The new FDA antibiotics regulations will require pig farmers to have a valid veterinary-client-patient relationship (VCPR). Depending on the state in which the veterinarian practices, he or she can only issue a VFD in the context of a valid VCPR as defined by the state requirements. In simplest terms, this means a pig farmer will need to have a good relationship with their veterinarian and expect to spend more time in developing a plan that satisfies all VFD requirements. As for the veterinarian’s role, he or she must be familiar with the production practices and herd health profile.
In states that do not have VCPR requirements applicable to VFDs, the veterinarian will be required to follow the federal VCPR standards, which are outlined in the FDA regulation. The agency has posted a list of states on its website that do and do not have VCPR requirements for VFDs, as well as the key elements of the federally defined VCPR. The list may change over time as states update their veterinary practice requirements.
Producers, veterinarians and feed processors will all need to be especially diligent in keeping records associated with VFDs and prescription water antibiotics once FDA’s new policies go into effect. Producers with Pork Quality Assurance® Plus (PQA Plus®) certification should be familiar with requirements for accurate and complete record-keeping.
The “Pen or Individual Pig Treatment Record” within PQA Plus provides guidance on the type of records that FDA will require. The number of animals, reason for treatment, product name and who administered the treatment, are among the data to be recorded.
The record-keeping commitment will involve keeping hard copies or electronic versions of all VFDs for two years and one year for all prescriptions. The issuing veterinarian will maintain the originals for the same timeline. Distributors who manufacture VFD feed also will keep VFD copies for two years. Any of the parties must be able to provide the VFD orders (and prescriptions) to FDA upon request.
PQA Plus also provides useful tools that can be applied on the farm to help in the regulatory transition, such as: