A lawful VFD is a complete VFD. Learn more about what needs to be included on the VFD order. We also discuss how you will need to manage your VFD records.
Liz Binversie, Agriculture Educator, Brown County UW-Extension
Sarah Mills-Lloyd, Agriculture Agent, Oconto County UW-Extension
Time: 6:33 minutes
Liz Binversie: Greetings, I’m Liz Binversie, Agriculture Educator for Brown County UW-Extension. We’re going to switch gears a little bit on today’s episode on the Veterinary Feed Directive and talk about how this is going to affect recordkeeping on the farm. On the podcast today is Sarah Mills-Lloyd, Agriculture Agent for Oconto County UW-Extension. Sarah, what do producers need to know about recordkeeping and what are they required to do under these new Veterinary Feed Directive changes?
Sarah Mills-Lloyd: The very first thing that a producer needs to understand is that they need to have a valid veterinary client patient relationship, which is defined by state statute but it’s basically responsibilities of both parties—that the veterinarian has the responsibility for making medical judgments regarding the health of the patient and the client has agreed to accept those medical judgements and to follow the related instructions of the veterinarian—which leads into the Veterinary Feed Directive form and the requirements on that form, which are filled out by your herd veterinarian, which would include the veterinarian’s name, address and telephone number, the client’s name, address, and telephone number, the premise which the animals are housed, the date of when the VFD was issued, the expiration date of the VFD, the name of the VFD drug, the species and production class that is being fed the VFD, the indication of use, the level and duration of the Veterinary Feed Directive, withdrawal time or special directions or cautionary statements, the number of authorized refills, the veterinarian’s electronic and/or written signature, and also a statement saying that “The use of feed containing this Veterinary Feed Directive drug in a manner other than as directed on the labeling—extra label drug use—is not permitted.”
Liz Binversie: Sarah, when it comes to the expiration date and duration of use, I know this can be pretty confusing for some folks so could you explain what the difference is between them? They sound a little similar here and what do producers need to know so they don’t accidentally do something that is illegal.
Sarah Mills-Lloyd: The Veterinary Feed Directive definition for duration date would be the length of time the Veterinary Feed Directive product may be fed to the animals and that is actually specified on the product label. In addition, the expiration date can sound very similar to duration date but actually it’s the period of time in which the authorization to feed that specific feed containing the VFD drug to the specified animals. In addition to all of those definitions, we also have to understand recordkeeping requirements. The Veterinary Feed Directive records must be maintained for two years. This includes the veterinarian, the client, and also the feed mill distributor. The veterinarian maintains the original copy of that Veterinary Feed Directive and you can have electronic records. Those are allowable under the code of federal regulations. However, what is not legal and is prohibited is the verbal issuance of a Veterinary Feed Directive.
Liz Binversie: As a follow up question: What would happen if my VFD order is going to expire before I can finish the treatment because I’d be following the duration date but maybe exceed the expiration date? What do I do?
Sarah Mills-Lloyd: If the Veterinary Feed Directive drug that you’re trying to use exceeds the expiration of your current Veterinary Feed Directive, you must secure a new Veterinary Feed Directive order from your veterinarian.
Liz Binversie: Sarah, we talked about recordkeeping and what’s required of producers but could we get a little more specific about electronic vs. written and maybe what items that producers need to keep track of or pieces of information they need to make sure that they write down or keep track of in order to maintain those records properly?
Sarah Mills-Lloyd: So, farmers have responsibilities in the written record portion of the Veterinary Feed Directive that they do need to maintain the copy of the Veterinary Feed Directive order for two years and also record information. The last component of it too is they need to provide the Veterinary Feed Directive orders for inspection if they are requested by the Food and Drug Administration. It might behoove people to actually start a filing system and this can be done through a notebook piece of paper and/or an electronic version through an excel spreadsheet. Items to include on a summary sheet, if you want to keep it in a concise manner, because obviously you need to keep the original or copy of the Veterinary Feed Directive from your veterinarian, but in addition to that, you can also start a log system. Things to include on that log system would be the date you started feeding the Veterinary Feed Directive medication, the location and description, the animal description and identification, the Veterinary Feed Directive drug, and that use—so is it water-based or feed-based—the date that you finished that medication, so what is that label duration and that is from that VFD order, the withdrawal date from the label, the name of the veterinarian issuing your Veterinary Feed Directive, the date of expiration of the Veterinary Feed Directive, your purchase point of the Veterinary Feed Directive, and any additional information that you would like to include about it. That can be done on a simple excel spreadsheet or, like I said, on a notebook with just pen and paper.
Liz Binversie: Thank you again, Sarah, for being on the panel and helping to answer these questions that I’m sure a lot of producers have about the veterinary feed directive and what their responsibilities are for the recordkeeping portion of it. So again, thank you very much and stay tuned. We’ll also have an Ask the Expert segment for our next podcast.