Veterinary Feed Directive | Expiration vs. Duration of Use

Beginning in 2017, the purchase and use of any drug intended for use in animal feed will require the authorization of a veterinarian for treatment of a specific disease or illness as required by the drug’s label.

A veterinary feed directive, or VFD, is a written statement issued by a licensed veterinarian that authorizes the use of a VFD drug or combination VFD drug, in or on an animal feed. This statement or order authorizes the owner of the animal or other caretaker to obtain and use animal feed bearing or containing a VFD drug or combination VFD drug to treat the client’s animal(s), only in accordance with the conditions for use approved, conditionally approved, or indexed by the FDA.

The rule will require veterinarians to issue all VFDs within the context of a veterinarian-client-patient relationship (VCPR), including the requirement that the veterinarian engage the client or animal caretaker to assume responsibility for making clinical judgments about patient (animal) health, have sufficient knowledge of the animal by conducting examinations and/or visits to the facility where the animal is managed, and provide for any necessary follow-up evaluation or care.

The FDA hopes that by requiring a veterinarian’s supervision, their professional oversight will ensure the judicious use of medically important antimicrobials in food animals. As part of this new framework, it will also be illegal to use these drugs to promote animal growth or for use in production purposes.

Expiration date
The expiration date on the VFD specifies the last day that the VFD-ordered feed or product can be fed or dispensed. VFD-ordered products cannot be fed to animals after the expiration date on the VFD. Once a VFD is written, the client is authorized by the veterinarian to purchase that product or feed and complete treatment within that time frame.

In some cases, the FDA determines the expiration date of a VFD as part of the approval, conditional approval or listing of that drug. If a date is not specified, the expiration may not exceed 6 months after the date of issuance. The veterinarian will use his or her own medical judgment to determine the appropriate expiration of the VFD based on the client’s individual situation, facility, reason for use and treatment history. Therefore, an expiration date may be less than 6 months, depending on the product and use.

It is unlawful to feed the VFD feed to animals after the VFD expiration date.

Duration of use
The VFD expiration date defines the length of time for which the authorization to feed an animal the feed containing a VFD drug is lawful. This length of time may be specified in the approved labeling of a given VFD drug or, if not specified in the labeling, the veterinarian must specify an expiration date for the VFD that does not exceed 6 months.

The duration of use is a separate concept from the expiration date, and determines the length of time, established as part of the approval, conditional approval, or index listing process, that the animal feed containing the VFD drug is authorized for use.

For example, a drug’s label may list a 14-day duration of use with a 45-day VFD expiration. Once the VFD is issued, the client must obtain the VFD feed or product and complete the entire label-determined course of therapy — 14 days as determined by the drug manufacturer — before the VFD expires, which would be 45 days from the date of the VFD issuance. Since it is unlawful to use the VFD feeds after the specified expiration date, if a client has not completed the full course of treatment as determined by the product’s manufacturer before the VFD expiration, the veterinarian must be contacted to request a new VFD order.

How long do I keep records?
Producers must keep a copy of each VFD for a minimum of 2 years.

For more information on VFD rules and product use, visit the FDA’s website at fda.gov and search “VFD” or contact your veterinarian. If you don’t have a veterinarian, now is the perfect time to reach out and develop a relationship with one. A little preparation now will go a long way later, especially when the clock is ticking.

“Veterinary Feed Directive | Expiration vs. Duration of Use” is from the April 2016 issue of The Cattleman magazine.