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Milking Center Management: Residues and FDA

November 17, 2010
By: Mark Wustenberg, Dairy Today Contributor

Bonus Content

Spanish translation

Food Animal Residue Avoidance Databank

NMPF's Drug Residue Prevention Manual

"Dubious List"

* Extended comments are highlighted in blue.

Last winter, I wrote about the Food and Drug Administration’s (FDA) increased interest in drug residues in meat and milk (“Dubious List,” February 2010). I pointed out that FDA publishes a list of drug residue violators including the individual or farm’s name and type of drug used.

A recent review of this list raised the following questions:

1. Why are virtually all the meat residues showing up in animals of dairy origin (either adult dairy cattle or veal)?

2. Why are we seeing residues for drugs that should not be used in dairy animals?

3. If we are seeing these kinds of residues in meat, is our system for screening milk adequate?

Currently, FDA is stepping up efforts to do follow-up field visits when a violation occurs. In addition, there is a distinct possibility that this issue will become a much more public discussion.
Our customers and consumers are not well educated on this issue and already have strong misconceptions, particularly regarding the amount of antibiotics used in the dairy industry. There is also a widespread misconception that milk routinely contains residues of the drugs we use.

We need to take this issue very seriously as an industry or we are going to find ourselves with a much more restricted ability to manage animals that require medical care. In addition, we are simply fueling the misconception that our current management systems are somehow inherently unhealthy for the animals we care for. The good news is that we know the solution and it is entirely within our control to implement it. The first step is to get your veterinarian involved.

One of the premises of prudent drug use is establishing a meaningful veterinarian-client relationship. This does not mean that a vet has to treat every animal that needs medical attention on your dairy.

The regulations state that a valid veterinarian-client relationship must exist when drugs are used in an extra-label manner. That means any usage, dosage or treatment strategy that is not explicitly stated on the label. Most, if not all, dairy operations use drugs extra-label.

This is not bad in itself. However, once you deviate from the label instructions--whether it is using a nonlactating drug in a lactating animal, dosing at other than label dosage, treating for longer than on the label or treating medical conditions not on the label--you are taking sole responsibility and you need to have a justified basis for your actions.

There are a number of ways that your veterinarian can help as a resource, so get him or her more actively involved:

1. Learn to recognize animals early that require medical attention. On the flip side, learn to recognize situations where the chances of treatment success are poor, and develop alternatives.

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FEATURED IN: Dairy Today - December 2010

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