Last week I attended a talk on the new Veterinary Feed Directive (VFD). This continues to be a topic that “everyone is freaking out about” when I don’t think most need be. On hand to present were Amber Itle, a WSDA Field Veterinarian and Cat Marrier, a WSDA Feed Specialist. I was already pretty familiar with the law change, having read up on it when it was proposed in the Federal Register, and following it as it became law. But I did pick up a few tidbits of interesting info I didn’t know!
First off, it was pointed out that this law came from Congress, driven by public sentiment; as are many initiatives which the FDA and other agencies are directed to implement. I’m well aware of this, because when I worked in the medical device industry, it was common to influence FDA decisions impacting industry by hiring lobbyists to first influence congressmen. So, I felt a little bad for the WSDA staff there to present the details of the law, because some in the audience were getting agitated, and it was a “shoot the messenger” kind of situation. But, they handled it well and were very patient at answering questions and clearing up confusion.
They covered a bit of background of the why’s behind this law being implemented. The obvious main concern is antimicrobial resistance. That as we use antimicrobials, over time, microbes evolve to become resistant, and the drugs lose their effectiveness. This is a threat to the both human and animal populations, as drug inventors aren’t able to invent new antimicrobials fast enough to keep up. But, there are subtleties to this topic. Of course, the public gets all up-in-arms about the idea of anyone using antimicrobials anywhere in the food supply. And they confuse some of the details and facts here, since they’re just envisioning huge factory farms delivering antibiotics by the barrel-full all day every day to all animals.
Yes, it’s true that a large proportion of the antimicrobials manufactured are used on livestock. But that’s mainly because the word “antimicrobial” covers a lot of things, plus there are a lot of livestock in America, and livestock are big. A 1,000 lb cow likely needs a dose 8-10 times that of a human, just because of weight proportions. If there are 98 million cows in the US, and 319 million people, we can see why if similar percentages of cows and humans get sick and need antibiotics, the cows simply outweigh us and will use a higher volume of drugs. So, it’s not as shocking of a statistic at first blush that AG uses a lot of antibiotics, we simply have a lot of cows.
Secondly, most of the antimicrobials used in livestock are not drugs which are medically important in people. For example, ionophores, like Rumensin and Bovatec – things we use to treat coccidia, which is a protozoa. Only about 20% of of the antimicrobial resistance that impacts humans can be traced to animal use. So, 80% of the problem of drug-resistant “super bugs” in people comes from non-AG sources, namely from physicians over-prescribing antimicrobials, and people not taking their Rx’s in the prescribed manner (i.e. stopping the Rx too early, allowing drug-resistant flora to multiply). But we still know that AG is a contributor to this societal problem, even if one of the smaller contributors, so we must address it.
Thus, in comes the VFD. The current change is to address the concern over antibiotic resistance associated with daily use in animal feed fed to food animals. This is critical to tease apart, that we’re only talking about: a) antibiotics relevant to human use, b) that are put in animal feed or water, c) which is fed to food animals, and d) that is fed daily. What doesn’t count here are other drugs besides antibiotics, drugs which are administered through vehicles other than feed or water (i.e. injections, oral drenching), nor drugs used on non-food animals like horses or dogs.
The main thing that has been totally shut down is daily feeding of certain antimicrobials (the ones important to humans) to promote growth in food animals. That, you simply can’t do anymore, even if you have a vet saying he thinks it’s ok. And this makes sense: making one’s animals grow faster and be more profitable does not trump the public need to slow down the evolution of drug-resistant microbes.
So, what we can still do today is pick up a vial of Penicillin from the feed store and inject it, according to the label, for the therapeutic treatment of an infection in a cow, pig or sheep. Dr. Itle also pointed out a subtlety: it’s still ok to use that same Penicillin prophylactically on a trailer load of cattle you’re shipping to a buyer, knowing that the travel stress may trigger pneumonia in the animals. (Minding that withdrawal times per the label still apply, of course.) We can still use Corid in water for coccidia for cows (and for sheep extra-label with a veterinary prescription); because it’s not a drug which is medically important to humans. We can still use Rumensin and Bovatec in feed mixes. Yes, all of this is still ok, and your vet and paperwork don’t need to be involved, as long as you are following the label directives.
