Source: Michigan State University Extension, Jerad Jaborek
Regulations now require veterinarian oversight for providing medical treatment to animals since medically important antimicrobials are no longer available for purchase over the counter.
By now, you have heard of the U.S. Food and Drug Administration Center for Veterinary Medicine’s (FDA-CVM) change of purchasing medically important over-the-counter antimicrobials for animals to now requiring a veterinary prescription as of June 11, 2023. This is one of many regulatory changes implemented regarding administering antimicrobials to food producing animals over the last decade due to the growing concerns of metaphylactic treatment of food-producing animals and antimicrobial resistance. As part of FDA-CVM’s 2012/2013 release of guidance for industry (GFI) #209, “The Judicious Use of Medically Important Antimicrobial Drugs in Food-Producing Animals,” the FDA-CVM aimed to:
- Limit medically important antimicrobial drugs to uses in food-producing animals that are considered necessary for assuring animal health.
- Limit medically important antimicrobial drugs to uses in food-producing animals that include veterinary oversight or consultation.
This led to the introduction of GFI #213, “New Animal Drugs and New Animal Drug Combination Products Administered in or on Medicated Feed or Drinking Water of Food-Producing Animals: Recommendations for Drug Sponsors for Voluntarily Aligning Product Use Conditions” with GFI #209. These recommendations led to changes of the Veterinary Feed Directive (VFD), where a written statement must be issued by a licensed veterinarian to authorize the use of a VFD drug in or on the animal’s feed. The two goals of GFI #213 were:
- To eliminate the uses of medically important antimicrobial drugs for enhancing production (i.e., increased weight gain or improved feed efficiency) claims rather than specifically treating an identifiable disease.
- Implement additional veterinary oversight because of their scientific knowledge and clinical training regarding the treatment, control and prevention of disease to ensure judicious use of medically important antimicrobials.
Most recently, as part of the FDA’s five-year action plan for antimicrobial stewardship, GFI #263, “Recommendations for Sponsors of Medically Important Antimicrobial Drugs Approved for Use in Animals to Voluntarily Bring Under Veterinary Oversight All Products That Continue to be Available Over-the-Counter” ensured that any medically important antimicrobials available over the counter were brought under veterinary oversight and prescription (Rx) marketing status for the therapeutic medical treatment of all animals.
After the brief history lesson, you can quickly see how veterinarians have become the gatekeeper for food producing animal production operations and their own ability to manage animal health and disease. This brings me to the point of this article. As beef or dairy cattle producers, we must maintain a valid veterinarian-client-patient relationship (VCPR) with a licensed veterinarian in order to obtain the antimicrobial drugs needed to treat sick cattle. The FDA defines a valid VCPR as one that meets the following requirements:
- A veterinarian has assumed the responsibility for making medical judgments regarding the health of (an) animal(s) and the need for medical treatment.
- The client (the owner of the animal or animals or other caretaker) has agreed to follow the instructions of the veterinarian.
- There is sufficient knowledge of the animal(s) by the veterinarian to initiate at least a general or preliminary diagnosis of the medical condition of the animal(s).
- The practicing veterinarian is readily available for follow-up in case of adverse reactions or failure of the regimen of therapy. Such a relationship can exist only when the veterinarian has recently seen and is personally acquainted with the keeping and care of the animal(s) by virtue of examination of the animal(s), and/or by medically appropriate and timely visits to the premises where the animal(s) are kept.
Veterinarians offer a wealth of knowledge on maintaining proper animal health and basic husbandry practices. Find a veterinarian who is willing to have and maintain a VCPR with you. Set up regular farm visits annually to keep your veterinarian accustomed to your farm’s animals and management practices. Veterinarians can offer regular farm consultations on the phone (i.e., telemedicine), but an annual farm visit is still required. Veterinarians can offer advice on developing biosecurity protocols for your farm to prevent incoming disease threats. Work with your veterinarian to develop a herd health protocol/schedule for disease treatment, control and prevention throughout the year. This may include protocols for calving, breeding, vaccinations, weaning, receiving calves, dehorning, castration, euthanasia and medicated feed options when needed.
Beef Checkoff and Beef Quality Assurance have developed a Cattle Care Tool Kit Checklist to review and prepare for your cattle operation so you’ll have these things ready for when the tool is needed. Preparation is critical when animal health is at risk because time can be of the essence for positive treatment and recovery outcomes. Take the time now to have meaningful conversations with your veterinarian about preparing your cattle operation for herd health events.