We know one thing to be true: life in agriculture is always changing. Some of these changes we can prepare for more than others and we must always look ahead. In June 2023, new prescription labels will be placed on medically important antimicrobials that you are used to getting over the counter. You may recall back in 2019 that the FDA began requiring a Veterinary Feed Directive for all medically important antimicrobials used in livestock feed or water under FDA Guidance GFI #213. This transition of over-the-counter antibiotics to prescription is an expansion of that known as GFI #263.
So what does this mean for me exactly?
Drugs such as penicillin and tetracyclines (such as LA-200® and generics) will now only be available with a prescription from a veterinarian, only to be used when necessary for the treatment, control, or prevention of specific diseases.
Why is this being done?
Antibiotics have restrictions placed upon them for 2 main reasons: to help ensure safe and wholesome food supply and to help ensure that they remain effective. As goat owners, I don’t need to tell you the story of anthelmintics (dewormers). They have long been overused, the parasites developed resistance mechanisms, and now we are in a situation where the drugs no longer work as they did initially. The situation with antibiotics is similar. They have mechanisms to kill bacteria and the bacteria have multiple capacities to learn how to get around those mechanisms. By only using antimicrobials when they are medically necessary, not just-in-case, you are helping to ensure that the bacteria your animals are exposed to can be treated when needed. This also helps to reduce the likelihood of antibiotic-resistant bacteria contaminating food products from livestock. Another goal of responsible antibiotic use is to ensure that withdrawal times are observed so that residues of the drug do not appear in food products.
Why do we have to go through this when we are doing things right at our farm?
It is always frustrating to be subject to new rules and regulations, especially when you’re doing things right. Unfortunately, with increasing regularity, people are using drugs in goats and other livestock in ways they are not labelled for and are not observing food product withdrawals. Recently, a list of the most common violative residues found in goats at slaughter was published and included, among many drugs,
a dewormer (moxidectin or Cydectin®), an anti-inflammatory (flunixin or Banamine® and its generics) and the antibiotics ciprofloxacin, enrofloxacin (both from Baytril® use), oxytetracycline (Liquamycin® LA-200 and its generics) and penicillin. It’s worth noting that any use of Baytril® in a goat is illegal. So, when residues like these show up, it brings attention to the industry and opens all of us up to increased scrutiny.
What do I need to do to get ready?
First, you should make sure you have an established, ongoing relationship with a veterinarian. This doesn’t mean they did a C-section for you 2 years ago in the middle of the night. The legally defined Veterinary-Client-Patient-Relationship (VCPR) which must be established for writing prescriptions states that the veterinarian has knowledge of the herd of origin of the animal and sufficient knowledge of the animal to make at least a preliminary diagnosis of the condition. It is a regular event for veterinarians to have clients get frustrated with us that we won’t just sell a bottle of a prescription drug without seeing the animal. A VCPR can be established in different ways, including in-person visits to a farm or ranch at regular intervals, written protocols for disease identification and treatment on the farm, and seeing an individual sick animal and making a diagnosis. When a goat owner calls me for advice and all I’ve ever done for them is that 2 a.m. emergency C-section, we don’t have a relationship and shared knowledge that allows for me to dispense advice or drugs. If, however, I have seen a number of animals for this producer and been to his or her facility and seen firsthand how they operate, I am in a much better position to help them over the phone when needed. This is where having a “daylight relationship” with a veterinarian can really save you money in the long term.
If you have an established, regular relationship with a veterinarian, have a conversation with him or her now to see how they will be handling this rule change in their practice. If you do not have a veterinarian, I would suggest scheduling a farm visit and begin the process towards having an established relationship.
Next, and your veterinarian can help you with this, evaluate your overall management plan to determine if there are places where more can be done to prevent infections and therefore reduce overall antibiotic use. Are all classes of animals receiving and consuming adequate trace minerals? Are you fully vaccinating against diseases that are a risk to your herd? Are things like coccidia well controlled in your young animals so that they are not immunosuppressed and more susceptible to things like pneumonia? With a good herd health plan in place, farms often find that they can get away with minimal to no antibiotic use.
What if I don’t have a veterinarian who knows anything about goats?
I hear this a lot from goat owners, whether they raise meat or dairy goats. There are a couple of suggestions I would make here. First, it’s worth an honest conversation with the veterinarian about their willingness to work on goats and their personal comfort in working with them. Some veterinarians may not have had a lot of exposure to goats in school or in their time in practice, but are willing to learn. A little patience and an open-mind can go a long way in establishing a mutually beneficial relationship between farm owner and veterinarian. Llama and alpaca farms know all about this. When these animals were first being imported into the US, no veterinarians here knew anything about them. These farms invested, and many continue to do so, in helping veterinarians learn about their chosen farm species. They hosted farm days for veterinarians to come examine their animals, hosted veterinary students, sponsored veterinary students to train with camelid veterinarians, gave scholarships, etc. I’m not saying you need to develop a foundation with a veterinary training program, but the concept is there: choose to see that there is room for the exchange of ideas rather than simply throwing up your hands in defeat. I will give you this ray of hope: I travel and give presentations all over the country at about 8-10 state and national veterinary conferences every year, many of them about goat medicine, surgery, and preventative care. The rooms are always packed with veterinarians. There are veterinarians who are willing to learn and serve.
Remember, we can’t predict or control everything that comes our way in agriculture. The weather, fuel prices, etc., all out of our hands. But we do know this is coming and there’s a straightforward path to making sure we are ready for it:
- Develop a relationship with a veterinarian such that they have a working knowledge of your place and can work with you to achieve your animal health goals. If you want to use a veterinarian less in the long run, use them more in the short run.
- Follow all directions as prescribed and only to the animal or animals for whom it is prescribed.
- Follow the prescribed withdrawal times for all food products.
The following link from the Food and Drug Administration addresses some common questions regarding GFI #263: