The National Grain and Feed Assn. (NGFA) and American Feed Industry Assn. (AFIA) made several recommendations to the U.S. Food and Drug Administration (FDA) regarding its draft Veterinary Feed Directive (VFD) guidance. 

FDA made the draft guidance available on March 27 to provide the agency’s current thinking on responsibilities associated with all parties involved with VFD orders – veterinarians, VFD feed distributors (e.g., feed mills) and clients (i.e., owners or other caretakers of food-producing animals). The document expanded upon a previous FDA VFD guidance issued in September 2015 by adding 53 new questions and answers and revising 14 others. The new and revised questions and answers address a wide range of issues that have emerged as a result of the increased use of the VFD process. 

The VFD regulations establish requirements for authorizing the use of animal drugs in or on feed that require the supervision of a licensed veterinarian. FDA’s updated VFD rule went into effect Oct. 1, 2015, and the agency’s implementation of policies to promote the judicious use of antimicrobial drugs in food-producing animals was completed Jan. 1, 2017. Based upon FDA’s policies, all production uses (e.g., growth promotion) of medically important antimicrobials approved for use in the feed or drinking water of food-producing animals were eliminated, and such drugs now only can be used for therapeutic purposes under veterinary oversight.

In its statement, NGFA commended FDA for updating the guidance with valuable information for all parties covered by the VFD regulations. However, NGFA also made recommendations for several questions and answers in the draft guidance where it believes further consideration by FDA is warranted before final guidance is issued. Among NGFA’s recommendations were that FDA:   

Related:FDA issues revised Q&A draft guidance on VFD regulation

Paul Davis, AFIA director of quality, animal food safety and education, said aside from expressing gratitude for the agency’s work to clarify several questions from industry, AFIA also urged the agency to modify a few key questions, including not be overly prescriptive with drug levels in feed, since there are more than 30 indications that can be expressed accurately and appropriately in units of measure beyond “g/ton” and to clarify that only one “distributor” be permitted per VFD transaction, particularly since many feed mills that manufacture VFD products work with bulk delivery vehicles and deliver products for dealers, which act as VFD distributors transactionally.