Advocacy in action: VFD Audits (Jan 2018)

Here’s the scenario: it’s 8:15 am on a Monday morning. You’ve just walked into the back door of the clinic clutching the remnants of your second cup of coffee. As you’re checking the duty calendar, the receptionist calls back on the clinic-wide intercom, “Hey Dr Whyme, can you come up front? There’s a guy here with a badge. He says he’s from the FDA and wants to check your VFDs.”

As you walk to the front of the clinic, you notice all the half-eaten donuts and steaming cups of coffee sitting on the desks of the now empty offices of your veterinary partners. Desk chairs still twirling. As you continue your march of dread you’re at least comforted by something you recently read in the AASV e-Letter’s Doc Tales: “If you have to eat a frog first thing in the morning, you at least get to go through the rest of your day knowing the worst is behind you.”

Finally, the second longest walk of your life (the first being leaving your anatomy final wondering why in the hell a swine vet needs to be able to identify and name the pudendal artery when all you really need to know is, if ever faced with the option, don’t cut it) ends with you standing face to face with someone you’ve never seen in your life and, yep, he’s holding a badge. He thrusts out his hand (the one without the badge) and introduces himself as FDA Compliance Officer I. M. Heretohelp.

Officer Heretohelp hands you a copy of a Veterinary Feed Directive (VFD) form containing your signature and explains that he is here to conduct an unannounced “random VFD audit.” He indicates that he is coming from the local feed mill and is just following up to determine if all parties are following the proper procedure for issuing a VFD, manufacturing and distributing the VFD feed, and feeding the VFD feed. He calms your nerves slightly by assuring you that this visit is “educational” in nature to determine whether or not all parties understand and are complying with the new VFD regulations. He’s quick to note, however, that although the FDA wants to make sure everyone is comfortable with the new regulation, the agency will soon be transitioning to full-on compliance investigations. Then he asks to see your copy of this VFD.

You escort the investigator to your office where you turn on your computer and make chit-chat while it boots up to a picture of the two cutest grandkids in the world dressed up as a llama and a sheep (you still can’t tell which is which but that’s beside the point). The investigator turns down your offer of a cup of coffee, stating that caffeine tends to “make him trigger happy.” You assume it’s a joke but don’t bother mentioning you also have decaf.

As you log into your GlobalVetLink (GVL) account, you explain to Mr Heretohelp that this VFD was issued to pigs on a farm managed by your clinic, so you are actually the veterinarian and the producer in this case. After spending a few minutes explaining how that works, you provide the investigator with two copies of the VFD from your GVL account – the veterinarian’s copy and the producer’s copy. He examines both copies and compares them to the VFD and feed delivery records he obtained from the feed mill. Once satisfied that the VFD contains all the necessary information, is valid, and that the feed manufactured and delivered complies with what was requested on the VFD, Officer Heretohelp thanks you for your time and offers his appreciation for your efforts to comply with the regulation.

At 10:15 am, you’re finally standing on the doorstep to your clinic waving goodbye to the inspector, satisfied that you’ve done a good job and all the work your clinic put into ensuring VFD compliance has paid off. With a smile on your face and a spring you haven’t had in your step since your last colonoscopy, you walk back down the hall to start your day. Amazingly, you notice that all of your partners have miraculously found their way back to their offices. Shaking your head, you grab your coffee mug and walk into the break room only to find an empty coffee pot and no donuts. Heads are going to roll!

This has been a realistic, although admittedly somewhat stylized, description of a typical FDA VFD inspection as has been recounted to me by a number of our AASV members. The FDA continues to conduct training and educational audits of all parties subject to the VFD regulation (veterinarian, feed mill-distributor, and producer) to evaluate compliance. In discussions with FDA, it has been reported to us that compliance among swine veterinarians has been very good, with no major or systemic compliance issues. If you have questions regarding the VFD, we have a number of resources available on the AASV Web site (https://www.aasv.org/aasv%20website/Resources/Antimicrobial%20Use/VFD.php) or you can submit your questions directly to FDA at AskCVM@fda.hhs.gov.

Harry Snelson, DVM
Director of Communications