Livestock Management RANCHING Veterinary Feed Directive:
Expiration vs. Duration of Use By Kristin Lewis Hawkins
B
EGINNING IN 2017, THE PURCHASE AND USE OF ANY DRUG intended for use in animal feed will require the
authorization of a veterinarian for treatment of a spe- cifi c disease or illness as required by the drug’s label. A veterinary feed directive, or VFD, is a writ ten
statement issued by a licensed veterinarian that au- thorizes the use of a VFD drug or combination VFD drug, in or on an animal feed. This statement or order authorizes the owner of the animal or other caretaker to obtain and use animal feed bearing or containing a VFD drug or combination VFD drug to treat the cli- ent’s animal(s), only in accordance with the conditions for use approved, conditionally approved, or indexed by the FDA. The rule will require veterinarians to issue all VFDs
within the context of a veterinarian-client-patient re- lationship (VCPR), including the requirement that the veterinarian engage the client or animal caretaker to assume responsibility for making clinical judgments about patient (animal) health, have suffi cient knowl- edge of the animal by conducting examinations and/or visits to the facility where the animal is managed, and provide for any necessary follow-up evaluation or care. The FDA hopes that by requiring a veterinarian’s
supervision, their professional oversight will ensure the judicious use of medically important antimicrobials in food animals. As part of this new framework, it will also be illegal to use these drugs to promote animal growth or for use in production purposes.
Expiration date The expiration date on the VFD specifi es the last
day that the VFD-ordered feed or product can be fed or dispensed. VFD-ordered products cannot be fed to ani- mals after the expiration date on the VFD. Once a VFD is written, the client is authorized by the veterinarian to purchase that product or feed and complete treatment within that time frame. In some cases, the FDA determines the expiration
date of a VFD as part of the approval, conditional ap- proval or listing of that drug. If a date is not specifi ed, the expiration may not exceed 6 months after the date of issuance. The veterinarian will use his or her own
60 The Cattleman April 2016
medical judgment to determine the appropriate expira- tion of the VFD based on the client’s individual situation, facility, reason for use and treatment history. Therefore, an expiration date may be less than 6 months, depend- ing on the product and use. It is unlawful to feed the VFD feed to animals after the VFD expiration date.
Duration of use The VFD expiration date defi nes the length of time
for which the authorization to feed an animal the feed containing a VFD drug is lawful. This length of time may be specifi ed in the approved labeling of a given VFD drug or, if not specifi ed in the labeling, the veterinarian must specify an expiration date for the VFD that does not exceed 6 months. The duration of use is a separate concept from the
expiration date, and determines the length of time, es- tablished as part of the approval, conditional approval, or index listing process, that the animal feed containing the VFD drug is authorized for use. For example, a drug’s label may list a 14-day duration
of use with a 45-day VFD expiration. Once the VFD is issued, the client must obtain the VFD feed or product and complete the entire label-determined course of therapy — 14 days as determined by the drug manu- facturer — before the VFD expires, which would be 45 days from the date of the VFD issuance. Since it is unlawful to use the VFD feeds after the
specifi ed expiration date, if a client has not completed the full course of treatment as determined by the product’s manufacturer before the VFD expiration, the veterinarian must be contacted to request a new VFD order.
How long do I keep records? Producers must keep a copy of each VFD for a mini-
mum of 2 years. For more information on VFD rules and product use,
visit the FDA’s website at
fda.gov and search “VFD” or contact your veterinarian. If you don’t have a veterinar- ian, now is the perfect time to reach out and develop a relationship with one. A little preparation now will go a long way later, especially when the clock is ticking.
thecattlemanmagazine.com
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