The balance between ensuring a safe food supply and potential overburdening regulations is a timely concern that is generating discussion among dairy producers. What is the concern? Implementation of the Food Safety Modernization Act (FSMA, pronounced Fiz-Ma) and the Veterinary Feed Directive (VFD) and its potential impact on dairy producers. The quick answer to the concern is the impact of the VFD will be felt more than FSMA by dairy producers. So what are they and how are they the same or different?
What is the reason for these regulations?
Both regulations have been enacted to further improve the safety of our food supply. Yes, the United States has one of the safest food production industries, but perspectives are changing and there is room for improvement. The two regulations address food supply safety but with different objectives. FSMA was passed in 2011 with the intent of preventing foodborne illness in the United States and protecting the public. FSMA targets 7 aspects of the food system continuum. In addition to produce production, FSMA also includes Preventive Controls for Animal Food for both production and pet animals. The Veterinary Feed Directive seeks to provide oversight on the use of antibiotics in animal feeds given the ever increasing concern about antibiotic resistance. The Food and Drug Administration (FDA) will look to the VFD to guide producers to properly use certain antibiotics in animal feeds by requiring more direct oversight by the herd veterinarian.
Who will they affect?
The FSMA Preventive Controls for Animal Food regulation applies to most facilities that manufacture, process, pack, or hold animal food with some exemptions. Regulations are focused on large manufacturers and feed mills and will not affect individual dairy producers mixing feed on their farm as long as it is only used to feed animals at that location or on another farm under the same ownership. Essentially FSMA will expect feed manufacturers to be more proactive in controlling potential feed adulteration hazards by implementing risk-based preventive controls and current good manufacturing practices. Implementation of these protocols may improve feed mill production of animal feeds and further reduce any potential for mixing errors leading to potential cow health issues on your farm. Dairy farms that manufacture or process dairy products should consult the regulation for Preventive Controls for Human Foods.
The VFD more directly affects livestock producers, veterinarians, and feed suppliers in varied capacities. At the crux of this regulation is the need for dairy and other livestock producers, including bee keepers, to establish a valid veterinarian-client-patient relationship (VCPR). A valid VCPR requires the veterinarian to have direct knowledge of the animal care and management for a given farm. The VFD intent is to move more antibiotic usage for animal care under the guidance of the herd veterinarian. Both government and pharmaceutical industry are cooperating in an effort to reduce antibiotic usage, which ultimately should reduce the already low rate of violative tissue residues and the specter of antibiotic resistance. Under the VFD, dairy producers will work together with their herd veterinarian to determine when antibiotics should be used and which antibiotics are appropriate. A VFD order or prescription for a medicated feed from the herd veterinarian will be required in order to purchase it from a mill, retailer, or other supplier. It must be remembered that feed medications cannot be used in an extra-label manner, even under veterinarian direction. Now the VFD does not regulate all medications available for dairy cattle, but only those antibiotics of medical importance for humans. This means the feeding of monensin as currently allowed is not covered under the VFD, as this is not a medically significant human medication. However, use of medicated milk replacers or calf starters containing antibiotics other than ionophores will require a VFD prescription from the herd veterinarian. Resources for additional information on the facilities covered under FSMA are listed in the reference section of this article. Information about the medications covered by the VFD can be found there as well.
When will they be implemented?
The first compliance dates for the Animal Food portions of FSMA passed on September 19, 2016. Additional compliance dates are staggered over the next several years and are dependent on the size of the business. The VFD will be implemented beginning on January 1, 2017. The American Association of Bovine Practitioners has been providing informational forums for practicing veterinarians and much resource information.
Who is responsible for overseeing these regulations?
The FDA is responsible for the oversight of FSMA and the VFD; however, cooperative agreements may be arranged with other agencies to assist with this task.
For additional information about the FSMA Preventive Controls for Food for Animals or the Veterinary Feed Directive, please consult the resources listed below.