It’s hard to believe that we’re already in October. Three months remain in 2016 and three months remain before the VFD rule goes into effect. While this rule change does not affect any CRYSTALYX® products, we want to be sure that you are well versed in what will be affected and what you will need to do. Below are 5 more questions that have come from the field as the deadline draws near.
First, however, a quick review as to which medications will be affected. Only those medications that are shared use (used in humans too) are affected. Ionophores (Rumensin® and Bovatec®) and bambermycin (GainPro®) are not affected by the rule change as they are only used in livestock.
1. Why has the label changed already? Does this mean I need a VFD?
You may notice that your CTC mineral has an additional caution statement on it ahead of January. Feed manufacturers have the option to add the official text (CAUTION: Federal law restricts medicated feed containing this veterinary feed directive (VFD) drug to use by or on the order of a licensed veterinarian.) ahead of January 1, 2017. Many will take advantage of that as they may have 100s of labels to change. This does not mean that the medicated mineral or feed you buy on Dec 17th needs to have a VFD. Manufacturers are just getting ready as all affected products must have that added statement on Jan 1st.
2. Can I stock up in December and feed after Jan 1st?
There is nothing to prevent you from buying a large amount of a VFD medicated product in December. However, in order to legally feed that product after Jan 1st, you will need to have a valid VFD on file at home and with your veterinarian.
3. How can I store my records?
The answer to that will depend on if you want to try electronic VFDs or paper. Either way, records will need to be stored for 2 years. GlobalVetLINK is a paid service, working to connect producers, veterinarians and feed manufacturers to put the process on line. You can learn more about it here.
4. What if I have VFD medicated feed remaining and my VFD has expired?
There are 2 options if that should happen. You will need to contact your veterinarian to get a new VFD to be able to legally feed any remaining product from the expired VFD. The less popular option is to dispose of the unused feed in a landfill.
5. Will there be producer audits?
The possibility of an audit is there, but most likely small. I do happen to know a cattle and sheep producer in Minnesota who has already been selected for a pre-compliance audit. I don’t know the details of the audit, but it does show that it could very will happen. It’s more likely to happen if an inspector finds an issue at the dealer level and then wants to follow up with customers.
I hope that you all have a plan, or a few ideas at least, in place for the changes coming on Jan 1st. Talk to your dealer about what their plan is, there are some who have decided they do not want to carry any VFD requiring products. Talk to your veterinarian, make sure that you are both on the same page when it comes to what medications you want to use. Talk to your nutritionist or sales representative, they may have ideas centered around adjusting trace mineral levels to support immune function or have suggestions on non-medicated feed additives. Bottom line is that it’s time to plan and there are people available to help you.
For more information about VFDs in general, click on the links below.
Rumensin® is a registered trademark of Elanco
Bovatec® is a registered trademark of Zoetis
GainPro® is a registered trademark of Huvepharma®