So where does the new VFD apply? When you want to use certain antimicrobials (the ones important to humans) in feed or water for prevention, control or treatment of disease. And, you still can. But you have to vet a vet to write down the VFD, and some subsequent paperwork shuffling ensues. The vet provides a copy to the producer and the feed distributor. The distributor forwards a copy to the FDA and also “acknowledgement” to the drug supplier. And everyone in this chain is subject to audit, so must keep careful records. VFDs are only good for six months, so they have to be renewed often.
The most common application is going to be large-scale confinement animal feed operations (CAFOs). These guys were using antimicrobials as growth promoters, and they still are going to use them for prevention and treatment. Because when you put a few thousand cattle together in a big pen, invariably some of them are going to come in with a bacterial or viral illness. And because they’re in close quarters, it’s gonna spread, and the animals are stressed, so you’ll have losses. So, antimicrobials need to be used in this case as both a preventive and a treatment (always, always with withdrawal times respected, so there should be no residual drugs in the meat product at the time of slaughter). 
But, large-scale CAFO people already know this, they already have veterinarians on staff and are also used to a lot of paperwork. So they’ll likely take this change in stride. What has people all-freaking-out is, how does this impact the small producer, who doesn’t have a vet on staff, or a vet at all? People in the audience were getting all hyped up, am I gonna have to get a vet and pay them for a farm call to write a VFD for my three chickens or my FFA bottle lamb or my sick cow? Because I don’t have a vet, or I can’t afford a vet, and oh, this is punishing the small producer and this is terrible… on and on.
The simple answer is, no. This probably does not impact you if you are a small producer. Because in general, for heaven’s sake, why do your homestead animals need important human antibiotics applied daily in their feed? Isn’t part of the point of being a small producer is to raise a more natural product, in a cleaner, non-stressful setting with lower threat of disease coming in, where you don’t need to use these amped-up drugs in feed on an all-flock or all-herd basis? Is your desire really to be a mini CAFO where you are dependent upon constant drugging in feed to keep your animals alive?
And even if you did need these particular antibiotics to control an outbreak and there was no other treatment choice, usually you wouldn’t deliver the meds in feed on a casual, long-term basis (after getting a VFD…). You’d do it via drench or injection, to get it in the bloodstream fast. And that application is still allowed. In general, my impression of the VFD is that by design, it’s intended to make some hurdles to getting access to human drugs for animal feed. It’s going to force you to assess “do I really need this?” and if so, force you to jump through some hoops to get it.
The two areas mentioned in the seminar where we’re likely to see changes at our local feed store are these: medicated chick feed and medicated milk replacer for food animals. These will no longer be on the shelves just ready to grab and go. Two places where people tended to use medicated feed “just cuz” (probably because they read in a book from 1960 that you should, or because a feed store self-proclaimed expert recommended it). Two places where there is probably no good reason for routinely using important human drugs in food animals.
For growing chicks, you have a couple of choices. You could instead purchased chicks vaccinated for coccidia (this works great for me). Or, you can just keep your chicken pen clean and free of mud, which is what tends to encourage coccidia outbreaks. I believe there are still some treatment options for acute cases that are non-VFD drugs;, especially for meat birds. But drug options for laying hens are (and always have been) extremely limited because of the unstudied effects on egg production.
For bottle baby lambs, kids, calves and piglets, you can start out not medicating, and try to use other methods for controlling scours: good colostrum access, probiotics in the feed and cleanliness in husbandry. If an individual does scour, then you can treat with oral drench or injectable antibiotics, as the label advises (or extra-label under veterinary oversight). 
If you are raising more than a dozen or two animals, and you do find you have a need to use a drug that’s under the VFD rule, then, yes, you’re going to need a vet to write you a VFD. But if you are in that middle-size scale of producer, likely you need to be working with a vet anyway, to have access to other important veterinary drugs which are (and have always been) only available via prescription. So now there is just some added paperwork. And, possibly more limited options for purchasing VFD-drug-laden feeds. I’ve heard of a few local feed mills and stores where they’ve decided the paperwork and audit-readiness burden is too much; so they don’t plan on carrying any medicated feeds anymore- even those not falling under the VFD!
