Veterinary Feed Directive

FAQ

Veterinary Topics

(Clicking on the source link at the end of each topic section will take you to the original document from which the questions and answers were derived.)

• What are my responsibilities as a veterinarian?
  • In order for a VFD to be lawful, the veterinarian issuing the VFD:
    • must be licensed to practice veterinary medicine (21 CFR 558.6(b)(1)(i));
    • must be operating in the course of the veterinarian’s professional practice and in compliance with all applicable veterinary licensing and practice requirements (21 CFR 558.6(b)(1)(ii));
    • must write VFD orders in the context of a veterinarian-client-patient relationship (VCPR) (21 CFR 558.6(b)(1)(ii));
    • must only issue a VFD that is in compliance with the conditions for use approved, conditionally approved, or indexed for the VFD drug or combination VFD drug (21 CFR 558.6(b)(2));
    • must prepare a written (nonverbal) VFD (21 CFR 558.6(b)(7)) that includes the veterinarian’s electronic or written signature (21 CFR 558.6(b)(3)(xv));
    • must ensure the VFD includes all required information specified in the VFD regulation (21 CFR 558.6(b)(3));
    • may enter additional discretionary information to more specifically identify the animals to be treated/fed the VFD feed (21 CFR 558.6(b)(4));
    • must include certain drug-specific information for each VFD drug when the veterinarian is authorizing the use of a drug combination that includes more than one VFD drug (21 CFR 558.6(b)(5));
    • for VFD drugs approved for use alone or in combination with one or more OTC drugs, must include on the VFD order an affirmation of intent either to restrict authorized use only to the VFD drug cited on the VFD or to allow the use of the cited VFD drug in an approved combination with one or more OTC drug(s) (21 CFR 558.6(b)(6));
    • must provide the distributor with a copy of the VFD order (21 CFR 558.6(b)(8));
    • must provide the client with a copy of the VFD order (21 CFR 558.6(b)(9));
    • must retain the original VFD for 2 years (21 CFR 558.6(a)(4)); and
    • must provide VFD orders for inspection and copying by FDA upon request (21 CFR 558.6(a)(5)).
• Can I write a VFD order for an OTC drug?
  • No. A practicing veterinarian may not write a VFD order for an OTC drug. A veterinarian may only write a VFD order for drugs approved, conditionally approved, or indexed as VFD drugs by the FDA (21 U.S.C. 354); nor may he or she write a VFD order to be used other than as specified on the labeling for that drug (i.e., extralabel use is not permitted). (21 CFR 558.6(a)(3)).
• How do I authorize or limit the use of a VFD drug that is approved to be used in
  combination with OTC drugs?
  • Some VFD drugs are approved for use alone or in a combination with one or more OTC drug(s). In those circumstances, the issuing veterinarian would specify on the VFD whether he or she authorizes the VFD drug to be used alone or in an approved drug combination with one or more OTC drug(s). In accordance with 21 CFR 558.6(b)(6), the veterinarian is required to affirm his or her intent by including one of the following three statements on the VFD:
    • "This VFD only authorizes the use of the VFD drug(s) cited in this order and is not intended to authorize the use of such drug(s) in combination with any other animal
      drugs."
      • This statement is used if the veterinarian does not authorize the VFD drug to be used in combination with any other animal drug in the medicated feed. For those VFD drugs that are only approved as a single ingredient Type A medicated article, i.e., there are no approved combinations that contain the VFD drug as a component, this statement is the only one of the three statements that can be selected and must be included in the VFD.
    • "This VFD authorizes the use of the VFD drug(s) cited in this order in the following FDA-approved, conditionally approved, or indexed combination(s) in medicated feed that contains the VFD drug(s) as a component." [List specific approved combination medicated feeds following this statement.]
