FDA’s antibiotic rules have been in effect for several weeks now and it is time to comply. From discussions we have had with experts, here are a couple of key things you can do to stay in compliance with FDA.
Documentation is key! With this new law, all three parties involved; the producer, the veterinarian and the distributor, are required to maintain a copy of your VFD for a minimum of 2 years. As a producer, you are also required to maintain feeding records of all antibiotics requiring a VFD. These records should include the date, location description and/or premise ID, animal description, antibiotic fed, date feed was finished, withdrawal date of antibiotic, veterinarian, VFD expiration date and where the antibiotic was purchased from. You may keep your feeding records in any format you wish, but the University of Wisconsin-Extension has generated a VFD form for producers to use in keeping feeding records. Click here for the link to this form. This form is not a requirement, but it is a tool that you are welcome to use.
Communication across all parties involved in a VFD will promote understanding in feeding directions. Clear communication is just as important as documentation. While it is not required, special instructions that are included on the VFD will help to diminish confusion among caretakers and distributors. Document any phone conversations you have with your veterinarian or distributor.
Yes, inspectors are out visiting farms. To be prepared for such an event, can you answer the following questions that an inspector is likely to ask? These may include:
Does the client keep copies of VFD orders for at least 2 years?
Did the client feed the VFD feed to the authorized number of animals on the VFD order?
Did the client feed the VFD feed for the identified duration on the VFD order?
Did the client stop feeding the VFD feed before the expiration date on the VFD order?
Did the client follow the withdrawal period for the VFD feed, if any?
It all stems back to documentation. By maintaining feeding records for antibiotics requiring a VFD, answering these questions should be easier in the event of an inspection.