Of course, there is handwriting on the wall: in the future, our access to medications will likely become even more limited. There may be a day when we can’t buy injectable Penicillin off the shelf at the feed store and we will have to buy it from a vet. But today is not that day. For now, I feel that the VFD is sensible, and of low impact to small-scale producers. We all really should be striving to find more ways to raise animals without the crutch of continual medication, which means using good genetics, good nutrition, and good husbandry.
The Collie Farm Blog 
July 11, 2016 at 8:00 am
Thanks for the info, Michelle. This is pretty much what I thought it was, and even a little better (thought the OTC penicillin at feed stores would no longer be available except with a vet prescription). I didn’t attend the meeting last week because I figured it would be a lot like you indicate here (hand wringing, “punishing the small producer” kind of upset) and didn’t have the stomach for that. Plus, what’s done is done. I don’t have the vet out every time something goes awry, but I do maintain a good relationship with mine, and I find LA vets to be very accommodating when you need advice and medication (vs. SA vets who just seem to say “bring him/her in”). If they’ve been to your place once, or seen your stock within the past year, they will work with you. And to me that’s not unreasonable. And I agree, moving away from the automatic, medicated feed approach to raising animals is a good thing for all of us.
July 12, 2016 at 1:01 am
The problem is a world wide one. We are importing our food from everywhere. The likelihood that increased regulation in the US will help is unsubstantiated. There is more to the story of antibiotic resistance that needs to be evaluated.
http://betsymccaughey.com/betsy-mccaughey-germs-multiply-while-cdc-fiddles/
July 12, 2016 at 3:55 am
mcfwriter, I feel the same way- livestock vets are usually pretty understanding. I make sure I pay mine to come out at least yearly to look at the flock. I type up my protocols, and have her review them. That way, we agree on the instances where I’ll use extra-label drugs, then she can sell me whole bottles of things so I have them on hand. I definitely would be constrained without such access. But we have limited access to vets here, and I appreciate that some people live in places with essentially zero access.
July 12, 2016 at 4:36 am
CAnderson, true, it’s a complex issue for sure. When I worked in medical device, we definitely felt frustrated at times by the slowness of FDA approval, and sometimes over-conservativeness. If we have a life-saving technology on the table, ready to take to market, every month or year of delay while reconnoitering the application is many potential live-saving events deferred. I appreciate their abundance of caution, but sometimes, it’s an over-abundance; or a lack of funding and staffing. So, who’s to say that part of the reason we don’t have more rapid development of new antibiotics is over-regulation?
As far as all the contributing factors for “super bugs” I think we have to try to attack all the big hitters. Even some that are still somewhat theoretical- better to move forward with a theory than wait for 100% concrete proof, while the problem gets worse. We can always measure the effects of our various attempts to see which ones are most successful. The affects of any approach are layered. I could imagine that countries with more lax feeding regulations may be able to beat us on price for meat imports, so we may have to introduce taxes or embargoes to level the playing field there.
And, regulation aside, I think most American consumers prefer meat produced without high dependency on antibiotics, and are making demands that are pushing the industry in that direction, anyway. We can’t change overnight, because obviously some segments of the industry are very dependent upon the antimicrobial approach. But, I think if we raise the bar in increments, the industry will adjust. I thought this article was interesting from a while back, how the company cited that it took a long time to develop new systems that allowed them to break their antibiotic dependency, it wasn’t a change they were able to implement rapidly.
http://www.npr.org/sections/thesalt/2014/09/03/345315380/perdue-says-its-hatching-chicks-are-off-antibiotics
July 12, 2016 at 7:45 pm
The introduction of more regulation by the ruling class almost always makes ranching and farming less profitable. Using medications is costly and self limiting in itself, so I have trouble believing that we are overusing them. When will the ruling class trust us and understand that we have a stake in our future that most likely is as far reaching as they believe theirs to be? As a tree farmer, I am planting trees that I will never harvest, but that is what farmers and ranchers do. We have a legacy that isn’t discussed in history books, but we take it seriously as it is part of who we are.
