One of my city friends from several states away felt the need to call me and tell me about the raw milk she was buying. I asked why, and she proudly announced because she wanted her milk free of drugs. Guess what? If you purchase milk in the grocery store, I can assure you it already is free of drugs. Furthermore, dairy producers take great pride in selling milk free of drug residue, plus there are multiple layers of testing to assure that milk sold to consumers is free of any antibiotics or other residues.
Every time the issue of drugs and animals comes up, I cannot help but think my spoiled suburban friends envision my cows lounging in an opium den instead of the freshly sand bedded, well-ventilated drive-through barn. The topic of superbugs caused by antibiotic resistance in human medicine has been given much press lately. Some worry that antibiotically-treated animal feed that is used as preventative and growth promotion is contributing to the problem. Many experts do not agree that animals are the source of superbugs, which typically originate in human hospitals, but due to consumer perception, the FDA implemented the Veterinary Feed Directive, effective Jan. 1 of this year. These new regulations are the typical approach when it comes to concerns about agricultural practices — another round of Simon Says and more paper and the problem is solved, at least in the minds of many.
As of Jan. 1, 2017, any medicine that goes into animals’ water, food or minerals (injected medicines do not change) must comply with the new Veterinary Feed Directive (VFD). A VFD is required if a farmer needs to add an antibiotic that is used by both humans and animals to the feed, water or mineral supplement of his herd. The VFD acts as a permission slip, not a prescription for judicious use limited to treatment, prevention and disease control. There is no authorized use of antibiotics for growth promotion and feed efficiency. Types of medicine affected include penicillins, cephalosporins, quinolones, fluoroquinolones, tetracyclines, macrolides, sulfas, glycopeptides and others.
The producer must indicate the approximate number of animals to be given the medication. My advice is to estimate high. Common sense tells me if it has hydraulics or hair, it can fail you.
The veterinarian will forward the VFD to feed distributors by email or fax. Producers will also receive a copy. All three parties must keep copies of the VFD for two years, although the VFD is only valid for a maximum of six months. There are no refills.
Even if a farmer obtained medicated feed or other VFD antibiotics before Jan. 1, 2017, he will need a VFD to legally use it after Jan. 1, 2017.
Veterinary Client-Patient Relationship forms must be signed yearly and kept on file at the farm and the veterinary clinic. This form is signed by the veterinarian familiar with your facility and the people working on the farm. Vets must be licensed in the state where the animals are being fed.
Perhaps the most important part of the new regulations is the veterinary-client-patient relationship. A farmer needs to have a relationship with his vet. The vet needs to know where you live, who you are, what animals you own, and they need to have a medical record documenting all of this.
Both the federal and state government will monitor compliance with VFD rules through FDA and the state department of agriculture. When checking, an inspector will first stop at the distributor to select VFD Forms that they will trace back to the producer and vet clinic. A producer will need to show VFD, Veterinary Client-Patient Relationship Forms (VCPR) and a document verifying when antibiotics are fed, withdrawal times, and labels from VFD Feeds.
While computerized filing is encouraged, I suggest maintaining hard copies in a dedicated VFD file. My favorite law professor deemed this the “belt and suspenders approach.”
The good part about this new regulation is that it encourages a relationship that anyone with an animal enterprise already has, counsel from a veterinarian. I usually hang around and try to assist when the vets are called to our farm. The occasional left displaced abomasum (LDA) surgery reminds me of their skill. They operate on a cow that is awake and standing in the parlor or barn, a less than sterile environment. They are subject to the weather, which can be excessively hot or miserably cold. They perform major invasive surgery without a surgical team or any of the drama or superbugs associated with human medicine. And usually their patient lives to milk another day.