Veterinary relationships and drug regulations
Veterinarians in both small and large animal medicine have been facing economic pressures along with owners and producers alike. Companion animal specialists are expected to sign off on prescriptions for common medications and preventatives that once were readily sold (conveniently, I may add) through their own clinics—but now are ordered readily online. Legislation is offering the idea of forcing these same veterinarians to write obligatory prescriptions for EVERY medication—whether it is dispensed or not through their clinic!
Regulations between political and professional organizations can appear burdensome at times, but these policies are put forth in order to ensure the safety of our animals, people, and food supply.
The Food and Drug Administration (FDA) has also tightened regulations on drugs often used in food producing animals. New testing methods instituted by the Food Safety Inspection Service are able to scope out a broader array of residues. The American Veterinary Medical Association has also approved recent modifications within the Veterinary Practice Act regarding the veterinarian-client-patient relationship (VCPR) standing.
The VCPR is a relationship between a veterinarian, his or her client, and the pet or herd cared for by said client. As FDA defines the VCPR, the veterinarian assumes responsibility for making the medical judgments pertaining to preventative care and ill-health concerns for the animals owned by the client; the client also has agreed to abide by the instructions of their chosen veterinarian. The veterinarian (or member of the coordinating practice) must also be readily available for follow-up regarding patient cases and in situations where adverse reactions may have occurred.
Routine visits with patients help a veterinarian keep on top of medical advice and treatments indicated, as well as aiding the appropriate documentation for patient medical records. All patient records are required to be filed for two years (either by the veterinarian or the producer) in case of an FDA investigation.
Concern among some veterinarians still exists pertaining to the use of ‘extra label’ drugs. The withdrawal time for these types of medications can enter a “gray zone” rather easily. Consulting with your veterinarian is the best way to ensure that your herd is complying with all of the nec-
essary FDA standards and protocols. The typical order of events include: a medical diagnosis, selection of an appropriate medication for treatment, and applying a reliable withdrawal time for food or milk products.
The most recent legislation regarding the VCPR has allowed some states to consider “sufficient knowledge” of a pet or herd health status to be examined by analysis of health papers or production records. This has sparked concern with producers and veterinarians alike, who feel that animal examinations are necessary for appropriate therapeutic decisions. Producers are often targeted for making the mistake of not having a VCPR in place; FDA indicated recently that approximately 59 percent of residue violations investigated have occurred on operations that were not following advice from a veterinarian. Both flunixin and penicillin are at the top of the list of most commonly identified residues.
Using medications off label and simply adding a few days or weeks to the withdrawal time will likely result in violations at some point as the assessment of elimination and half life of the drug in question is needed for accuracy. Residues may also occur due to the drug being administered in an off label method, such as an intravenous injectable that is given subcutaneously or intramuscular. Animals being treated with off-label medications must be identified via methods such as ear tags, record-keeping or nameplates.
These preventative measures are meant to keep animals from inadvertently entering the food chain with medications still in their systems and tissues.
Veterinarians can be allowed to legally use some drugs to reduce animal suffering and improve animal welfare—these drugs are not approved, but permission is granted due to the Animal Medicinal Drug Use Clarification Act (AMDUCA). However, AMDUCA does require that a labeled drug be used first for therapy, and if off label drugs are used for better efficacy—they must be approved for usage in food animals. All off label drugs can only be used therapeutically, not for feed efficiency, synchronization or other production parameters.
More information on drug residues can be obtained from the Food Animal Residue Avoidance Databank at www. farad.org. — Dr. Genevieve Grammer