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News and analysis on the global poultry
and animal feed industries.
on September 1, 2010

AFIA, NGFA submit comments on VFD

Associations urge FDA to make changes to existing process

The American Feed Industry Association (AFIA) and National Grain and Feed Association (NGFA) have released a joint statement calling for the Food and Drug Administration (FDA) to make "much-needed improvements" to its current regulatory procedures, in particular the veterinary feed directive (VFD).

Currently a licensed veterinarian can issue a VFD with respect to tilmicosin and florfenicol for swine respiratory disease and certain conditions affecting aquatic species. The two industry associations are opposed to the FDA intention of mandating the VFD process with respect to previously approved antimicrobials which have safety records dating back to the 1950s.

The VFD is a regulatory program whereby a licensed veterinarian issues a written statement that authorizes the use of a VFD drug to treat a client's animals, but only in accordance with the directions for use set forth by the FDA. The FDA is considering expanding the program to apply to more than the current two approved drugs as a means to increase veterinary oversight. The AFIA and NGFA, however, said they were "extremely concerned about, and would oppose" such expansion. "This regulatory burden is substantial, both in terms of time and cost, with feed mills being the focal point for inspection when regulatory officials seek to determine compliance with the current VFD regulations," the associations said. Limiting more drugs to approval via the VFD process would only cause more paperwork burdens and regulatory compliance costs for feed manufacturers, the NGFA and AFIA said.

In addition, the AFIA and NGFA listed several proposed improvements to the current VFD process:
• Eliminate the requirement that veterinarians calculate the quantity of feed required to treat targeted animals.
• Eliminate the requirement that VFD orders disseminated by fax or e-mail be followed up with an original copy within five business days.
• Change the records-retention requirement for VFD orders to one year, rather than the current two years.
• Amend existing medicated feed regulations to avoid automatically classifying VFD drugs as Category II, Type A medicated articles.
• Increase educational and training efforts among veterinarians to reduce problems associated with incomplete or inaccurate VFD orders.  

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