The National Pork Producers Council (NPPC) has submitted a letter to the Food and Drug Administration (FDA) raising a number of concerns about its proposed Veterinary Feed Directive (VFD).
NPPC says the draft text provided for comment addresses many difficulties identified with the current VFD. However, to make the transition of all feed antibiotics to VFD smoother, NPPC suggests that FDA consider the following:
1. Refills –The draft text states that the veterinarian issuing a VFD is responsible for listing the number of refills allowed during the time the VFD order is in effect. NPPC asks FDA to remove this requirement because it is likely to cause confusion among producers, veterinarians and feedmills. Many existing products that will require a VFD do not currently have refills listed on their labels. Unless the number of refills is also included with the change in marketing status for these products, it appears that a veterinarian would need to write a new VFD each time a product would be used. This creates a great deal of uncertainty.
2. Approximate number of animals – The draft text states that the veterinarian is responsible for approximating the number of animals to be treated on the VFD order. However, FDA does not provide a scientific rationale for requiring this information or how they would utilize this data. Additionally, FDA should clarify the responsibility of the feedmill to address any discrepancies between the amount of feed ordered and the amount of feed that might be estimated to be needed for the approximate number of animals listed on the form.
3. Expiration date– The draft text states that a VFD cannot be written for a period longer than six months. NPPC believes a six-month expiration period will disproportionately affect small producers and those located in remote areas.
4. Category I and II products– While not specifically addressed in the draft text, historically all products that are VFD have been Category II products, making acquisition of these products for on-farm feed production in non-commercial mills difficult. It would be helpful if FDA could clarify when current Category I products change to a VFD marketing status whether they will keep their Category I designation. If these products are not available for on-farm feed production, small producers who mix their own medicated feed will be negatively affected.
5. Floor stock– Many small producers buy either medicated pre-mix or medicated complete feed as floor stock from feedmills, distributors or retail establishments. The requirement for notification of FDA to distribute VFD products could discourage distribution and sale of floor stock. NPPC suggests that FDA seek input on the issue of product distribution, retail sales and floor stock during its listening sessions to help address the complexities of this situation.
6. Education efforts– The transition of all medically important antimicrobials in feed to VFD will require a concerted outreach to producers, veterinarians and feedmills. NPPC suggests that in addition to working with the veterinary organizations and the feed industry, FDA work with the producer groups to help reach producer audiences with this information.
7. Reporting– While the draft text does not indicate that FDA is considering VFDs to be reported, NPPC would ask that they not become reportable.
Click here to read the entire letter from NPPC.