The Food and Drug Administration (FDA) recently announced its intention to screen farm bulk-tank milk for a number of compounds other than the beta lactams required by the Pasteurized Milk Ordinance.
This decision is at least partially the result of a pattern FDA sees when analyzing drug tissue residues at slaughter. In the last five years, approximately 7.7% of the adult cattle slaughtered in this country were dairy animals. However, dairy cattle were the source of some two-thirds of tissue residues detected at slaughter.
It appears that FDA will begin testing this winter and continue through September 2011. During this time, the agency will sample some 900 dairies. It will test for 27 different compounds that represent a wide range of antibiotic classes as well as flunixin and thiabendazole.
FDA is apparently selecting the dairies based on a risk analysis it is conducting. One of the risk factors it will consider is whether there have been prior residue issues on a dairy. So if you have had an issue, it is important to make sure that things are in order. Even if you are not at high risk of being sampled and audited, the following are some points you should review:
- Anyone involved in diagnosing and treating animals needs to be trained and knowledgeable regarding your dairy’s diagnostic and treatment regimens.
- Treatment protocols need to be written down. Ask your veterinarian for help in developing, reviewing and documenting these protocols.
- Make sure your drug inventories for both lactating and non-lactating animals on your dairy match those used in your protocols. Again, make sure your veterinarian as well as your drug suppliers and employees understand how important this is.
- Follow label directions for dosage, route of administration, withdrawal times and diseases treated. If you deviate from the label, do so with the proper extra-label drug use protocols in place. This starts with having a true veterinarian-client relationship. Extra-label usage is not legal unless a veterinarian is involved.
- Keep good records. Shipping animals without proper withdrawal times and shipping or milking the wrong animals because of poor identification or control are probably the most common problems.
- This point also involves keeping good records. When there is an issue, even one that resulted from a treatment that happened when the
- animal was a heifer, the expectation is that your animal ID system will allow you to trace it back to the offending incident. If not, you are not in compliance.
- If you are contacted and sampled, it is essential that you work with your milk handler to make sure the screening process on your dairy doesn’t have wider impacts. If a residue is detected and the milk has already been processed, the FDA and state regulatory authorities are required to conduct additional risk assessment. They need to determine the potential impact the residues might have on additional product, up to and including product recall.