FDA’s strategy for VFD enforcement: Education first
FDA’s first priority when implementing the new veterinary feed directive rule is educating and training all stakeholders, which includes veterinarians, poultry producers and feed mills.
After that, FDA says it will engage in “risk-based general surveillance as well as for-cause inspection assignments” to ensure compliance.
As part of its enforcement strategy, FDA also plans to work closely with state regulatory partners and state boards of veterinary medicine, says William Flynn, DVM, MS, deputy director for science policy, FDA’s Center for Veterinary Medicine, recently wrote.[1]
In instances where a state veterinary-client-patient relationship applies, the state may also pursue enforcement, he noted.
Initially, it’s expected that FDA will issue warning letters for minor or unintentional violations. However, major and flagrant violations could result in injunctions, seizures and possibly even criminal charges involving jail time and hefty fines.[2]
Lesser criminal violations could lead to 1 year in jail, a fine not more than $1,000 or both, FDA says. Repeat violations or violations intended to defraud or mislead could lead to 3 years in jail, fines of not more than $10,000 or both.[3]
[1] Informal communication from William T. Flynn, DVM, MS, deputy director for science policy, FDA Center for Veterinary Medicine, to Sheldon R. Jones, Farm Foundation, NFP. March 4, 2016.
[2] Seeking Clarity on Antibiotic Rules
Accessed March 28, 2016
[3] Informal communication from William T. Flynn, DVM, MS, deputy director for science policy, FDA Center for Veterinary Medicine, to Sheldon R. Jones, Farm Foundation, NFP. March 4, 2016.
Posted on October 12, 2016