      • This statement is used if the veterinarian chooses to authorize the use of the VFD drug(s) only in specific combination(s); the veterinarian may only list approved, conditionally approved, or indexed combination(s) that contain the VFD drug. The client is authorized to use the VFD drug(s) in medicated feed either alone or in those specific combinations that the veterinarian has specified on the VFD.
    • "This VFD authorizes the use of the VFD drug(s) cited in this order in any FDAapproved, conditionally approved, or indexed combination(s) in medicated feed that
      contains the VFD drug(s) as a component."
      • This statement is used if the veterinarian authorizes the use of the VFD drug(s) in any approved combination that contains the VFD drug. The client is authorized to use the VFD drug(s) either alone or in any approved, conditionally approved, or indexed combination with the OTC drug(s) in the medicated feed.
• Other than the required information, what other information may I include in the VFD?
  • As also noted in II.C.1 above, the veterinarian may, at his or her discretion, more specifically identify the animals authorized to be treated/fed the VFD feed (21 CFR 558.6(b)(4)). Specifically, the veterinarian can further specify the location of the animals (e.g., site, pen, barn, stall, or tank), the approximate age or weight range of the animals, or any other information the veterinarian deems appropriate to identify the animals subject to the VFD.
• How can I transmit an electronic VFD order to the distributor immediately if my third-party computer server holds all VFD orders and only transmits them once per day (e.g., midnight)?
  • For an immediate delivery of an electronic VFD order, we recommend that the veterinarian print a copy of the VFD and have it hand delivered, transmitted by facsimile, or transmitted electronically to the distributor.
• How do I cancel my VFD order?
  • To cancel a paper VFD order we recommend that the veterinarian promptly contact the client and distributor in possession of a copy of the VFD order. To cancel an electronic VFD order that involves a third-party server, we recommend that the veterinarian contact the server and request that the VFD order not be transmitted. If the
    veterinarian wants to cancel the VFD order after the order has been electronically transmitted, we recommend that he or she contact the distributor and client who received a copy of the VFD order and request that the VFD order be cancelled. We recommend that the involved parties document the cancellation request and make the records
    available at the time of an inspection. In a situation where the distributor is contacted regarding cancellation of the VFD order, we recommend that the distributor document the final outcome of the cancellation request (e.g., state that the VFD feed was neither prepared nor distributed to the client).
• In the past, I issued paper VFD orders. Do I have to issue electronic VFD orders now?
  • No. Issuing VFD orders electronically is entirely optional. Paper VFD orders remain an acceptable means of authorizing the use of a VFD drug.
• How do I obtain a VFD form for a VFD drug?
  • Although it is not mandatory for VFD drug sponsors to provide copies of a VFD form for use by veterinarians, sponsors may make the VFD forms available to veterinarians in triplicate to ensure efficiency and completeness of VFD order transmission. Regardless of whether or not a drug sponsor makes VFD forms available to veterinarians, a veterinarian may create his/her own VFD form for a VFD drug. Any VFD form, whether provided by the drug sponsor or created by a veterinarian, must include the information specified in 21 CFR 558.6(b)(3).
• Can I make my own VFD form to authorize the use of a VFD drug?
  • Although many companies distribute for use by veterinarians a VFD form that is specific to their products, a veterinarian may also create or use a different VFD form, as long as it contains all of the required information specified in 21 CFR 558.6(b)(3).

