Veterinary Feed Directive: Veterinarian FAQ

Q: What is a Veterinary Feed Directive (VFD)? Why do we need the VFD classification?

A: The VFD category of medicated feeds was created by the Animal Drug Availability Act of 1996 to provide an alternative to prescription status for certain therapeutic animal pharmaceuticals for use in feed. The FDA's Center for Veterinary Medicine (CVM) expressed a need for greater control over the use of certain new, therapeutic antimicrobial medications for feed. The purpose of the added professional control is to reduce the rate of development of resistance and thereby prolong the period of effectiveness of the medication. The participation of the veterinarian in the producer's decision to use such medicated feeds was essential to satisfy the FDA's concerns in this area. Currently labeled over-the-counter (OTC) medicated feeds will not be affected by the VFD. The VFD applies only to new drugs for therapeutic use in feed that are being approved by the FDA.

Q: Can veterinarians sell VFD medicated feeds?

A: Yes. Veterinarians may act as distributors of VFD feeds by notifying the FDA once, in writing, within 30 calendar days of the date of first distribution of the VFD medicated feed. Preprinted forms for this purpose may be available from the drug sponsors.

Q: Is a VFD a prescription for feed?

A: No. The VFD is an alternative to prescription classification for medicated feeds. A prescription status would lead to major disruptions of existing marketplace practices for drug sponsors, feed manufacturers and animal producers. Among other problems, the prescription status would have triggered state pharmacy laws and regulations that were intended to apply only to the dispensing of other dosage forms of drugs, not to medicated animal feed. Similarly, it would have triggered statutory limitations on labeling and marketing practices that would place covered drugs and feeds at a commercial disadvantage when comparedwith OTC medicated feeds. The VFD will only apply to those specific drugs that are newly approved as VFD medicated feeds. Extra-label use of medicated feeds including VFD drugs is prohibited.

Q: How long is a VFD valid?

A: The decision to issue a VFD and the length of time it will cover should be made by you, the veterinarian, based upon your knowledge and training and within the confines of a valid veterinarian-client-patient relationship (VCPR). However, use of the printed VFD form is required and may include a limit on the length of time for which it is valid.

Q: Can a veterinarian issue a VFD over the phone?

A: No. A VFD must be issued on a printed form. The veterinarian may FAX or E-mail the form to the producer and/or the feed supplier.

Q: Can a VFD be renewed?

A: A VFD may be renewed subject to limitations on the printed VFD form, if you allow for renewals. A new VFD form may be issued when the previous VFD expires, if conditions warrant continued use of the VFD medicated feed.

Q: How do I establish the valid VCPR required for issuing a VFD?

A: A veterinarian may only issue a VFD if a valid VCPR exists. A valid VCPR, as defined by the American Veterinary Medical Association (AVMA), exists when:

  1. The veterinarian has assumed the responsibility for making medical judgments regarding the health of the animal(s) and the need for medical treatment and the client (owner or caretaker) has agreed to follow the instructions of the veterinarian; and when
  2. There is sufficient knowledge of the animal(s) by the veterinarian to initiate at least a general or preliminary diagnosis of the medical condition of the animal(s). This means the veterinarian has recently seen and is personally acquainted with the keeping and care of the animal(s) by virtue of examination of the animal(s), and/or by medically appropriate and timely visits to the premises where the animal(s) are kept; and when
  3. The practicing veterinarian is readily available, or has arranged for emergency coverage, for follow up in case of adverse reactions or failure of the regimen of therapy.

Q: Do I have to examine the animals before issuing a VFD?

A: As long as a valid VCPR exists, each animal or group of animals addressed in a VFD does not have to be examined.

Q: Am I responsible for ensuring that proper mixing of a VFD medicated feed occurs on the farm?

A: The veterinarian is responsible for providing the producer with adequate instructions for mixing (i.e., dilution and concentration) and use of the VFD medicated feed. The veterinarian is not responsible for supervising the actual mixing of a VFD medicated feed.

Q: Do I assume liability when issuing a VFD?

A: The appropriate use of VFD medicated feeds requires the participation of a veterinarian who acts responsibly and prudently in issuing a VFD. Directing the use of any medication, including a VFD product, that can result in antibiotic tissue residues or otherwise have adverse effects in animals exposes the veterinarian to liability.