An Overview of the FDA Veterinary Feed Directive
For anyone who is inclined to pay attention to it, there is a debate raging on about the use of antibiotics in food animals. As I listen, and sometimes engage in the debate, I am reminded of a story of a little boy whose parents didn’t attend church regularly, but the neighbors always took the little boy. One Sunday when the little boy got home from church, the dad asked him what they preached about that day. The boy informed his dad that the sermon was on sin. When the dad further inquired as to what they had to say about sin, the little boy thought for a bit and said, "They’re against it."
I think most of us would say we are against disease. However, there is a slice of the population who believes that "antibiotics" is a four-letter word, at least when they are used on food animals. As a veterinarian involved in animal agriculture, I would like to think my position on the use of antibiotics in food animals is based on sound science. So, if you are like the little boy’s dad, wondering where I stand on the use of antibiotics in food animals – "I’m for it."
Now, having said that, I am not for the indiscriminant use of antibiotics in food animals. To say that any unrestricted use of antibiotics in food animals or any other creature, including humans, is also wrong. In fact, to hold the position that indiscriminant use of antibiotics in food animals is okay is just as wrong as the position of all antibiotic use in food animals is a bad thing.
Antibiotics are truly miracle drugs. It is interesting that when I search the Internet for "reasons the life expectancy is increasing in developed countries," I find one of the leading factors is the ability to fight infectious disease. If we look back at the leading causes of death a century or two ago, we find that infectious and parasitic diseases topped the list. Today, heart disease and cancer figure prominently into the leading causes of death. Maybe that is because people used to not live long enough to develop heart disease and cancer. I realize that clean drinking water, safer food and vaccinations have contributed to the decrease in the number of people who die from infectious diseases. But I also think the discovery, development and use of antibiotics has greatly contributed to the decreasing number of deaths from infectious diseases.
Part of the friction about using antibiotics in food animals is the premise that they help create bacteria resistant to antibiotics and, when they are needed to treat human diseases, they won’t work because of their use in cattle, swine and poultry. That is a concern we are not only aware of but also take steps to guard against. First, there are a large number of human antibiotics not even available for food animals. Also, many of the antibiotics used in food animals are not used in human medicine. Additionally, most antibiotics are restricted to use under the direction of a licensed veterinarian. In the past, back in the 1900s, there were several antibiotics for animal use also available over the counter. Those over-the-counter antibiotics are becoming more and more scarce. In fact, I believe we are moving in a direction that will likely see over-the-counter antibiotics go the way of the dinosaur. In just a minute I will discuss the Food and Drug Administration Veterinary Feed Directive that I think supports my prediction.
Before I talk about feed directives, I want to touch on drug withdrawal times and how they are monitored. First, every drug, antibiotic or other classification, approved for food-animal use has a withdrawal time. It is printed right on the label. To assure compliance with drug-withdrawal times, animals are randomly tested for antibiotic residues at harvest. According to people who know a lot more about statistics than me, if you test a certain number of randomly selected samples, you can have a 95-99 percent confidence level that if antibiotic withdrawal times have not been observed, it will be caught. I think that’s pretty good because I can go days without being 95 percent confident of very many things. Anyway, they also do "for cause" residue testing. That would be for animals appearing to have new injection sites or exhibiting signs that would cause suspicion of recent antibiotic or other drug use. If antibiotic residues are found, then a trace-back is done to determine who did not observe the withdrawal time. Then you get on the FDA’s you-know-what list, a place you do not want to be. Initially there is an effort to educate the producer. However, if the situation appears that a producer was not just ignorant of the withdrawal regulation but ignoring it, the penalties can become much more formidable.
The FDA is also making some changes in policy addressing the use of antibiotics in food animals. Regulatory guidance is being put into place requiring antibiotics used in feed be accompanied by a veterinary feed directive. Antibiotics that have, in the past, been available over the counter to put in animal feed will transition to now requiring a veterinary feed directive very specific in the use of the antibiotic. It requires a veterinary-client-patient relationship where the veterinarian has specific knowledge of the animals being fed the medicated feed. It also requires specific records be maintained. The thought behind a move in this direction is that medically important drugs used in food-producing animals be limited to assuring the health of the animals and be limited to those uses that include veterinary oversight and consultation.
Finally, as I consider the subject of antibiotic use in food animals, I believe it is inhumane to allow animals to suffer from infectious diseases when it is within the science-based regulations and guidelines to treat those animals. When we graduate as veterinarians, we take an oath:
"Being admitted to the profession of veterinary medicine, I solemnly swear to use my scientific knowledge and skills for the benefit of society through the protection of animal health, the relief of animal suffering, the conservation of livestock resources, the promotion of public health and the advancement of medical knowledge. I will practice my profession conscientiously, with dignity and in keeping with the principles of veterinary medical ethics. I accept as a lifelong obligation the continual improvement of my professional knowledge and competence."
I don’t think I can live up to the part about "protection of animal health, the relief of animal suffering and the conservation of livestock resources"without the judicious use of antibiotics.
Dr. Tony Frazier is the State Veterinarian for Alabama. You can contact him at 334-240-7253.