The Impact of VFDS on Swine Production
FEED MILL PERSPECTIVE
Veterinary Feed Directives (VFDs) will fundamentally shift and change how food is produced and will impact every level of production including feed mills, producers and the veterinarians that serve them. There are and will continue to be unknown costs associated with VFDs. Also, feed mills will more than likely be required to police the system.
In 1996 the Animal Drug Availability Act was passed by Congress. This rule set out a pathway for veterinarians to approve and signoff on antibiotics that are fed to livestock animals around the country. To date three swine drug are VFDs: Pulmotil® was approved in 1996, Florfenicol was approved in 2005 and Avilamycin was approved in 2015. In 2012 the Federal Drug Administration (FDA) began to rewrite the VFD regulations. During that rewrite, all medically important antimicrobial drugs used in food-producing animals will require VFDs beginning in January 2017. Common animal drugs not impacted are wormers, ionophores, bacitracin methylene disalicylate (BMD), bambermycin, carbadox, and tiamulin.
POSITIONED FOR CHANGED
The swine industry has a great starting point due to the fact that Pulmotil®, which is widely used in the industry, is currently classified as a VFD. Producers that use that drug are already aware of the relationship that needs to exist between them and their veterinarian to generate a VFD and then transfer it to the feed mill. An additional advantage for the swine industry is that a vast majority of producers already have a veterinary/ client relationship due to group housing because of the integrated systems that we have in today’s production environment.
That being said, currently swine producers only have a few drugs designated as a VFD that a veterinarian needs to sign off on in order to utilize it in their systems. Also, today’s producers have an array of antibiotics that can be implemented for the prevention and treatment of disease that do not need veterinarian intervention. After January 2017 the entire prevention thought process with these drugs will be reduced and everything will revolve around treatment.
MILLS ARE THE WHEELHOUSE
There are many steps that must be completed for VFDs to be implemented effectively. An original copy of the VFD is kept by the veterinarian. The veterinarian will then provide a copy to the producer or directly to the feed mill depending on the veterinarian. Once the feed mill receives the VFD from the veterinarian or producer they must crosscheck and verify that the VFD has been filled out correctly and that it is accurate. If any of those parameters are not met the VFD is null and void and the mill should not fill the order.
From a regulatory perspective, veterinarians should be the group monitoring, policing and ensuring that legitimate VFDs are being executed in the field. From a realistic perspective, the feed mill is going to become the wheelhouse that is going to monitor the process. Not because the feed mill wants to, but because the feed mill must. The mill is required to keep every VFD for two years. The new VFD rule did eliminate the need for veterinarians to specify the volume of VFD feed associated with the order. However, the expiration date for the VFD cannot exceed six months if the drug approval process does not specify a required VFD expiration date. In practice, new VFD drugs likely have a specified expiration date. For example, Pulmitol® for swine feed currently has a specified VFD expiration date of 90 days. Those activities put the feed mill into the policing position whether they want to be or not.
Those Activities Put the Feed Mill Into The Policing Position Whether They Want To Be Or Not.
There is an economic cost to the rule. Preparation and execution of VFD implementation will require additional investment from the feed industry prior to January 2017. After implementation record keeping will be critical and people must monitor the records which is a cost. Some mills manufacture hundreds of thousands of tons of feed. Can that be monitored by people and paper? Possibly, but some are going to require a computer software package which is a cost. When an operation chooses to utilize electronic software the program needs to be 21 CFR Part 11 Compliant. Some mills are well positioned and others must bring additional resources to the table.
Some Mills Are Well Positioned And Others Must Bring Additional Resources To The Table.
Also, veterinarians are not going to issue VFDs for free. There is no set cost for issuing VFDs; however, more onsite calls will be required, and some veterinarians have stated that they will charge the cost of an onsite visit, which can vary widely. This could have ramifications for feed mills or integrators that have contract growers under them because someone must absorb the cost.
I envision during the next four to five years, some consolidation in the swine industry from a feed mill and producer standpoint. U.S. consumers will continue to drive for more natural, organic and antibiotic-free products. As they make that drive, the use of antibiotics at the producer level and feed mill level will more than likely decrease. Alternatives to antibiotics will continue to grab hold and push agricultural systems in the U.S. to meet that consumer demand. Organizations that have science-based highly effective alternatives like Ralco will continue to be very well positioned in the agriculture industry.
- Matt Frederking
Matt Frederking is Vice President of Regulatory Affairs for Ralco.