WHAT DO NEW FEED DIRECTIVES MEAN FOR PRODUCERS?

by: Stephen B. Blezinger
PhD, PAS


As most livestock producers are aware, the use of antibiotics in the feeding and production of food animals has been under constant scrutiny for several years. One predominant reason is the belief by some doctors, scientists and regulators that the feeding of “medically important antibiotics” or antimicrobial products has and does create a resistance in certain microbial organisms to antibiotic treatment when an infection develops in humans. In other words, the perception by some is that because certain antibiotics are used (and abused) by the livestock feeding industry, this has led to antibiotic resistant strains of certain organisms that can create sickness in humans. Additional arguments include observations that more consumers now insist on knowing what is in their food and how it is produced.

From either or both positions, the resulting activity by the government and regulatory bodies will affect those who grow and produce the food by increasing these challenges that will most certainly require more paperwork and regulations for many producers. In other words, this is one more hurdle to profitable production.

There are some problems with this reasoning. First, as with so many other scientific issues that have social and political implication there is not a clear picture of this problem. Extensive research has come out on both sides of the issue of whether or not various bacteria can develop the resistance indicated. Secondly, there is not a clear tie to the use of various antibiotics in food animal production for therapeutic or production enhancement purposes and the perceived development of antibiotic resistant bacteria.

Additionally, there is seldom much mention in the media of the potential problems created by the U.S. population in general with the misuse of the literal tons of antibiotics prescribed daily by doctors across the country on a daily basis. Again a great deal of research has been generated on the effect this situation has but you can't regulate how a person takes the antibiotics he or she has been prescribed. This may be a much greater and more widespread problem than anything created by the food animal industry. But focusing on this issue and how to deal with it is not as popular by regulators, politicians and groups that might find it necessary to find yet another reason to demonize the animal production industry.

So once again, our government choses to take steps to further regulate agriculture in a misguided attempt to “make the world a safer place.”

As you can tell, I'm not a fan.

Two Sides to Every Issue

There are two viewpoints which are most apparent concerning the application of the Veterinary Feed Directive. Let's discuss the “pro” side first.

For those that are in favor of more regulation and in this case “veterinary oversight” of antibiotic use in food animals, articles are generated almost daily with titles such as “Veterinary Feed Directive Assurance of Safe Product Benefits Entire Industry.”

Such is the case with the Veterinary Feed Directive (VFD), which is being directed by the Food and Drug Administration. Effective in December 2016, the use of medically important antibiotics in feed will require a VFD and use of such antibiotics in water will require a vet's prescription.

Some veterinarians believe this is the right move and have long desired the type of oversight that will now become common. Many believe the implementation of the VFD is the correct direction which takes a controlled view of regulating how antibiotics are used and yet maintains a focus on the care and well-being of the animal. This is as opposed to a dramatic reduction or all out elimination of fed antibiotics to which other groups would favor. So this provides for an evolution of antibiotic use as opposed to a sudden change that could have disastrous economic and animal welfare effects.

Other positive positions assert that this methodology assures a safe, wholesome food product for the public and this benefits the entire industry. The belief is that by complying with the new regulations, the industry is helping to assure the consumer that antibiotics are being used judiciously and that their food is now “safer.”

Currently the VFD applies to “medically important antibiotics” which are termed as those important to human health. Under the new regulations a licensed veterinarian must write the VFD for producers. The VFD may be applicable for up to six months and then be rewritten. Subsequently vets, feed suppliers and producers must keep a copy of each VFD for two years.

Some Specifics:

1) A VFD is similar to a prescription. Once a veterinarian writes it, the VFD is active and must be kept on file. Manufacturers of veterinary pharmaceuticals are required to report overall sales of all products to FDA every year. This also includes antibiotics that are not considered medically important to human health.

2) The VFD must include:

•Location - where the animals are located.

•Indication for use - what disease is being treated.

•The antibiotic or antimicrobial being prescribed.

3) Currently there is no requirement on the VFD to list the amount or volume of antibiotic used.

4) Veterinary Feed Directives will cover all food-producing animals. This includes cattle, swine and poultry and other minor species for which the products are approved. For cattle producers, the new regulations will pertain to all segments of the beef industry, including cow/calf operations, calf growers, replacement heifers, developing bulls, stocker or backgrounders and feedyards.

5) VFDs can be written for more than one location if the veterinarian deems it is appropriate. That might apply if the cattle are managed similarly, have similar disease issues or are of similar origin.

6) As mentioned antibiotics covered under the VFD are all medically important feed-grade antibiotics. A VFD does not apply to injectable antibiotics which currently already require a Rx.

