Antimicrobial Use & Stewardship
Federal & State Policy
Livestock producers and veterinarians dedicate their lives and livelihood to the provision of high quality, safe and nutritious food for millions of Americans. Producers have a real passion and pride for their industry, from progressive ranch management and environmental sustainability, to on farm animal welfare and preventative health practices. Veterinarians have the indispensable role as stewards of animal health, animal welfare and public health. Veterinarians, livestock producers and processors follow a number of state and federal laws in order to ensure that they are producing safe and responsible food for consumers.
The following resources explain a few of the important laws related to antimicrobial drug use in livestock species that veterinarians and producers observe on a daily basis.
California Limitations on MIAD Use
According to the Livestock: Use of Antimicrobial Drugs law (FAC § 14400 – 14408), a medically important antimicrobial drug (MIAD) can be used to treat, control the spread of, and, in some cases, prevent disease or infection in livestock under the professional oversight of a veterinarian. Veterinarians may authorize use of MIADs when necessary for the following:
- To treat a disease or infection.
- To control the spread of a disease or infection.
- In relation to surgery or a medical procedure.
MIADs may be used when, in the professional judgement of a licensed veterinarian, it is needed for prophylaxis to address an elevated risk of contraction of a particular disease or infection. MIADs cannot be administered in a regular pattern to prevent disease, unless they are necessary in relation to surgery or a medical procedure. MIADs may not be administered to a healthy animal continuously beyond therapeutic need or employed as an imprudent, habitual management practice.
Medically Important Antimicrobial Drugs (MIADs)
Veterinarian-Client-Patient Relationship (VCPR)
In California, a VCPR is established when the client has authorized the licensed veterinarian to assume responsibility for making medical judgements and the need for medical treatment of the patient (including the prescription of antimicrobials) AND the veterinarian has agreed to assuming that responsibility and has communicated with the client an appropriate course of treatment.
For a valid VCPR, the veterinarian must be personally acquainted with the care of the animal(s) by way of an examination of the animal or by medically appropriate and timely visits to the premises where the animals are kept AND have enough knowledge of the animal(s) to give at least a general or preliminary diagnosis of the medical condition.
Veterinarian Continuing Education Requirement
Effective January 1, 2018, a licensed veterinarian who renews his or her license shall complete a minimum of one credit hour of continuing education on the judicious use of medically important antimicrobial drugs every four years as part of his or her continuing education requirements.
An explanation of when the first unit of CE is required can be found at the Veterinary Medical Board's website.
California VMB Approved CE Providers The California VMB requests that any provider that is not a statutorily recognized entity seek approval through the American Association of Veterinary State Boards (AAVSB) Registry of Approved CE (RACE).
Requirements for Prescriptions
U.S. FDA: Veterinary Feed Directive (VFD)
U.S. FDA: Extralabel Drug Use (ELDU)
Extralabel use refers to the use of an FDA approved drug in a manner that is not in accordance with the approved label directions.
Under the provisions of AMDUCA and its implementing regulations, the FDA recognizes the professional judgment of veterinarians, and permits the extralabel use of drugs by veterinarians with a valid VCPR under certain conditions following recordkeeping and labeling requirements. In food-producing animals, extralabel uses of antimicrobials must not be administered via feed (with an exception made for minor use/minor species), nor result in a residue that may present a risk to public health.
A substantially extended withdrawal period supported by appropriate scientific information (scientific literature, academia, or FARAD) must be established and followed. The client must maintain the identity of the animal treated, otherwise the entire group, herd or flock must follow the established withdrawal period.
Under the AMDUCA provisions, FDA has the right to prohibit extralabel uses of certain drugs in food animals if the extralabel use of the drug or class of drugs presents a risk to human health, including antimicrobial resistance.
U.S. FDA: Minor Use/Minor Species (MUMS)
“Minor use” drugs are for intended uses in major species (horses, dogs, cats, cattle, pigs, turkeys, and chickens) for diseases that occur infrequently or in limited geographic areas and in only a small number of animals annually.
“Minor species” are all animals other than humans that are not one of the major species. They include animals such as zoo animals, ornamental fish, parrots, ferrets, and guinea pigs. Some animals of agricultural importance are also minor species. These include sheep, goats, catfish, game birds, and honey bees among others.
U.S. FDA: National Organic Program
Veterinarians working with organic livestock producers have a very important role and responsibilities when treating organic livestock. Veterinarians must know what options are allowable to treat organic livestock and how to best advise the owner in order to establish and maintain their organic status and certification.
Food Animal Residue Avoidance and Depletion (FARAD) Organic Livestock Operations is a valuable resource for veterinarians on the allowable organic treatment options and considerations that must be made in order to ensure a safe food supply.
In order to be marked as "Organic" in the United States, all domestic and imported livestock products must comply with Federal regulations. The detailed requirements of all organic and crop operations are published annually in the Code of Federal Regulations