July 13, 2016 at 4:19 am
CAnderson,though I generally agree as the logic applies to small family farmers, I don’t think that large-scale CAFOs (or any large corporations) will “do the right thing” without regulatory intervention. I think they are mostly what this law is aimed at. I suppose one way they could have eased the potential impact to small farmers vs large was institute a rule that if you’re using below a certain volume of VFD feeds, then you are exempt. But still, I have a hunch most family farms are not using VFD feeds in ways impacted by the law: it is really more of a large-scale CAFO practice.
Indeed, medications are expensive; and for most of us small-scale people, becoming too dependent on them would erode our margins past the point of sustainability. But, for very large scale operations, their death toll is much higher than anything we would see; forced by conditions of high stocking rate, inability to closely monitor animals at the individual level and treat at early disease onset, and lower cleanliness standards that we’re able to maintain at a smaller scale. So, for them, the cost equation for daily medicating is different; and then, they are operating at such high volumes, the price-per-unit goes down. CAFOs are well-known for using medications as growth promoters, beyond just disease prevention; so clearly they have already proven the cost model pans out at their level.
July 13, 2016 at 1:56 pm
Thank you for attending and typing this all up! I have not had the time to really research all that is going into the VFD bill (life gets in the way sometimes), and I was under the impression it would be more restrictive as well, IE: the bottle of Pen at feed store, or having a bottle of LA 200 on hand, etc.
We are a mid scale farm and ranch, and do use limited feed that will fall under the VFD, mostly the kids’ show cattle. But we have a very good relationship with our vet, so I am not concerned about that or our management practices.
July 14, 2016 at 6:26 am
Jessica, you’re welcome, I hope it was helpful, and that I captured everything right that they talked about. I imagine it depends on where one lives and how large-scale the feed stores and feed mills are. One friend of mine mentioned the feed mill where she buys lamb creep, where she used to have them add coccidiastat, a whole year ago, they announced they were going to stop doing that. Even tho coccidiastat is not a VFD med. But they just said, they’re getting out of the biz of any additives, so they don’t have to hassle with record-keeping or audits. I thought this was interesting, indeed; because this could impact a lot of smaller-scale producers, if a lot of local feed mills took this tact! So perhaps this will be an unintended side effect of the change?
July 14, 2016 at 5:27 pm
In tree farming, whatever reduces profit reduces number of farms, reduces operating mills, truckers, nurseries growing seedlings etc. We have to ship our trees much further because they are “too large” for local mills. Follow the bouncing ball folks! We already have a problem with luring vets for livestock in some areas that are rural and distant. If there are less producers because there is less profitability in the industry we may be looking at a new advertising campaign of ” LAMB the forgotten meat” and that isn’t anything to LOL about! I guess we can keep them as pretty lawn mowers. If it is assumed that “super bugs” are being created by using antibiotics, maybe we need to understand the science of antibiotics better.
July 15, 2016 at 6:05 am
But, I think we have to get back to what this rule is about: daily feeding of certain antibiotics to livestock. I’m just not convinced this is a best practice. I think it’s a crutch that compensates for poor husbandry and overstocking conditions. If you have good husbandry, and retain the ability to treat acute illness in individuals, why do you need to dump meds in feeds day in, day out, for the whole herd? And if you really do, I don’t object to the idea that you should work with a vet. Maybe the vet can recommend better practices to reduce the dependency on long-term, daily medicating… 🙂 Probably a good investment in useful advice that improves profitability; and in the meantime, you are supporting a local small business person, your neighborhood vet!
July 15, 2016 at 2:50 pm
Respectfully, animals will be lost because meds aren’t available in a timely manner. There will be animals that will be sidelined because a small rancher will not want to call in the vet after hours for one or two sick lambs when they might have had a chance with OTC Penicillin. Catching and restraining animals in large flocks is dangerous to animals and their handlers and medicating feed is less stressful to the animal. There are many reasons associated with choosing to medicate your flock or herd. To tie the hands of livestock ranchers by assuming that they can’t figure out what “best practices” means is somewhat alarming. What else are they doing that we need to monitor?