The new regulations also aren't designed to chart individual animals that may have been given antibiotics. The purpose of the VFD is to document judicious use of feed-grade antibiotics, not individual animal tracking.

The broad implications of the regulations essentially put veterinarians in charge of all medically important antibiotics that are used in the feed of food animals. As the regulations are currently written they do not apply to certain products. The only antibiotic currently used for growth promotion or, more specifically, for improvement of feed efficiency in cattle on a large scale is the group called the ionophores (Rumensin®, Bovatec®, Cattlyst®). They're not included in the medically important group since they are not routinely used for the treatment of a medical issue. No hypothesis has been made that they could contribute to antibiotic resistance in humans. As such ionophores do not currently require a VFD. However if, for example, Rumensin® is combined with a medically important antibiotic, it will then require a VFD for use in combination with that antibiotic.

As with any regulation, particularly new ones, a degree of agency oversight can be expected. At this time the FDA hasn't announced how inspections or enforcements will be handled. The regulations continue to be developed and implemented (and potentially expand).

Obviously these regulations will have far reaching affects. A feed mill that does a lot of custom manufacturing of feed products will need to keep a record for all feed containing VFD or medically important antibiotics. Even FFA and 4-H show animals and backyard producers will not be immune and will need VFDs under the same rules as those that apply to large producers.

On the Flip Side

Many producers and groups are not particularly excited with the coming change.

One of the most prominent beef producers group, The Texas and Southwestern Cattle Raisers Association (TSCRA), believes this is another example of the federal government expanding their authority and attempting to regulate ranchers out of business. Their contention is that the Feds are accomplishing this by requiring producers to obtain the VFD from a licensed veterinarian before they can acquire and use antimicrobial drugs in feed or water.

As described, a vet must fill out the VFD form specifying the ranch, group of animals to be treated, drug to be used, feeding rate and the duration of the treatment for the cattle. The TSCRA's position is that this additional regulation will have little or no effect on antibiotic resistance or food safety and the only net result will be the additional time required and increased costs (vets aren't going to do this for free) for producers who are now subject to these regulations.

Furthermore, an unrealistic amount of detailed form filing and record keeping is necessary with said records retained for a minimum of two years by the veterinarian, rancher and feed mill or distributor (extreme redundancy). As with so much regulation within agriculture and other industries this amount of paperwork is unnecessary and arduous just to receive a drug ranchers have used appropriately for years to care for their cattle.

The new regulations are not only proving arduous to producers. The new VFD rules also require vets to follow state defined vet-client-patient relationships (VCPR). In states where the FDA determines no applicable or appropriate state VCPR requirements exist, veterinarians are required to issue VFDs in compliance with federally defined VCPR requirements. While states like Texas and Oklahoma already have state VCPR requirements in place, the FDA is overlooking the fact that ranchers already have good working relationships with their local veterinarians.

The VFD rule is part of FDA's strategy to promote the “judicious” use of antimicrobials in food-producing animals. This is to imply that current use or application has been ‘non-judicious” and at the whim of the producer. As mentioned earlier the Obama Administration believes antibiotics are causing resistance in humans who consume beef products but have continuously failed to back this claim with proper peer-reviewed sound science.

The American rancher has proved time and time again to be admirable stewards of their cattle, and have continuously provided a safe, healthy and abundant supply of beef for the U. S. and the world. They have done this by being educated and experienced in sound production practices and by working with veterinarians, nutritionists and other experts to use antibiotics judiciously in the treatment of sick cattle and maintaining healthy herds.

They're Coming

Unless something changes, the livestock production industry can only assume that the new VFD regulations are soon to be the law of the land. In other words, this will prove to be another layer of regulation that, for the most part, will only create more hurdles to efficient production. At this point the important thing that producers can do is to begin preparing for the implementation of the VFD, is to examine their current production program and start a conversation with their veterinarian and nutritionist regarding whether they currently use these products, and plan how they will continue to use them when the VFD is effective. Or they may determine if viable alternatives exist that can be used to accomplish the same results but avoiding the additional red tape (non-antibiotic solutions).

Until full implementation is in effect, the cattleman should monitor this situation closely to determine how it will affect their operation.

Copyright 2015 – Dr. Stephen B. Blezinger. Dr. Steve Blezinger is a management and nutritional consultant with an office in Sulphur Springs, TX. He can be reached at sblez@verizon.net or at (903) 352-3475. For more information please visit us on at www.facebook.com/reveillelivestock.







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