Go with the flow: How to manage VFDs with pigs coming and going
Part 9 in a series
In an exclusive 90-minute interview with editors from the VFD News Center, William Flynn, DVM, MS, deputy director for science and policy for FDA’s Center for Veterinary Medicine, clarified some hazy points of the new veterinary feed directive (VFD) regulations that took effect January 1, 2017. In this installment, Flynn discusses syncing VFDs with a farm’s pig flow and the medications being fed.
Managing VFDs with pig flow
Q: Pigs and other livestock are not always as consistent in feed consumption as chickens. What happens if, for example, a swine VFD medication such as chlortetracycline is indicated for a treatment period of no more than 14 days. However, because feed consumption was less than expected, there’s still some medicated feed remaining on day 15. Does that feed need to be discarded? Or can the medicated feed remain in the lines as long as the producer abides by the product’s designated withdrawal time?
WF: The challenge with this question is the legality, specifically around extra-label use for feed-use products. Technically speaking, the treatment duration needs to be followed. If it’s only 14 days, then you should use the medication only for the 14 days. Anything beyond that would require a reassessment by the veterinarian — essentially reauthorization for another course of therapy.
Q: So, on day 15, does the producer need to dump all that feed out of that line? Or could the producer finish the next 12 hours’ worth?
WF: The issue there — and you mentioned it earlier — is whether there are any drug-residue issues resulting from that extended duration. I understand the preference is not to dump feed, and we are not interested in feed being unnecessarily dumped, either.
However, so long as there is no significant public-health concern from a drug-residue issue and the veterinarian is aware of the situation, this is not likely to be a high priority for us from an enforcement standpoint.
Q: in summary, then, if it’s a 14-day treatment and you get into day 15, it would be acceptable to keep using the medicated feed as long as you consult with your veterinarian and honor the product’s withdrawal time?
WF: I can’t say that this is okay, legally. But from a compliance standpoint, it’s not something we would view as a high priority in a situation where you didn’t quite hit the mark with feed consumption and a little overlap — a day or so — particularly when it doesn’t represent a public-health concern. Any significant usage beyond that should require a new VFD.
Q: What happens if pigs are moved before they finish the VFD feed? Is it necessary to remove the feed completely from the bin? Or can the feed be stored in the bin until you have another group of pigs and your veterinarian has issued a VFD?
WF: If you have leftover medicated feed containing a VFD drug and the VFD authorization you had expired, you don’t have to get rid of that feed, provided there’s not a shelf-life issue. You can legally hold that feed on site. You just can’t feed it to animals until a new VFD is in place. This situation needs to be documented, however. There should be some record that the feed was held and then used for a new set of animals with a new VFD from a veterinarian.
Q: Let’s say we have a VFD that’s good for 6 months. What happens if new pigs are introduced to a site or barn where a VFD medication is already in use? Specifically, if we’re bringing in groups of nursery pigs and we’re loading that nursery with, say, 500 every week. Is a new VFD needed for each new group of incoming pigs? Or are they covered under the 6-month VFD that’s already in place for that barn and that age of pig?
WF: Yes, the 6-month VFD would cover the incoming pigs. The only qualifier here is that the VFD needs to authorize the drug’s use in a certain number of animals. For example, even if you have a VFD authorization that is valid for 6 months, the veterinarian was required to issue it on the approximate number of animals, not the quantity of feed.
So, if the understanding was that 5,000 head would be moved through a facility, that the expectation is that the capacity of that facility is 5,000 head over 6 months. At any given time, maybe there’s only 500 to 1,000 of those animals but the authorization is for up to 5,000 animals over a designated period of time.