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). Meds

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.

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