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VFD Information for Animal Producers
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What do these changes mean to animal producers?
  • Effective January 1, 2017, a producer must have a VFD from their veterinarian to use a feed medicated with a drug on the FDA's List (this includes all feed product types; complete feeds, supplements, premixes, liquid feeds milk replacers, etc.)
  • Production claims, like increased rate of gain and improved feed efficiency, will no longer be legal uses for the drugs on the FDA's list

How does a producer get a VFD?

A VFD can only be written as part of a valid, veterinarian-client-patient relationship (VCPR) so it is critical that you have a relationship with a veterinarian.

For more information about the FDA's VCPR requirements, click here.

After you have established a management practice and herd health history with your veterinarian, you should discuss disease challenges with your veterinarian when they arise. If your veterinarian decides that a VFD-medicated feed is needed to treat, prevent or control a disease challenge your animals are facing, he/she will write a VFD.

Click here for a "roadmap" to help you navigate the VFD process for producers.

I have my VFD and my medicated feed, now what?

The VFD-medicated feed must be used according to the information specified in the labeling and on the VFD.

This means that the feed can only be used for the indications and duration of use specified on the label and VFD form and in the animals at premises specified in the VFD.

Furthermore, if the VFD authorizes use of a VFD drug in an approved combination, that combination also must be used according to the labeling and VFD form.

Can an animal producer also be a distributor?

Yes, an animal producer can complete the one-time notification to the FDA to become a "distributor" and purchase purchased VFD-medicated feeds without having an actual VFD in-hand from his/her veterinarian when the feed is shipped.
  • The producer/distributor will provide his/her feed supplier with an AOD (Acknowledgement of Distribution Limitation for VFD Feeds) in order to purchase the VFD-medicated feed
  • In order for the producer to receive the VFD-medicated feed without a VFD in-hand, he/she must have previously notified the FDA that he/she is a distributor
  • Although the feed was received before the VFD was written, a producer is still required to have a lawful VFD from his/her veterinarian in order to feed his/her animals a VFD-medicated feed or selling the feed to his/her customer

It's also very important to remember that producers who are also acting as distributors must follow the recordkeeping requirements for both the producer role and for the distributor role.

Click here for distributor recordkeeping requirements
Click here for producer recordkeeping requirements
VFD-Requirements

Important feeding rate information your veterinarian needs to know when writing a VFD

The veterinarian is required to indicate the VFD drug inclusion rate in the feed on a gram per ton (g/t) basis on the VFD form in order for it to be lawful.

This can be listed as a specific g/t level or a g/t range as long as it is appropriate for the claim.

When working with your veterinarian, discussing the type of feeds that you normally use along with the corresponding feeding rates needed to meet the nutritional needs of the animals will help your veterinarian assign the appropriate drug inclusion range on the VFD form and will help ensure the best course of treatment for the animals
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What's the difference between an "expiration date" on the VFD and the duration of use?

The VFD expiration date is the period of time for which the authorization to feed a VFD-medicated feed is lawful.

The expiration date can never exceed six months but could be shorter depending on the specific drug approval and/or what the veterinarian determines is appropriate.

The duration is the length of time that the VFD-medicated feed can be fed to the animals. If the duration of use is not specified by the drug approval, the veterinarian will determine what is appropriate.

Can I feed a VFD-medicated feed past the VFD expiration date?

No, VFD-medicated feed must not be fed to animals after the expiration date on the VFD.

What if my VFD is going to expire before I can complete the duration of use on the form?

You should contact your veterinarian to request a new VFD. A VFD-medicated feed must not be fed to animals after the expiration date on the VFD.

Extra-label Use
Extra-label use of medicated feeds, including VFD-medicated feeds, is illegal. Extra-label use is when a drug is used in any way that is different from what's been approved by the FDA for that specific drug, species, production class, drug level, purpose, etc.

Examples of extra-label use include but are not limited to:
  • Feeding the VFD-medicated feed for any other purpose than what's listed on the product label and VFD form.
  • Feeding the animals for longer than the duration of use stated on the label and the VFD form.
  • Feeding a VFD-medicated feed at a drug level that is different from what's specified on the label and the VFD form.
  • Feeding the VFD-medicated feed to an animal species or production class that isn't specified on the product label and the VFD form.
FDA's List of Producer Responsibilities

The FDA's VFD Requirements for Producers page says that producers must:
  • Only feed VFD-medicated feed to animals based on a VFD issued by a licensed veterinarian
  • Follow the VFD and the product label exactly, including withdrawal times
  • Not feed a VFD-medicated feed to animals after the expiration date on the VFD form
  • Not mix VFD-medicated feeds with any other medicated feeds unless you're authorized to do so by the VFD
  • Provide a copy of the VFD form to the feed distributor if the issuing veterinarian sends the distributor's copy of the VFD through you, the client
  • Maintain a copy of the VFD and related feeding records for a minimum of 2 years and be able to produce them for inspection and copying by FDA upon request
What records is a producer required to keep?

A producer must keep their copy of the VFD and corresponding feeding records, and make them available to the FDA upon request, for 2 years.

For more information: FDA's VFD Requirements for Producers page
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