Rambling thoughts...
VFD only applies to antimicrobials mixed into feed... has no impact on injectible/topical/oral products. ONLY specific antimicrobials mixed in feed.
I attended a 3-hour session for veterinarians on the VFD last night, put on by Zoetis & Burkmann feeds. It was helpful, but there will continue to be new questions that pop up between now and when this thing takes effect on Jan 1... and well beyond that point.
I can promise you, there are very few, if any, veterinarians who are looking at this new government regulation as a 'cash-cow'... for most of those folks, it's just another government intrusion into their business, with a whole new set of paperwork that they have to keep on hand for the following two years, and they're open to FDA inspectors showing up to examine their records, unannounced, at any time.
I've spoken with several of my colleagues who've just said, "I'm not going to do it; I'll never write one. Period."
It was NOT a regulation requested by or driven by veterinarians... if you feel the need to point fingers... look at 'consumers'... and at folks (producers & veterinarians alike) who have misused/abused these products.
FDA claims that this reg is not intended to decrease use of antibiotics in feed... but to ensure that when they are used, that they are used correctly. Sounds good... but, they're from the government, and they're here to help us, right?
You can 'stockpile' all you want between now and 1 Jan 2017... but after that date, if you feed it without a valid VFD... you're not in compliance. FDA could potentially come down on you. Presenter last night made the analogy... you can grow and possess all the marijuana you want... but you can't smoke it without being in violation of the law...
First year or so, FDA says they're mainly gonna be 'educating' producers/veterinarians/distributors who are found to be in violation... unless you're committing fraud, in which case they'll nail your hide to the wall... but after that, they likely will get tougher on reinforcement.
Repeal? Not likely. At all.
A VFD will require, as its first point: a valid Veterinarian/Client/Patient Relationship (VCPR). A veterinarian following the 'letter of the law' will be required to have an actual knowledge of you, your animals, your facility/farm. If you don't already have a good working relationship with a veterinarian... you're going to have to develop one... If you don't have one... how much time is that veterinarian going to have to spend with you/on your farm to truly have that VCPR and to be able to write, distribute, file those VFDs... 'time' is that veterinarian's most limited commodity...somebody's gotta pay for that time... and it's gonna be the producer who needs that feed additive.
Additionally, veterinarians won't have 'carte blanche' to prescribe just anything... there are limitations on what antibiotics can be used in certain classes/species of animals (for example, NONE are approved for incorporation into feed for sheep/goats), what concentrations of any given drug can be mixed, how long it can be prescribed to be fed, what conditions it can be prescribed for... and some combinations of drugs are not allowed.
If you, as a producer, are accustomed to mixing your own feed with, say, Aureomycin at XX concentration, you may no longer be allowed to do so, if that concentration is not allowed by FDA... 'cause your vet cannot write a VFD for that level. Oh, and if you're mixing your own feed... FDA has access to you on two levels - both as the producer and as the distributor/manufacturer... and your paperwork had better be in order when that FDA inspector shows up.
And, let's say, if you routinely mix a feed with Aureomycin and Rumensin in it... that combination is not approved, and your vet cannot write a VFD for that. Etc., etc., etc.
