No one ever suggested it was going to be easy; however, when the Food & Drug Administration (FDA) revealed its first draft of the amended Veterinary Feed Directive (VFD) last year, the stakeholders in the feed industry threw up red flags on a number of items.
Of these problem areas, one major point of contention was the required two-year VFD recordkeeping guideline. While the other hot button areas were resolved to the satisfaction of the trade associations, like the American Feed Industry Association (AFIA) and the National Grain and Feed Association (NGFA), the June release of the final rule of the VFD did not resolve the two-year recordkeeping requirement.
Richard Sellers, AFIA’s senior vice president of regulatory affairs, was of the belief that the recordkeeing timeline had been reduced to one year and was a bit taken aback when it remained.
“We believed we had convinced FDA the two-year requirement should be reduced to one year to agree with the one-year recordkeeping requirement that appears in the Current Good Manufacturing Practices regulations," he said.
The problem: With the high costs associated with a validated electronic system, none of the U.S. feed mills are currently verified. Instead, each will need to print, sign and date each VFD and store for two years. This may not seem like a huge inconvenience at first, but when you consider the additional 283 drugs gaining VDF status, holding onto paperwork for two years at a time presents a great administrative burden (not to mention the office footprint these files will occupy).
To date, it’s unclear if this portion of the rule will amended. But it’s certain that under the current law of the land, feed mills better clear the way for extra filing cabinets.
The final rule goes into effect in January 2017.