than the veterinarian expects you’ll have on the farm. The veterinarian is responsible for indicating the number and location of the animals to be treated. This might get a little tricky for producers who buy several groups of feeder calves over time. Veterinarians might decide to only write the VFD for what is currently on the farm, or they could write it for the number eventually expected, if they are confident that number will be eventually procured.
  • Pneumonia: A VFD can’t be written to treat or control pneumonia when there isn’t any pneumonia in the cattle. In the past, it was not uncommon for treatment doses of CTC to be fed to cattle to “get ahead of” an outbreak, or to “clean up” the calves’ respiratory tract in anticipation of problems. When treatment doses are authorized by a VFD, this implies that active pneumonia is present in the group. It doesn’t mean producers have to wait until each and every calf is sick – but clearly, CTC labels don’t allow for using treatment doses in a group of completely healthy calves. This is the veterinarian’s call. If their clinical judgement tells them there’s pneumonia present in the group, they can write the VFD.