[Source: FDA GFI 120]

• How will electronic VFDs work? What constitutes a valid signature (part 11)? does Global Vet Link satisfy requirements for the vet, producer and feed mill?
  • Electronic records, such as an electronic VFD that meets the requirements of part 11, may be used in lieu of a paper VFD. As we have previously stated in GFI #120, part 11 applies to records in electronic form that are created, modified, maintained archived, retrieved, or transmitted under any FDA records requirements. Electronic VFDs issued by veterinarians must be compliant with part 11, and VFDs received electronically stored by distributors and clients must be compliant with part 11. 21 CFR part 11 does not apply to paper records that are, or have been, transmitted by electronic means (such as facsimile, email attachments, etc.).
    
    The VFD is required to be signed by the veterinarian. If the veterinarian chooses to sign the VFD electronically, the electronic signature needs to be part 11 compliant. We recommend that users check with Global Vet Link, or any other electronic VFD service provider to confirm that the software system is part 11 compliant. If a veterinarian signs a paper copy and scans the VFD to distribute a copy to the client/distributor, that is not considered an electronic signature.
    
    Additional information about part 11 compliance, including information on how FDA intends to exercise enforcement discretion with regard to certain part 11 requirements during the reexamination of part 11, can be found in GFI Part 11, Electronic Records; Electronic Signatures--Scope and Application; http://www.fda.gov/downloads/RegulatoryInformation/Guidances/ucm125125.pdf
• Can technical vets for animal health companies write a VFD?
  • In order for a technical services veterinarian for a drug company to write a lawful VFD, the veterinarian issuing the VFD must 1) be licensed to practice veterinary medicine, and 2) be operating within the course of the veterinarian's professional practice and in compliance with all applicable veterinary licensing and practice requirements, including issuing the VFD in the context of a veterinarian-client-patient relationship (VCPR) as defined by the State. If applicable VCPR requirements as defined by such State do not include the key elements of a valid VCPR as defined in 21 CFR 530.3(i), the veterinarian must issue the VFD in the context of a valid VCPR as defined in 21 CFR 530.3(i) (21 CFR 558.6(b)(1)).
    
    Refer to the link below to determine if the State or Federal VCPR Definition applies to a Lawful VFD in your State: http://www.fda.gov/AnimalVeterinary/DevelopmentApprovalProcess/ucm460406.htm
• Do you have to write a new VFD if a feed mill goes down, and you need to switch to a new mill?
  • The VFD regulation requires the veterinarian to send a copy of the VFD to the distributor via hardcopy, facsimile (fax), or electronically. If in hardcopy the veterinarian must send the copy of the VFD to the distributor either directly or through the client. (558.6(b)(8)).
    
    The distributor that the veterinarian or client gives the VFD to should be the only distributor filling the entire order. In special circumstances (eg., if a mill runs out of a VFD drug and the client needs VFD feed immediately to adhere to the treatment regimen or if a feed mill goes down unexpectedly), there may be a need for two mills to fill the entire order. If that is the case the client and distributors should all keep records documenting the situation so that it is clear that the animals received only the treatment authorized by the VFD.
• Can a small animal vet write a VFD?
  • In order for a small animal veterinarian to write a lawful VFD, the veterinarian issuing the VFD must 1) be licensed to practice veterinary medicine, and 2) be operating within the course of the veterinarian's professional practice and in compliance with all applicable veterinary licensing and practice requirements, including issuing the VFD in the context of a veterinarian-client-patient relationship (VCPR) as defined by the State. If applicable VCPR requirements as defined by such State do not include the key elements of a valid VCPR as defined in 21 CFR 530.3(i), the veterinarian must issue the VFD in the context of a valid VCPR as defined in 21 CFR 530.3(i) (21 CFR 558.6(b)(1)).
    
    Refer to the link below to determine if the State or Federal VCPR Definition applies to a Lawful VFD in your State: http://www.fda.gov/AnimalVeterinary/DevelopmentApprovalProcess/ucm460406.htm
• Can a vet write a VFD if they aren't accredited?
  • A National Veterinary Accreditation is not required for a veterinarian to issue a valid VFD. In order for a small animal veterinarian to write a lawful VFD, the veterinarian issuing the VFD must 1) be licensed to practice veterinary medicine, and 2) be operating within the course of the veterinarian's professional practice and in compliance with all applicable veterinary licensing and practice requirements, including issuing the VFD in the context of a veterinarian-client-patient relationship (VCPR) as defined by the State. If applicable VCPR requirements as defined by such State do not include the key elements of a valid VCPR as defined in 21 CFR 530.3(i), the veterinarian must issue the VFD in the context of a valid VCPR as defined in 21 CFR 530.3(i) (21 CFR 558.6(b)(1)).
    
