Drug residues and regulations – Dr. Dave Rhoda, University of Wisconsin-Madison, retired
Click here to download Rhoda’s PowerPoint presentation.
By Progressive Dairyman Editor Peggy Coffeen
Ensuring food safety by preventing drug residues is what matters, but how can dairy producers make this a part of their everyday protocols?
According to Dr. David Rhoda with the Wisconsin Veterinary Medicinal Association (WVMA), the Food Armor® program provides the answer. Rhoda discussed how WVMA’s Hazard Analysis and Critical Control Points (HACCP) for Proper Drug Use helps dairy producers identify risks and create an action plan that promotes a safe milk and meat supply.
“Residues are not a drug problem, they are a people problem,” Rhoda told dairy producers at the Vita Plus Calf Summit 2016.
That is why Food Armor encourages producers to identify the people involved with drug use on the dairy, and then proactively and systematically address the risks. The six-point HACCP plan includes the following:
1. Veterinary Client Patient Relationship (VCPR): This identifies a team of people on the dairy, with the owner or manager at the center. The team members include the veterinarian of record (VOR) and other consulting veterinarians, feed distributor, herdsmen or herd supervisors, and others involved in the day-to-day animal care on the farm. Having a valid VCPR provides producers the flexibility to use drugs without a vet present for every treatment.
2. Drug list: Identify all drugs specific to your individual farm, including any feed-grade antibiotics that require a VFD. Also, identify extra-label drug use (ELDU) and high-risk drug use.
3. Protocols: A proper drug use protocol spells out what to do when an animal needs to be treated. It defines the condition, drug protocols, records to be recorded and withdrawal time.
4. Standard operating procedures (SOPS): SOPs are the “how to” action steps for getting milk or meat back into the supply chain.
5. Records: Keeping a record of drug use is key to identifying drifts in procedures, verifying compliance and reviewing epidemiology of diseases on the dairy. Workers should keep treatment logs daily, but detailed, permanent records and animal identification are also necessary.
6. Oversight: The HACCP plan must be continually monitored by the VOR. Routine veterinary involvement satisfies the verification principle that validates other sections of the plan.
The purpose of this plan is to address the top three reasons for drug violations identified by the Food and Drug Administration: lack of on-farm treatment records; increased dosage without adjusted withdrawal times; and no individual animal identification.
“The FDA expects justifiable drug use,” Rhoda added.
Rhoda reinforced that, with the new veterinary feed directive (VFD) going into effect in 2017, the feed distributor should also be named to the VCPR team. December 31, 2016, is the date for VFD compliance. The first step is to choose a VOR for the farm (this vet has a new set of regulations and labels to learn) and then set up an efficient way to communicate with the VCPR team, which now includes the feed distributor, before establishing a drug plan for your dairy.
“You must secure a signed VFD from a chosen feed distributor,” Rhoda said.
He reminded dairy producers that they are the ones at the helm of seeing this through.
“The producer is the one in charge of driving this team,” he concluded.
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