Originally published in November/December 2016 issue of the OVMA Observer.
Beginning Jan. 1, 2017, the use of antibiotics administered through feed or water to food-producing animals will change considerably. Even if your practice is small animal focused, you may get requests and inquiries from small food producers who are proximate to your area and who do not have an established relationship with a veterinarian or from beekeepers (more on that later). In other words, it is a good idea for all veterinarians to have at least a basic working knowledge of Veterinary Feed Directives (VFDs) and the new prescription requirement for water-based antimicrobial medications.
To begin with, the VFD is a federal regulation of the Food and Drug Administration designed to promote the judicious use (treatment, prevention and control of disease, and no longer for simply feed efficiency and growth promotion) of antibiotics. Judicious use is advanced by requiring a veterinarian to write a VFD for any “medically important” (those antibiotics used in human medicine and deemed as medically important by FDA) antimicrobial medication administered via feed to food-producing animals that prior to 2017 had been available to producers over the counter.
A veterinary-client-patient relationship serves as the basis for interaction between veterinarians, their clients, and their patients. A veterinary-client-patient relationship exists when all of the following conditions have been met:
(A) A veterinarian assumes responsibility for making clinical judgments regarding the health of a patient and the need for medical treatment, medical services, or both for the patient, and the client has agreed to follow the veterinarian’s instructions regarding the patient.
(B) The veterinarian has sufficient knowledge of the patient to initiate at least a general or preliminary diagnosis of the medical condition of the patient. In order to demonstrate that the veterinarian has sufficient knowledge, the veterinarian shall have seen the patient recently and also shall be acquainted personally with the keeping and care of the patient either by examining the patient or by making medically appropriate and timely visits to the premises where the patient is kept.
(C) The veterinarian is readily available for a follow-up evaluation, or has arranged for emergency coverage, in the event the patient suffers adverse reactions to the treatment regimen or the treatment regimen fails.
Effective Date: 10–12–2006
A VFD is similar in nature to a prescription in that it requires the establishment of a valid veterinary-client-patient relationship (see right) to be written for a client by a veterinarian. A VFD is a written statement by a veterinarian licensed in the state where the animals are located authorizing a client to use animal feed containing a VFD drug or combination VFD drug. A copy of the VFD is provided to the feed mill and the client, and the veterinarian must also keep a copy in the form in which it was originally written (i.e., electronic or paper).
A VFD must contain specific information as outlined by FDA and convey the drug to be used in “grams per ton.” AVMA and AABP, among others, have created VFD templates, you can make your own, or you may use an electronic service such as GlobalVetLink or E-VFD. The VFD cannot be written for a period longer than six months.
Medically important water-based antibiotic medications are being moved to prescription status, and general prescriber rules, including labeling and the need for a VCPR with the client, will apply.
Beekeepers pulled under VFD requirements; DVM involvement now needed
The new Veterinary Feed Directive has a few surprising twists, one of which is that bees are also covered under the regulations. Antibiotics used to control bee diseases will now require a VFD from a veterinarian as well, and just like with the more commonly viewed food animals, a VCPR will be necessary. This presents veterinarians with a new opportunity to serve area beekepers.
OVMA has been in contact with the Ohio Beekeepers Association and individuals at the Ohio Department of Agriculture who oversee the apiary program to facilitate communications and understanding of the challenges this requirement will present. According to ODA, there are presently about 5,000 registered beekeepers in Ohio, of which about 70 percent have fewer than five hives.
OVMA is looking to identify and establish a list of veterinarians who either already have some experience with bees—perhaps as beekeepers themselves—or who are interested in serving this group of potential clients. If you wish to be added to this list, please e-mail ohiovma@ohiovma.org.