    Refer to the link below to determine if the State or Federal VCPR Definition applies to a Lawful VFD in your State: http://www.fda.gov/AnimalVeterinary/DevelopmentApprovalProcess/ucm460406.htm
• Does the veterinarian have to specify the feed mill on the VFD?
  • The VFD regulation requires the veterinarian to send a copy of the VFD to the distributor via hardcopy, facsimile (fax), or electronically. If in hardcopy the veterinarian must send the copy of the VFD to the distributor either directly or through the client. (558.6(b)(8)). If the veterinarian provides the client with a hardcopy to take to the distributor, the client can go to the distributor of their choice.
    
    When the veterinarian is issuing the VFD directly to the distributor (i.e., the client won't be taking a hardcopy to the distributor), the client should tell the veterinarian which distributor to send the VFD to. If the client is unsure of where they would like to get the VFD feed, they should get a hardcopy from the veterinarian so they can provide it to the distributor of their choice. If the veterinarian has sent the VFD to a distributor and the client decides they would like to get the VFD feed from a different distributor, they should contact the veterinarian to have them revoke the VFD from the original distributor and resend it to the new distributor.
• If writing a VFD that is to be distributed to multiple ranches (premises), do you need a separate one for each physical address?
  • The veterinarian may write a VFD that covers animals in multiple locations (animal production facilities) to be fed the VFD feed by the expiration date on the VFD, provided he or she can do so in compliance with professional licensing and practice standards and provided the VFD feed is supplied to such multiple locations by a single feed manufacturer (distributor). The veterinarian would also need to be authorizing the same use for all of the animals covered under the VFD (e.g., the indications, species, age range, etc.).
• Can video/photos count as "being familiar" with an operation to establish a VCPR?
  • The federal VCPR definition states in part that "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 animals and/or by medically appropriate and timely visits to the premises where the animal(s) are kept." 21 CFR 530.3(i)(3) In addition, one of the key elements required in order for a state VCPR to be recognized is that the veterinarian "have sufficient knowledge of the patient by virtue of patient examination and/or visits to the facility where the patient is managed." Therefore, for the purposes of issuing a VFD a VCPR cannot be established by video/photos.
• If a staff vet writes a VFD for a company owned feedmill, for company animals, do they need to retain one or three copies of the VFD? Does a copy have to be submitted to the FDA?
  • 21 CFR 558.6 identifies the three parties -- veterinarian, producer and the VFD feed distributor, as the parties that are required to keep the record of a VFD order. If one firm represents the veterinarian, the distributor, and the client, it is acceptable for the VFD to be stored in one location provided that everyone required to have a copy has access and can provide a copy to the FDA investigator upon request.
    
    A copy of the VFD does not need to be provided to FDA at the time of issuance, a copy of the VFD would only need to be provided to the FDA upon request.
• How are the veterinarians going to calculate dosages (used to milligrams, not pounds per ton)?
  • The final rule requires the veterinarian to write in the "The level of VFD drug in the VFD feed and duration of use" (558.6(b)(3)(x)). The allowable level of drug in the VFD feed is part of the VFD drug approval and is located on the VFD drug label. Many non-FDA resources are available to assist veterinarians in making any needed calculations.
• Can a lawful VFD be written for 6 months by a veterinarian licensed in another state who has a temporary -- 30 to 60 day -- permission to practice veterinary medicine in the state in which the premises exist to which the medicated feed is delivered?
  • Because the VCPR requirements for both the federal VCPR and state VCPR must include the ability for the veterinarian to provide for any necessary follow-up evaluation or care the veterinarian cannot write a lawful VFD under a valid VCPR if they do not have permission to practice veterinary medicine for those animals during the entire duration of the VFD. Therefore, the expiration date of the VFD should not exceed the length of time the veterinarian is authorized to temporarily practice veterinary medicine.

