On Jan. 1, the U.S. Food and Drug Administration (FDA) made changes to how antibiotics are used in livestock feed. One change regarded moving human medically important feed-grade antibiotics to the veterinary feed directive (VFD) drug process.
Additionally, many human medically important water-soluble antibiotics were moved to prescription use. These certain drugs (which were available previously over-the-counter) now require the oversight of a veterinarian.
Since the change went into effect, the Michigan Department of Agriculture and Rural Development (MDARD) has been receiving calls from producers, distributors and veterinarians. In order to clarify some of the specifics of these changes, we’ve worked to collect some of our most common questions:
- Can a distributor sell an entire bag of medicated feed containing a VFD drug to a producer when they only need a portion (example: distributor has a 50-pound bag and the producer only needs 25 pounds)?
Yes, the distributor/manufacturer can sell a 50-pound bag to the producer as long as the producer understands they can only feed the amount as ordered by the veterinarian in the VFD order. In order to feed the remaining amount, the producer must get another VFD order from their veterinarian. Additionally, if a portion of a bag is sold to a producer, a copy of the complete label must be affixed to the feed bag that the producer is purchasing.
- Can producers “top dress” a medicated feed?
Yes, as long as the label allows for this type of feeding. Different manufacturers and drugs may possess different FDA approved allowances for how the drug is administered to the animal. Veterinarians should check the approved FDA “Blue Bird Label” before determining how it can be used. Blue Bird Labels for each species are found on the FDA’s website.
- Do producers need a VFD order for a medicated milk replacer containing a VFD drug?
Yes, producers using a milk replacer already containing a VFD drug must obtain a VFD order from their veterinarian in order to use the product. If the producer wants to add a VFD drug to a liquid milk replacer or water, the producer must obtain a prescription from their veterinarian to mix that product into liquid.
- Are refills allowed?
No, but it should be noted that “refill” is often confused with “reorder.” VFD orders can be written by veterinarians for up to six months. Producers can reorder the feed as they get in new groups of animals. For example, every month, a new group of finisher hogs may come in, needing the same type of medication due to a common disease seen at that stage of production. This is a reorder, not a refill. A refill would mean that the same drug is going to the same animal or group of animals.
- Scenario: A veterinarian writes a VFD order for aureomycin in feed for 28 days. Two days after the 28 days have expired, the respiratory issue returns. Can the veterinarian write a VFD order for that same animal or group of animals?
Yes, this is allowable only if the veterinarian writes a new VFD order for that same animal or group of animals. It is the veterinarian’s responsibility to ensure they are issuing the VFD order for the correct purpose. The producer must also ensure they are using the VFD drug according to the written order.
- Scenario: A veterinarian writes a VFD order and makes two copies. The veterinarian retains the original for his/her own records and gives one copy to the producer and the other to the distributor. The producer then takes the VFD order to the place who is most cost- effective and convenient. What stops the producer from going to several places with the VFD order and getting more than one order filled?
Once the order is presented and filled by one distributor, it would be illegal to take the order to another distributor or mill and have the order filled. The FDA requires that the producer, distributor and veterinarian keep their respective copies on record for two years.
- How can beekeepers access medication for their hives?
Bees—like goats, sheep and deer—are considered minor species. The FDA has specific guidance for medication use with these species. There are approved drugs, including VFD drugs for certain minor species and purposes (such as treatment for foulbrood). For use of VFD drugs or medication for purposes other than what has been approved, you must have a veterinarian and an established veterinarian-client-patient relationship. The veterinarian’s primary role is to advise and guide the producer in determining which medications are appropriate for their animals whose health is being threatened by disease.
- What is the most common issue with currently issued VFD orders?
Some feed distributors are receiving VFD orders with incomplete information. Many veterinarians are using a commercial VFD order form that provides all the information required by the rule, but not enough information for the feed mill to complete the sale to the producer. The feed mill frequently has to call the veterinarian to get additional information.
Common incomplete information would be the animal weight and the preferred concentration for the drug [example: chlortetracycline (CTC) can be supplied in a variety of concentrations, such as 4 grams vs. 10 grams]. Under the VFD rule, the species of the animal and production class is required; however, this may not be enough information because directions are being given in milligrams per pound (body weight). Without the weight of the animals, it's impossible to fill the VFD accurately. Some of the commercial VFD forms are expecting animal weights to be recorded in the comments section, which is not obvious to a new user. If veterinarians need a VFD order template, MDARD has provided one on their VFD website.
- Is there a list of veterinarians in Michigan who are willing to write VFD orders?
MDARD has been working to create a database of veterinarians willing to write VFD orders. The list can be found on MDARD’s VFD webpage; however, the list is in progress and may change frequently.
- Where can I find a list of Michigan VFD distributors?
FDA updates the list monthly on their website.
Resources and more information on the VFD can be found at www.michigan.gov/vfd. Veterinarians who would like to be added to the list of practitioners willing to write VFD orders, and anyone with specific questions, can contact the Department at 800-292-3939. The website is being updated continuously, as MDARD strives to provide the best information possible to Michigan’s producers.