Milking Center Management: Residues and FDA

November 17, 2010 07:23 AM

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.

2. Know what you are treating. You do not need a veterinarian involved in every animal that requires treatment. However, you vet is the perfect resource to help make sure that someone on your dairy knows how to do a proper examination and diagnosis.

3. Develop treatment strategies that are based on good, sound medical judgment and stick to them. This ensures not only the highest treatment success but also that you are not squandering money and resources on treatments that are at best a waste of money and time.

4. Observe proper withdrawal periods. Once you deviate from label directions, the stated withdrawal time for meat and milk are no longer valid. For each extralabel treatment strategy, you need to document the likely withdrawal period. Your veterinarian has access to a resource called FARAD that can help with this. If you can’t establish a withdrawal period, don’t use the product.

5. Document the process. At the very least, establish a log of animals treated and what they were treated with. This is one of the first things the FDA will ask for if they visit. In addition, it’s a good idea to list the medical conditions you are treating and establish written treatment protocols.

6. Establish ongoing training for employees that are involved and monitor regularly for compliance.

7. Do not use drugs, for any reason, that are specifically identified as not to be used on dairy animals.

Efforts to develop a solid program help the industry maintain the tools it needs to keep animals healthy. As importantly, it frequently results in an economic benefit to the individual dairy by increasing treatment success while reducing overall drug use.

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