[Source: Farm Foundation]

• If a caretaker (not owner) of an animal gets a VFD, does a copy of the VFD have to be sent to the owner of the animal?
  • 21 CFR 558.6 identifies the three parties – veterinarian, producer (client), and the VFD feed distributor, as the parties that are required to keep the record of a VFD order.
    
    In the situation described, for the purposes of the VCPR (veterinarian-client-patient relationship) and VFD it may be that the caretaker will be considered the client because it appears that is the person who is responsible for feeding the animals the VFD feed.
    
    The preamble to the final rule and the definition for a veterinary feed directive describe the client as the "owner of the animals or other caretaker." Response 26 in the preamble states that the "client name and address should reflect the client in the veterinarian-client-patient relationship, which is typically the person responsible for feeding the animals the VFD feed.”
• How do I write a VFD when feed for a client may be coming from multiple mills?
  • The distributor that the veterinarian or client gives the VFD to should be the only distributor filling the entire order.
    
    In special circumstances (e.g., if a mill runs out of a VFD drug and the client needs VFD feed immediately to adhere to the treatment regimen or if a feed mill goes down unexpectedly), there may be a need for two mills to fill the entire order. If that is the case, the client and distributors should all keep records documenting the situation so that it is clear that the animals received only the treatment authorized by the VFD.
    
    It is unclear from the question whether the different feedmills are different locations for one distributor, as multiple feedmill locations could be considered one distributor if owned by the same corporation. A distributor is defined as "any person who distributes a medicated feed containing a VFD drug to another person. Such other person may be another distributor or the client-recipient of a VFD." (21 CFR 558.3(b)(9)). A person is defined in 201(e) of the FD&C Act "The term “person” includes individual, partnership, corporation, and association." (21 USC 321(3)). One distributor may have multiple locations and it is acceptable for that distributor to fill a VFD from any of its locations.
    
    In the preamble to the final rule we discussed how VFDs may be written for groups of animals with a similar age, weight range, etc., that are managed in a similar manner but housed at multiple premises. In the preamble, we said “the veterinarian may write a VFD that covers animals in multiple locations (animal production facilities) to be fed the VFD feed by the expiration date on the VFD, provided he or she can do so in compliance with professional licensing and practice standards and provided the VFD feed is supplied to such multiple locations by a single feed manufacturer (distributor).” The same principle would apply to groups of animals housed at the same facility, but receiving feed from separate mills. We would expect a separate VFD for the VFD feed received from each mill.
• Many feedyards "bid" a supplement for 30 days. If a veterinarian writes a script for 6 months but the "bid" changes between feed mills every 30 days, how does FDA handle that?
  • The VFD regulation requires the veterinarian to send a copy of the VFD to the distributor via hardcopy, facsimile (fax), or electronically. If in hardcopy the veterinarian must send the copy of the VFD to the distributor either directly or through the client. (558.6(b)(8)). The distributor that the veterinarian or client gives the VFD to should be the only distributor filling the entire order.
    
    In special circumstances (e.g., if a mill runs out of a VFD drug and the client needs VFD feed immediately to adhere to the treatment regimen), there may be a need for two mills to fill the entire order. If that is the case the client and distributors should all keep records documenting the situation so that it is clear that the animals received only the treatment authorized by the VFD.
    
    If the veterinarian provides the client with a hardcopy to take to the distributor, the client can go to the distributor of their choice. When the veterinarian is issuing the VFD directly to the distributor (i.e., the client won’t be taking a hard copy to the distributor), the client should tell the veterinarian which distributor to send the VFD to. If the client is unsure of where they would like to get the VFD feed, they should get a hard copy from the veterinarian so they can provide it to the distributor of their choice. If the veterinarian has sent the VFD to a distributor and the client decides they would like to get the VFD feed from a different distributor, they should contact the veterinarian to have them revoke the VFD from the original distributor and resend it to the new distributor.
• Pulmotil is to be fed for 21 continuous days. The first seven days is Phase 1 and is fed by Mill A. The last 14 days is fed in Phase 2 by Mill B. How should the VFD be written?
  • Can two mills be put on the same VFD? The VFD includes information about the drug as approved for the indication. The VFD does not include information about the nutritional ingredients in the ration of the VFD feed. It is acceptable to feed several rations under a single VFD so long as each of those rations is consistent with the VFD and the drug approval.
• Can a veterinarian store an electronic VFD on their own hard drive?
  • Electronic VFD (e-VFD) orders issued by veterinarians may be stored either electronically or in hard copy by distributors and clients (see 21 CFR 558.6(a)(4)).
    
