Antibiotic use, regulation, and
record keeping
Matt S. Anderson, DVM
Suidae Health and Production
Algona, Iowa
When Fleming discovered
penicillin, do you think he ever
envisioned such a debate?
Tools of the veterinarian
Vaccine
Antibiotics
Host of other medications
Physicians recognize the value too
The Perceived Problem
1. Antibiotics are used in animals
2. Results in the development of resistant
bacteria
3. Resistant bacteria remain on meat through
packing process
4. Resistant bacteria remains on meat through
transport and to the retailer
The Perceived Problem
5. Consumer buys meat and resistant bacteria
remains viable through preparation
6. Resistant bacteria is transmitted to
human/human becomes infected
7. Human goes to doctor and is prescribed an
antimicrobial
8. Human does not recover
(Dr. Scott Hurd)
Manifestations
All kinds of groups with specific agendas
and initiatives
PAMPTA
GFI 209
GFI 213
VFD
GFI 209 Final Guidance for Industry
Medically important antimicrobial drugs
will be limited to uses assuring animal
health
– Loss of growth promotant claims
– Expanded carbon footprint
– Economically detrimental to producers
Decreased ADG
Increased F/G
GFI 209
Medically important antimicrobial drugs
will be limited to uses that include
veterinary oversight and consultation
– Loss of OTC drugs
– Expanded role for veterinarians in oversight
May be an opportunity but may also cost more
GFI 213
Draft GFI 213
Implementation of principles espoused in
GFI 209
Veterinary Feed Directive
Draft text
Marketing status changes
Judicious Use of Antibiotics The right antimicrobial
At the right time
At the right concentration
With the correct amount of treatment time
With the correct amount of withdrawal time
observed
With the proper records completed and
maintained
Judicious Use
Have a herd health management plan
– Supported by current diagnostics
– With a demonstrated VCPR
– Maintain accurate records for the appropriate
amount of time
Judicious Use
Producers
– We care
– PQA Plus
Veterinarians
– VCPR
– ELDU
– AMDUCA
We Care Program
Produce safe food
Protect and promote animal well-being
Ensure practices to protect public health
Safeguard natural resources in all of our practices
Provide a work environment that is safe and
consistent with our other ethical principles
Contribute to a better quality of life in our
communities
PQA Plus GPP1 Herd health management plan
GPP2 Appropriate VCPR
GPP3 Use antibiotics responsibly
GPP4 ID, track, and maintain medication
and treatment records
GPP5 Adhere to withdrawal times
GPP6 Properly store, label, and account for
all drugs
PQA Plus
GPP7 Use proper administration techniques,
etc.
GPP8-10
VCPR
21 CFR part 530
1. Vet assumes responsibility for making
medical judgments
2. Vet has sufficient knowledge of the
animals in question
3. Vet is readily available for follow up
VCPR
Non-OTC Swine labeled products requiring
a prescription (Baytril or Naxcel)
Non-swine labeled products
– ELDU
ELDU
ELDU is permitted only by or under the supervision of a veterinarian.
ELDU is allowed only for FDA approved animal and human drugs.
A valid Veterinarian/Client/Patient Relationship is a prerequisite for all
ELDU.
ELDU for therapeutic purposes only (animal's health is suffering or
threatened). Not drugs for production use.
Rules apply to dosage form drugs and drugs administered in water.
ELDU in feed is prohibited.
ELDU is not permitted if it results in a violative food residue, or any
residue which may present a risk to public health.
FDA prohibition of a specific ELDU precludes such use
AMDUCA record keeping
Identify the animals, either as individuals or a group.
Animal species treated.
Numbers of animals treated.
Conditions being treated.
The established name of the drug and active ingredient.
Dosage prescribed or used.
Duration of treatment.
Specified withdrawal, withholding, or discard time(s), if applicable, for
meat, milk, eggs, or animal-derived food.
Keep records for 2 years.
FDA may have access to these records to estimate risk to public health.
AMDUCA label requirements
Name and address of the prescribing veterinarian.
Established name of the drug.
Any specified directions for use including the class/species
or identification of the animal or herd, flock, pen, lot, or
other group; the dosage frequency, and route of
administration; and the duration of therapy.
Any cautionary statements.
Your specified withdrawal, withholding, or discard time
for meat, milk, eggs, or any other food.
FDA Inspection Great way to test your knowledge and skill
in the areas of prescription and record
keeping
These inspectors are
professional, polite, incredibly
thorough, and have a very limited sense of
humor
FDA inspection can be initiated without any
notice and for not much in the way of a
reason
FDA Inspection Pre-emptive residue avoidance??????
Demonstration of VCPR
Looked at every product in every dark
corner of the farm---2 day effort
Every label was scrutinized
Every expiration date was studied
Many questions were asked
If you don’t break the rules you’ll be fine
The Veterinarian’s 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.
Adopted by AVMA HOD in 1954
– Revised in 1969 and 1999
The Veterinarian’s 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 and welfare, the prevention and relief of animal
suffering, the conservation of animal 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.
Revised by the AVMA executive board in late 2010
Suidae Health and Production
Veterinary Clinic
Research
Management
Laboratory Services
Distribution
Building
distributorship
Production
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