MFA Director of Animal Health Dr. Tony Martin has spent plenty of time on the road recently to answer questions about the upcoming implementation of the Veterinary Feed Directive. Here we highlight some of the top questions Dr. Martin took at producer meetings. The rule takes effect Jan. 1, 2017.
1. What will the cost of the VFD be to the producer?
Any cost or fee for the VFD will be at the discretion of the vet who creates it. I have heard fees discussed ranging from nothing to over $100. The bottom line is producers should expect some fee for the service, but consider it a consultation fee, not a cost required to buy the document. The real value of the VFD service comes from discussion between the vet and producer about the need for antibiotics, which ones to use, and how to use them. These conversations will likely broach other topics about how producers might decrease or eliminate the need for antibiotic use. There could be room for improved vaccine protocols, environment, livestock handling, nutrition, genetics, etc.
2. How specific must information on the location of the animals be for the VFD?
This question has been open to some interpretation. Some believe it has to be an official Premise ID. The commonly accepted answer from the FDA is that you need to provide the physical address where treated animals are located. This will most often simply be the owner or manager’s address.
3. Do I need a separate VFD for each separate group of animals for the same claim?
In other words, will I need a separate VFD for cows grouped in different pastures for anaplasmosis control? Similarly, would I need separate VFDs for multiple groups of incoming, commingled calves to receive standard pneumonia control protocol? My interpretation is that a single VFD would fulfill the needs for these examples. You would need to make sure that when you provide information for the VFD that you are giving an accurate approximation of the total number of animals. In the examples above, that would be the total numbers of cows in multiple pastures for anaplasmosis control or the total number of incoming calves to receive pneumonia control.
4. Can one VFD be used to purchase appropriate product from more than one distributor?
The feedback I have received from the FDA indicates that this would be allowed—if the merchant locations are all under the same ownership and control (i.e., one company). I would add that the supplier needs to be within a reasonable distance of where the product will be administered per the VFD. In other words, if you have a VFD for animals on a northwest Missouri farm and file the VFD at a nearby MFA Agri Services, you probably ought not to use the same VFD for a farm you own in southeast Missouri where livestock is under someone else’s care. This might not be the case with an integrated production system, but I question if the same veterinarian-client-patient-relationship (VCPR) can apply to such broadly separated animals under private ownership.
5. If a producer is caring for animals owned by one or more absentee owners, does the caretaker/producer obtain the VFD or does each owner have responsibility for the VFD?
In this example, the caretaker/producer is caring for and treating the animals described on the VFD. The answer from the FDA is that the VFD should list the caretaker/producer because that is the party most likely to have the VCPR with the vet writing the VFD.
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