    Although the electronic storage of e-VFD orders by distributors and clients must be compliant with 21 CFR Part 11, FDA has published its intent to exercise enforcement discretion with regard to certain Part 11 requirements in guidance the Agency issued in August 2003 entitled, “Part 11, Electronic Records; Electronic Signatures—Scope and Application.” The record retention portion of this guidance indicates that the Agency intends to exercise enforcement discretion with regard to the Part 11 requirements for the protection of records to enable their accurate and ready retrieval throughout the records retention period (§ 11.10 (c) and any corresponding requirement in §11.30). The guidance also states with respect to records retention that FDA does not intend to object if you decide to archive required records in electronic format to a standard electronic file format (examples of such formats include, but are not limited to, PDF, XML, or SGML).

[Source: Feedstuffs]

• This is a common scenario: Producer A wants to feed 2 pulses of Chlortetracycline (CTC) in the nursery phase (8 week duration of growth).  In a single group of a 1,000 pigs, they get 2 weeks of CTC at the beginning (weeks 0-2 at 15 lbs of weight) and again the last 2 weeks of the group (weeks 7-8 at 60 lbs of weight).  How many VFD’s are required for this group?
  • A veterinarian cannot issue a VFD that authorizes a duration of use that is inconsistent with the directions for use described on the product labeling. In the example provided, if the approval limits the treatment to 14 days, the VFD can only authorize that approved duration.  Issuing a VFD that authorized a 14 day course to be repeated for the same animals would be considered an illegal extralabel use. 
    
    However, if the veterinarian reassesses the animals involved after a single course of therapy (i.e., drug administered according to the labeled dose and duration), the veterinarian may decide that additional therapy is warranted.  In such case, a new VFD is needed.
• Producers buy some products from one mill, and other diets/products from a second mill. Do they need a VFD for each mill, or can they write one VFD with all of the products on it?
  • The distributor that the veterinarian or client gives the VFD to should be the only distributor filling the entire order. 
    
    In special circumstances (e.g., if a mill runs out of a VFD drug and the client needs VFD feed immediately to adhere to the treatment regimen or if a feed mill goes down unexpectedly), there may be a need for two mills to fill the entire order.  If that is the case, the client and distributors should all keep records documenting the situation so that it is clear that the animals received only the treatment authorized by the VFD.
    
    It is unclear from the question whether the different feedmills are different locations for one distributor, as multiple feedmill locations could be considered one distributor if owned by the same corporation.  A distributor is defined as "any person who distributes a medicated feed containing a VFD drug to another person. Such other person may be another distributor or the client-recipient of a VFD."  (21 CFR 558.3(b)(9)).  A person is defined in 201(e) of the FD&C Act "The term “person” includes individual, partnership, corporation, and association."  (21 USC 321(3)).  One distributor may have multiple locations and it is acceptable for that distributor to fill a VFD from any of its locations. 
    
    However, it is the distributor’s responsibility to comply with the applicable requirements in 21 CFR 558.6(a) and (c), including the requirement to distribute a VFD only if it complies with the terms of the VFD and the requirement to keep records of receipt and distribution of all VFD feed for 2 years.  Therefore, we would expect a distributor filling a VFD from multiple locations would have  required manufacturing records under 21 CFR 225 and VFD distribution records  under 21 CFR 558.6(c) that support that these requirements have been met. 
    
    During an inspection we will review VFD orders and compare them to manufacturing records.  We would expect that the amount of medicated feed produced to fill that VFD, whether in one or several batches would be commensurate with the amount of feed necessary for the approximate number of animals the VFD authorizes to be fed.

