As previously discussed, dairy farmers seem to be under increased scrutiny by the FDA for medicating their cattle without following prescribed laws governing such practices. To avoid violating federal law, dairy farmers should consider incorporating the following tips in the management of their herds:
- Implement a system to identify new additions to the herd to readily enable tracebacks to herds of origin, including individual animal identification;
- Before entry into the herd, identify any prior treatments and vaccinations received, and potential or actual disease exposure that had occurred;
- Restrict medications to those labeled for the specific use intended, or as prescribed by a veterinarian, in writing, with withdrawal times indicated;
- Record medications used on specific animals, including date, dosage, route and duration of treatment, condition treated, and required withdrawal time;
- Identify and segregate treated animals until treatment is complete AND the withdrawal time has elapsed, to prevent animals with drug residues from entering the food supply;
- Maintain legible treatment and animal records;
- Store medications, needles, syringes, and other dispensing equipment in a clean, dark, and temperature-appropriate area.
- As specifically recommended by FDA, “take appropriate measure to assure that assigned timeframes for withdrawal are met and no illegal drug residues occur in any food-producing animal subjected to extralabel treatment.”
Should a farmer recieve a warning letter from the FDA, a complete review of existing farming practices is advised, and a detailed response to the letter should be promptly returned, with documentation of the steps taken to change deficient practices identified.