Understanding the FDA Compliance Assessment
In August, the U.S. Food and Drug Administration (FDA) Center for Veterinary Medicine (CVM) released its findings for the Veterinary Feed Directive (VFD) compliance activities. The activities were conducted between 2016-2018 and involved the voluntary transition from changing all over-the-counter (OTC) medically important antimicrobial drugs used in animal feed to VFD marketing status.
According to the Guidance for Industry (GFI) #213 process, it states, “All VFD drugs, including combination VFD drugs, require authorization with a VFD from a licensed veterinarian prior to animals receiving the dedicated VFD drug. The drugs include approved uses in all major food-producing animal species (e.g., cattle, swine), and a number of minor species (e.g., sheep, fish).”
The education for the FDA compliance assessment allowed veterinarians, feed mills, producers, and retail establishments to give feedback and ask questions during the implementation. During this process, more than 200 meetings and webinars occurred with the affected parties and the CVM, allowing additional questions to be addressed about the VFD ruling.
The FDA compliance assessment is an important one to note in the industry as the increase in those facilities that put in the proper notification of their intent to distribute rose from 1,400 in 2015 to 9,600 in 2019. This number includes the facilities that are listed on the VFD Feed Distributor Notification List for all 50 states, Canada, and Puerto Rico.
Why Regular Testing and Education is Necessary
Once the FDA compliance assessment shifted its focus from education and implementation, the process of investigation by the Office of Regulatory Affairs (ORA) and other state feed regulatory program began.
In general, once the testing began, from 2016-2018, 91 percent of the VFD final codes were classified as no action indicated (NAI) — meaning — these inspections were without significant deficiencies. This indicates that the education and implementation process was pretty impactful and that most complied early on.
Moving forward, the FDA will continue to monitor compliance as some areas need more attention as indicated in the VFD inspection findings. Continued education will be provided, but enforcement strategies will be used for those when voluntary compliance is not achieved.
It is necessary for regular testing of animal grain feed in order to better understand the composition of the food. Without it, distributors, producers, and all the above-mentioned parties would not be able to accurately determine what the animals are eating and if they are consuming the adequate nutrients needed in their diets to grow at an effective rate, which includes the use of medicated and non-medicated feeds.
An ideal nutritional program for livestock — which are often fed a grain diet — consists of vitamins, minerals, fatty acids, amino acids, and carbohydrates. Additionally, an ample amount of safe drinking water is required for successful livestock production.
“Improper nutrient composition in animal feed can result in unfavorable production results for your livestock enterprise,” said Roger Beers, Barrow-Agee Laboratories CEO. “Without the proper testing methods or compliance by producers and feed mills in the industry, you are putting your business, and ultimately your customers, at risk by distributing a potentially faulty product.”
The FDA did have to administer one warning letter in 2018 for improper notification, misbranding, and adultering of VFD feed. The quality and content of your product is important, and improper labeling due to inadequate testing should never occur.
Expect Exceptional Turnaround Time with Barrow-Agee
When you work with Barrow-Agee Laboratories, not only can you expect to receive exceptional customer service, but also incredible turnaround time. When you come to our lab for testing services, we aim to have results out the door in as little as five days.
However, our on-time delivery schedule has surpassed that expectation, and we are now returning results to our valued customers in as little as two days, which is faster than comparable labs. The reason being is our proximity to FedEx in Memphis, which means we are never at a disadvantage when it comes to shipping out deliverables.
If you want to learn more about our testing services in grain proximates, please reach out. We are happy to assist in any way we can! When you are ready to submit a sample, you can review the process for our testing services here. As always, contact our lab with any of your questions, and we will be ready to support you so that you get the results you need right away!