• The producer batch farrows. He will put Pulmotil in the lactation feed for 21 days at 181 grams per ton. Next month he will batch farrow again and want to put Pulmotil in his lactation feed. My VFD only says to feed it for 21 days at 181 grams/ton. There are no stipulations on the VFD of when the 21 day period is, so does he need another VFD each month?
  • A veterinarian must include the approximate number of animals that need to be treated on the VFD.  The approximate number of animals is the potential number of animals of the species and production class identified on the VFD that will be fed the VFD feed or combination VFD feed at the specified premises by the expiration date of the VFD.  This number can include animals that are expected to be acquired by the client as part of the normal animal production operation prior to the expiration date of the VFD.  CVM expects that the veterinarian issuing the VFD will have knowledge of the capacity and normal animal turnover of the facility and the prevalence of illnesses when issuing a VFD that would include animals that the client will acquire during the time the VFD is valid.  This provision is not meant to allow the retreatment of animals.
• Will my veterinarian have to visit every site I have to do a VFD?
  • In order for a veterinarian to write a lawful VFD, the veterinarian issuing the VFD must 1) be licensed to practice veterinary medicine, and 2) be operating within the course of the veterinarians professional practice and in compliance with all applicable veterinary licensing and practice requirements, including issuing the VFD in the context of a veterinarian-client-patient relationship (VCPR) as defined by the State. If applicable VCPR requirements as defined by such State do not include the key elements of a valid VCPR as defined in § 530.3(i) of this chapter, the veterinarian must issue the VFD in the context of a valid VCPR as defined in § 530.3(i) of this chapter  (21 CFR 558.6(b)(1)).
    
    Refer to this link to determine if the State or Federal VCPR Definition applies to a Lawful VFD in your State: http://www.fda.gov/AnimalVeterinary/DevelopmentApprovalProcess/ucm460406.htm
    
    A veterinarian would need to meet these requirements for all of the animal locations in order to issue a lawful VFD. 

• How accurate do vets need to be on their pig numbers (approximate number of animals) on VFDs?
  • A veterinarian must include the approximate number of animals that need to be treated on the VFD. The approximate number of animals is the potential number of animals of the species and production class identified on the VFD that will be fed the VFD feed or combination VFD feed at the specified premises by the expiration date of the VFD. This number can include animals that are expected to be acquired by the client as part of the normal animal production operation prior to the expiration date of the VFD.
    
    CVM expects that the veterinarian issuing the VFD will have knowledge of the capacity and normal animal turnover of the facility and the prevalence of illnesses when issuing a VFD that would include animals that the client will acquire during the time the VFD is valid. This provision is not meant to allow the retreatment of animals.​
    
    During an inspection we will review VFD orders and compare them to manufacturing records. We would expect that the amount of medicated feed produced to fill that VFD, whether in one or several batches would be commensurate with the amount of feed necessary for the approximate number of animals the VFD authorizes to be fed.

• Do veterinarians need to do anything different to purchase bulk feed-grade antibiotics for resale?
  • If you are the veterinarian and the distributor of a Type B or C VFD feed, to distribute the VFD feed you would need to follow the distributor requirements including sending a one-time notification to FDA that you are a distributor.  If you are distributing VFD feed (Type B or C) to another distributor you need to receive either a VFD or acknowledgment letter from that distributor. If you are distributing VFD feed (Type B or C) to a client then you need to receive a VFD from the client.
    
    If you are distributing Type A medicated article, that is not a VFD feed and you do not need to receive an acknowledgment letter or VFD prior to distribution.
    
    All involved parties (veterinarian, client, distributor) must retain a copy of the VFD order for 2 years. The veterinarian is required to keep the VFD order in its original format. The distributor and client copies may be kept as an electronic copy or hardcopy. If you are both the veterinarian and the distributor, keeping the original is sufficient.​

[Source: ISU]