Veterinary Feed Directive — Producer Recordkeeping

Last month, we discussed the paperwork that will be required to comply with the new Veterinary Feed Directive rules that go into effect on Jan. 1, 2017.

Now that you are familiar with the VFD process and the forms necessary to purchase and use antimicrobial drugs intended for in or on animal feed, you will also need to be aware of the recordkeeping requirements of the rule.

The new VFD rule will require a veterinarian’s oversight and direction in the form of a written directive that includes all the pertinent information regarding purchase and use of the drug. After a veterinarian has determined the use of a VFD drug is necessary and appropriate under an established Veterinary-Client-Patient Relationship (VCPR) and animal examination, a directive will be issued to the producer to present to the feed mill or distributor.

There are a few recordkeeping rules and regulations to be aware of regarding the paperwork.

Who else gets a copy of the VFD, besides the producer?
A veterinarian must send a copy of the VFD to the distributor in hardcopy, by facsimile (fax), or by electronic means. If the veterinarian sends the VFD in hardcopy, he or she must send the copy of the VFD to the distributor either directly or through the client.

The veterinarian retains the original VFD order in its original form, whether that is electronic or hardcopy.

How long must I keep these records?
The FDA requires all involved parties, including producers, to keep VFD records for 2 years. The original stays with the veterinarian, while distributors and clients may keep an electronic copy or hardcopy.

Digital and electronic recordkeeping
A Veterinary Feed Directive (VFD) can be issued as hard copy, by fax or electronically. No matter what the format, the original stays with the veterinarian. The producer and distributor parties are required to have copies of the VFD, but those can be electronic or paper.

Companies such as Global VetLink offer resources and digital products for veterinarians, feed distributors and producers to keep track of their VFD information electronically. Much like issuing health certificates such as Coggins electronically, the FDA has approved the electronic issuance of VFD orders. If you decide to use an electronic service, program or portal to keep track of your VFD records, be sure it is a reputable service and that it will work with your personal veterinarian. It is advisable to discuss recordkeeping with your veterinarian now to be sure you’re both on the same page when it comes to how you can work together to make compliance easier on everyone involved, including your animals.

Many of the operational details of recordkeeping, issuance of directives and rule compliance are still being worked out by the FDA, feed manufacturers and producers. It is likely that further wrinkles in the system will be found and ironed out as Jan. 1, 2017 rolls closer.

For further information, visit FDA.gov and search “VFD.” -TC

“Veterinary Feed Directive — Producer Recordkeeping” is from the August 2016 issue of The Cattleman magazine.