With the federal government’s Veterinary Feed Directive (VFD) rule set to take effect January 1, 2017, one question that we’ve heard from AVMA members is how veterinarians should advise clients who expect to have extra supplies of over-the-counter antibiotics and medicated feed that will require veterinary oversight to use in 2017.
In most instances, with the exception of antibiotics that have been used only for growth promotion and feed efficiency, there’s good news. Those supplies don’t need to be thrown away, but instead will need a VFD (for medicated feed and milk replacer) or a prescription (for drugs administered through drinking water) issued by a veterinarian within a valid Veterinarian-Client-Patient Relationship before the products can be used or continue to be used.
The new VFD rule will regulate how medically important antibiotics — medications that are important for treating human disease — can be administered to animals in feed and drinking water. Among its provisions, it will require veterinary oversight whenever those antibiotics are given to any food animal species via feed or water (even if the animals are not intended for food production). It also will ban the use of these antibiotics for production purposes (growth promotion and feed efficiency).
The AVMA has comprehensive information to help veterinarians understand the VFD rule, including a fillable VFD form for use by AVMA members. You also can view lists of all antibiotics that are transitioning from over-the-counter (OTC) to veterinary oversight on the FDA’s website:
- Antibiotics transitioning from OTC to VFD (for medicated feed and milk replacer)
- Antibiotics transitioning from OTC to prescription (for drugs administered through drinking water)
How to prevent waste while complying with the VFD rule
What should your clients do if they expect to have over-the-counter supplies of these medically important antibiotics still on hand on January 1? They should talk with you about their animals’ needs and see if a VFD order or prescription is appropriate. If so, you can issue the VFD or prescription, and the use of the antibiotics can continue. In fact, the FDA indicates that it’s acceptable for a veterinarian to issue a VFD order prior to the start of 2017, for use beginning in 2017, as long as the necessary conditions for writing the VFD are met:
- The veterinarian needs to know the conditions of use and other information that will appear on the labeling for that product beginning in 2017. This is to ensure that the veterinarian can correctly fill out the VFD form. Representative labels for specific products, called “blue bird labels,” will be made available on the FDA’s website, according to the FDA.
- The course of treatment authorized by the VFD is able to be completed before the VFD’s expiration date or June 30, 2017, whichever comes first. The expiration date is expected to be up to six months for drugs that are transitioning from OTC to VFD; the date is counted from the date of issuance (when the veterinarian authorizes the VFD), not the date when the drugs transition to VFD status.
- The veterinarian has a Veterinarian-Client-Patient Relationship (VCPR) that meets the requirements in the VFD regulation.
Educate yourself and your clients about the VFD rule
With the weeks counting down to the Jan. 1, 2017, implementation of the new rule, it’s important for all veterinarians to understand the Veterinary Feed Directive, when a VFD order is needed, and how to issue one. It’s also important to educate your clients with food animal species – whether the animals are kept as pets or as livestock. The VFD rule applies to all designated food animal species, regardless whether they are family pets or production animals.
Here are steps you can take to prepare for the new VFD rule to take effect.
- Familiarize yourself thoroughly with the new rule as it applies to both pets and livestock. If you’re an AVMA member, you have full access to all of our VFD resources, including the fillable VFD form.
- If you’re issuing a VFD in 2016 with an end date that spans into 2017, be sure it satisfies the new rule. The AVMA’s VFD resources can help you write VFD orders that comply with the rule, and the FDA has additional guidance on its website.
- Talk with your clients who have food animal species – whether kept as pets or as livestock – to ensure they’re aware of the coming changes. During your conversations, you can make arrangements to issue any needed VFDs or prescriptions for the transition to the new year.
If you have questions or concerns about veterinary liability in connection with the new VFD rule, AVMA PLIT recently released a VFD risk assessment alert to provide you with guidance on the topic.