Residue Prevention Systems
Best Management Practices for Drug Residue Avoidance
(from Food Safety/Drug Residue Avoidance Module of NYSCHAP)
- The farm has a valid veterinarian-client-patient relationship (VCPR) in place:
Proper drug usage on the farm:
- A veterinarian regularly visits your herd and consults with you about animal management and health issues.
- A veterinarian is readily available for follow-up in case of adverse reactions or failure of treatment.
- The veterinarian and producer have established an approved drug list.
- The veterinarian establishes and reviews antibiotic use protocols in conjunction with the producer/farm management team.
- Only FDA – approved drugs are used to treat animals.
- All drugs on the dairy have proper labeling with copies of drug inserts and/or product labeling being followed and available.
- Only drugs that are approved and labeled for designated herd groups ie. lactating cattle, non lactating cattle (less than 20 months of age) or other herd groups (e.g. bob veal calves), are use in those herd groups, and only those herd groups.
- Only a veterinarian can prescribe drugs in an “extra-label” manner.
- A farm specific list of current over-the-counter and prescription drugs that can be used on the dairy has been developed.
- Drug withholding times for milk and meat are followed and documented as such in written records.
- Minimize the number of people administering drugs on the farm to prevent miscommunication.
- A record system is maintained for all treated animals.
- Treatments are recorded immediately after completion.
- ALL treated livestock (regardless of age or use), are identified after treatment.
- Treatment records are kept for at least two years (State or local regulations may require a longer record retention time).
- Drug label and insert directions are followed and the following information is recorded:
- Identity of animal(s) being treated
- Route of administration
- Dose of administered
- Person(s) administering
- Date of administration
- Reason for administration
- Drug administered
- Meat and milk withhold times
- Specific dates when meat and milk can be used for food
- If a veterinarian prescribed/recommended administration
- Find example of drug insert at http://www.drugs.com/vet/excede-sterile-suspension-for-cattle.html
- Treatment records are reviewed with veterinarian and used to improve management of potential hazards and to reduce risk to milk quality.
- Drugs for Lactating and Non-Lactating animals are stored separately.
- Drugs are NOT stored/held in the milk house.
- Expired drugs are removed from inventory.
- No prohibited drugs are kept on the farm, or used, on food producing animals. http://www.farad.org/eldu/prohibit.asp
- Prescription products are labeled appropriately, including name and address of the prescribing veterinarian (with which the herd has a veterinary-client-patient relationship).
- Any Veterinary Feed Directive (VFD) feeds on the dairy are stored in such a way that an accidental use cannot occur.
- It is understood that extra label drug of VFD drugs in animal feed is prohibited.
- A drug (including a bulk drug) may not be mixed with feed for any use or at a potency level not specifically permitted by FDA regulation (21 CFR Part 558), even if prescribed by a veterinarian.
- Milk from dry-cow treated cows that freshen early is tested for residues prior to marketing.
- Milk from newly purchased animals is tested before adding their milk to the bulk tank.
- When a cow is treated in an extra-label manner, test the milk for residues. When using bulk tank tests on individual cows, consult the manufacturer’s directions to ensure applicability.
- Complete a premarket/slaughter checklist before any animal is sold to market to review treatments and withdrawal periods to assure she is clear of drugs.
- Recommendations from the veterinarian are reviewed with employees and/or family members.
- Employees and/or family members receive regular training on the prevention of milk and meat residues.
- Treatment records are checked before marketing animals.
- Employees and/or family members are trained on protocol of handling treated animals ie. milking last, keeping their milk from saleable milk.
Precautions while administering drugs
When treating animals with any product that is given IM, SC, IV, or intramammary (IMM), take the following precautions:
- Read product label and insert, and consult your veterinarian before administering drugs.
- Use a clean injection site and use a sterile needle for all injections.
- Use the label dosage and method of administration least likely to create a residue.
- Discard milk from all four quarters even when treating only one quarter with an IMM infusion.
- Milk treated cows last or use a segregated facility (divert milk from bulk tank or saleable milk).
- Thoroughly wash all equipment (inflations, hoses, weigh jars, etc.) that has come in contact with milk from treated cows.
- Make certain that any procedure used to divert milk from treated cows cannot accidentally send contaminated milk into the pipeline.
- Keep medicated feeds separated from non-medicated feeds.
- Ensure that calves fed antibiotic waste milk are not sent to slaughter until withdrawal times are met.
- Train employees on proper injection site selection.
Producers should keep records on all animals treated with drugs for 2 years. The record system should be easily accessible to everyone who works with the animals and made available to government agencies when requested. Records should be permanent so the veterinarian has a history to which he/she can refer to prescribe effective therapy and to serve as protection in case of regulatory follow-up. The producer needs to be able to show how all drugs purchased were used or disposed. The treatment record should contain, at a minimum, the following information:
- Treatment date
- Animal identification
- Route of administration and expected duration
- Withdrawal time for milk and meat
- Individual who administered the drug
- Drug used
- Duration of therapy
Veterinarians should maintain records of what they are selling to their clients as well as protocols created for the client. This gives the veterinarian a history to which he/she can refer to prescribe effective therapy and to serve as protection in case of regulatory follow-up. NYS Department of Education requires records be kept for 3 years.
AMDUCA: The FDA requires veterinarians to maintain records for two years of all animals treated using extra-label drugs (21 CFR 530.5). NYS Department of Education requires records be kept for 3 years. http://www.op.nysed.gov/prof/vetmed/vetpgintro.htm
VFD: Three copies of the VFD will be issued by the veterinarian: one for their own records, one for their client and one to the client’s VFD feed distributor. Recordkeeping for VFD can be either written or electronic and must be retained for 2 years per federal guidance, 3 years per NYS guidance. VFD’s can be generated and handled electronically. More information on the veterinarian’s requirements for the VFD can be found at 21 CFR 558.6
- Drug Residue Risk Assessment
- 8 Steps for Keeping Records
- Animal treatment plan: an example of a written protocol to review with your veterinarian in the context of a VCPR specifying what condition the drug is used for, dose, route, length of treatment, withdrawal times, etc.
- Recommended Drug List for your Operation
- Daily Treatment Record for a herd: indicates which animals were treated for which conditions, at what time, withdrawal times, etc.
- Premarketing/slaughter checklist: prevent drug residue mistakes by double-checking that these conditions have been met
- AVMA/AABP: Guidelines for veterinary prescription drugs
- NYS Department of Education, Office of Professions, Practice Guidelines
NYSVFRP Sections: 1 2 3 4