The 123s of VFDs
Effective January 1, 2017, stricter federal rules regulate how medically important antibiotics—medications that are important for treating human disease—can be administered to animals in feed and drinking water. Among the provisions, the U.S. Food and Drug Administration requires veterinary oversight whenever such antibiotics are administered to any food animal species via feed or water, even if the animals are not intended for food production. From pet rabbits and pigs, to backyard poultry, to large livestock farms, the same restrictions apply. All medically important antibiotics to be used in feed or water for food animal species require a Veterinary Feed Directive (VFD) or a prescription.
1) Antibiotics must be used responsibly
The driving force for the initial VFD rule in 1996 and the recent revisions was improving drug availability for the benefit of animal health and welfare, and, in turn, food safety. The increasing threat of antibiotic resistance (antimicrobial resistance) to both human and animal health compelled the FDA to take action by removing production uses of medically important antibiotics and implementing greater veterinary oversight by transitioning over-the-counter (OTC) antibiotics to VFD or prescription status. Any antibiotic use can contribute to antibiotic resistance, so it is important to avoid unnecessary or inappropriate uses of antibiotics. The use of medically important antibiotics in livestock is one factor that can contribute to increasing resistance, and the 2017 VFD revisions (published in June 2015) aim to put responsibility for their use into the hands of veterinarians, who are trained to understand not only when these medications are needed, but also what is the appropriate drug, dose, duration, and administration method to resolve infection and protect animal health and our food supply. The expertise of the veterinarian is critical to ensuring the responsible use of antibiotics in animals.
2) The VFD protects animals and people
The FDA and drug manufacturers agreed to remove production uses (i.e., growth promotion, feed efficiency) for antibiotics that are medically important, and to require veterinary oversight for use of these antibiotics in feed (requires a VFD) or water (requires a prescription). Under the direction of a veterinarian, the responsible and appropriate administration of antibiotics reduces the opportunity for resistance to develop, and helps preserve our supply of effective antibiotics for situations of true need to protect animal and human health. While the change may be challenging, the end result will be more responsible antibiotic use that will benefit human and animal health.
3) Antibiotics will still be available
Veterinarians are committed to ensuring that animal health and welfare needs are met, and that needed medications be available and administered in a timely manner for treating, controlling, or preventing animal disease. Animals will still receive antibiotics when there is a clear indication of their need. Food producers are able to work with veterinarians to ensure that animals have the care and medication they need, when they need it.
AVMA's Role in developing the VFD rules
What was the AVMA's role in developing the VFD rules? The AVMA has worked with regulatory agencies (FDA, USDA, CDC) and other stakeholders such as producer groups to promote responsible use of antibiotics, while ensuring that animal health needs are met and potential burdens are minimized.
We were involved from the beginning, providing input to the FDA regarding veterinarians’ needs and roles in judicious antimicrobial use. Our volunteer leaders and staff provided the FDA with comments and suggestions for improving the VFD process. Our discussions with the FDA began by exploring how veterinarians could gain additional oversight of antimicrobials, and subsequently agreeing upon Veterinary Feed Directives as a vehicle. Although we recognized the challenges of a transition from over-the-counter (OTC) to VFD, we welcomed the opportunity to help shape the regulations.
The expert AVMA members who served on the AVMA Steering Committee for FDA Policy on Veterinary Oversight of Antimicrobials provided initial thoughts on how to improve the VFD process, and the FDA incorporated many of those concepts in the 2012 draft VFD and the 2017 final rule. AVMA's interactions with the FDA were guided by two overarching policies: The Role of the Veterinarian in Animal Antimicrobial Use and Veterinary Foresight and Expertise in Antimicrobial Discussions.
AVMA’s input influenced:
- Inclusion of a requirement that a proper Veterinarian-Client-Patient Relationship (VCPR) exist when a VFD is issued
- Adherence to licensing and practice requirements
- Changing the requirement from amount of feed to approximate number of animals (as feed consumption can be extremely variable and difficult to predict)
- An option for more specific identification of animals at the veterinarian's discretion (to restrict uses as needed)
- Clarification on record-keeping and formatting. For example, AVMA suggested the "written (non-verbal)" VFD and retaining VFDs electronically (as opposed to paper copies and triplicate forms)
Even with the new rule finalized, there may be remaining questions and areas of confusion. We are committed to being a resource of information and educating our members, and we invite feedback regarding tools or materials that would be helpful to this process.