July 15, 2016 at 5:37 pm
http://www.foxnews.com/story/2001/01/27/where-beef-on-farm-antibiotics.html
I know, I know, another comment to add, but farmers and ranchers really are not the culprit in antibiotic resistance. We need profit making companies like Eli Lilly to continue to work on new antibiotics to help. We want to partnership with “Big Pharma” and learn as much as we can about it. We need to partnership with big livestock people too.
July 15, 2016 at 11:39 pm
The topic of treating for acute illness was discussed at length in the presentation. What stood out for me is this logic: if you diagnose an animal as having a raging infection, you’re not going to drive to the feed store and pick up a bag of Show Lamb with Tetracycline to treat that animal. For one, it’s too hard to ensure proper dosage via feed for acute infection, you need precise dosage. And two, an animal with a raging infection is probably not eating, so a pre-mix feed won’t help in this instance. Plus, oral administration is a slow way to get meds into the body tissues; so not appropriate for acute cases.
Instead, you are going to use injectable antibiotics, probably IM or IV, to get meds into the bloodstream fast. Hopefully you have those antibiotics in inventory, so there is no delay driving to the feed store or the vet, and waiting for operating hours. Dr. Itle really emphasized, the types of medicated feeds that are on the VFD list are not designed for treatment of acute illness. They are designed for prevention and sub-clinical/low-grade illness.
But then this kind of gets back to husbandry: if you are dependent on continual feeding of these meds as a crutch, what will happen is you’ll get genetic drift towards weaker animals over time. To breed for maintained or increased genetic robustness, you need to be able to identify which animals tend to struggle with disease vs which animals don’t, so you can cull the ones with poor immune systems. You can’t differentiate them if they are all constantly medicated.
July 16, 2016 at 3:30 am
CAnderson- thanks for the link. The talk I went to actually corroborated this, for the most part; that there are alarmists who over-estimate the AG use of medically important antibiotics, the amount of microbes that pass between animals and humans, and AG’s contribution to the problem of antimicrobial resistance. The general public gets things confused, and people who have an agenda may twist facts to support their position.
And yet, I think it’s not good terminology to say we are not “the” problem- because most problems, including this one, usually have multiple contributors. So, AG is not the only problem, or even the main problem, but we still are part of the problem. Anyone who uses antibiotics is part of the problem. We know antimicrobial resistance happens, and it happens the more drugs are used, and used incorrectly. That is pretty basic and a proven fact. So, the more we can reduce the use of antimicrobials, and reduce their incorrect use, in all applications, the more we can slow down the progress of resistant microbe development.
As far as drug development goes, I think that is actually one of the main factors in the increasing alarm on this subject. Despite antibiotics being a very lucrative business, manufacturers have not been able to develop new ones in a long time. The last new class of antibiotics for gram-negative bacteria was developed 40 years ago!! Since then, some drugs have been tweaked to improve them, but no new ones have been discovered/developed. So, that is the big concern, is that science cannot seem to keep up with this problem, despite significant financial incentive to do so. So we have to preserve the effectiveness of the drugs we have as long as possible.
July 16, 2016 at 3:11 pm
The livestock producers that are hit the hardest by regulations like this are dairy farmers. If you can show with real science that the VFD will stop “super bugs” from mutating then no one in their right mind would be against it. There is no science that shows that this will do anything and only conjecture that it will. When in the history of our nation did we roll over for a mere agency of the government to start making laws when their job is to enforce the laws congress makes through legislation?
http://www.greeleytribune.com/news/20358154-113/veterinary-feed-directive-will-impact-whole-livestock-industry
July 16, 2016 at 10:47 pm
Last message on VFD. This morning I noticed my a few of my 30 Guinea Fowl Chicks were going downhill. Saturday morning and I am not running to the vet for an after hours call. The up side is that I had the restricted VFD Sulfamethazine Sodium that I needed posited away for a “just in case” situation. They will recover with some extra care. Now there are those who would say a few less Guinea Fowl in the world is a good thing, but I use them for my parasite control program. I guess I will have to turn myself in for rebelling against a program that is based on Junk Science. Oh, by the way, you might want to search JunkScience.com for information on “Long-Dreaded Superbug Found in Human and Animal in U.S.”
August 2, 2016 at 8:00 pm
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