Dakotaland Feeds LLC staff nutritionist Roxanne Knock says the biggest change for feed mills will be the record-keeping requirements the FDA requires. Their manufacturing process should remain the same since they already follow the FDA’s feed additive compendium.
“We have had to notify the FDA that we are going to distribute VFD-containing feed, and any retailers are going to have to notify the FDA that they are going to distribute VFD-containing feed,” Knock says. “It’s going to be an extra layer of record-keeping."
"We are either going to have to keep the VFD or keep a letter from the distributor saying that they won’t let the feed out of their door without a complete and valid VFD.”
The FDA requires three copies of the VFD – one for the producer, one for the veterinarian and one for the feed retailer. Those documents need to be kept for two years.
Dakotaland Feeds – which has mills in Huron, Kennebec, Cavour and Herreid, South Dakota, and Glen Ullin, North Dakota – is owned by Purina Animal Nutrition, North Central Farmers Elevator and South Dakota Wheat Growers. The Cavour and Kennebec locations are primarily grind and mix locations.
The mill in Huron is a pelleting and mineral manufacturing facility. The Herreid mill is solely dedicated to supplying feed to PIC’s hog unit in Mound City, South Dakota. The Glen Ullin mill is a pelleting facility. Knock estimates their mills sent out more than 100,000 ton of feed over all facilities last year.
Currently, their mills are inspected at least annually by the FDA. With the VFD regulations, for feed mills the more medicated feed they put out, the more likely they will be inspected on a more frequent basis.
Knock says the company has had producer meetings to at least get the VFD on producers’ radar.
“We’ve been trying to tell our customers about this beforehand to at least get them aware of it because it doesn’t have to be a terrible, terrible problem. Where it’s going to be a problem is where somebody hasn’t been proactive because the producer has to have a vet-client relationship,” she says.
Knock says producers will need a relationship with a veterinarian in order for the vet to write a VFD for them. Knock’s company has been encouraging producers who have not been working with a veterinarian to start so they are ready for the Jan. 1, 2017, implementation date for the VFD.
“If you’re proactive, have a relationship with your vet and can get it set up ahead of time, it doesn’t have to prolong the process or make it that much more difficult to use medicated feed,” Knock says. “A lot of producers are worried it’s going to be so much more difficult to use it.”
Knock says the VFD will not change how the feed mill manufactures medicated feed or the way the producer uses it. The VFD adds the extra record-keeping requirement and the veterinarian involvement.
Prior to the VFD going into effect, feed additives like aureomycin, oxytetracycline and tylan were over-the-counter.
“The FDA’s whole point behind this is the veterinarian is supposed to have an idea of the proper dose, duration and when it’s appropriate to use these products and to try to safeguard against antimicrobial resistance,” she says.
If a veterinarian writes an approved use on a VFD, the feed mill is not to fill that invalid VFD. If the feed mill filled an invalid VFD, they would be subject to a fine as well as the veterinarian, and if the producer fed it, the producer would face a fine, too.
“The best thing would be for people to not ask their veterinarian to do the things that are illegal. It’s easiest to just do things right,” Knock says. “The FDA can consider them adulterated if they’ve been fed an illegal VFD without a valid VFD. When you have adulterated anything according to the FDA, you’ve got a big problem.”
Wendy Sweeter is a freelance writer based in South Dakota.
PHOTO: Feed mills, such as this facility at Dakotaland Feeds, will face tougher regulations on record keeping in association with the Veterinary Feed Directive. Photo provided by Wendy Sweeter.