On October 12, 2017 Nestlé USA announced that by 2024 they would

“strive to source all of the broiler chickens we use as ingredients for our U.S. food portfolio from sources meeting a higher standard of animal welfare, building on our global Commitment on Farm Animal Welfare.”

More specifically, Nestlé has committed to sourcing from farmers who raise chicken with slower growth rates, good leg health, reduced stocking rates, and further compliance with standards approved by the Global Animal Partnership (GAP), a non-profit “registered as a 501(c)(3) non-profit organization and brings together a diverse group with the common goal of improving farm animal farm animal welfare standards around the world.”

Nestlé acknowledges that this commitment is “complex,” “require[s] investment and time, and the transition over the next seven years must be done in a sustainable and cost-effective way.”

There are six different levels or steps in GAP standards, that increasingly require significant investments by farmers who must modify their existing housing facilities and decrease the number of animals that can be raised in the existing space.

One of the concerns about laws that require changes to husbandry standards for farm animals are the related costs.  For example, California’s 2008 ballot initiative, Prevention of Farmed Animal Cruelty Act (“Prop 2”), funded in large part by the Human Society of the United States, requires egg-laying hens, veal calves and hogs to have sufficient room to lie down, stand up, fully extend their limbs, and turn around freely in their enclosures.

Despite the passage of Prop 2, HSUS is once again leading the effort to require additional changes to the law in California.  The recently proposed initiative would prohibit all sales of veal or pork in California unless produced in a manner that complies with California’s law.

The proposed initiative would also require that all eggs produced and sold in California must come from cage-free birds as of December 21, 2021.  The farmers in or outside of California who had modified their former housing systems to be in compliance with Prop 2 will now have to make additional significant investments in their housing systems again.  Such required continual modifications of animal housing facilities are not cost-effective nor sustainable.

Perhaps this is the point, since the goals of HSUS and many other animal rights organizations are to eliminate animal agriculture entirely.

 

As reported by Texas Department of Agriculture the following needs for livestock have been identified:

Donation of Hay and Feed:
The Department is currently working with Texas A&M AgriLife for donations of animal hay and feed. If you would like to donate hay, please call, text or email the TDA staff listed at the number listed below and let us know where the closest drop off location is for you. In your message, please provide your name, phone number, location and type of hay or feed to be donated and whether you have transportation.

Transport
Please note that we do not have transport but we are maintaining contact info for hay donors in the event we get offers for transport or others in your area who may be able to pick up hay. If you have transportation services that you can offer to help bring hay to the Coast from throughout Texas, we need your help! Please give us a call.

Pasture
If you have pasture, please contact us with your information to be put in our database for those who need help. If you are in need of pasture space, please contact us and we can provide information for someone with pasture who may be closest to you and provide assistance.

Water Troughs
If you have water troughs to donate, please contact us for donating those as well. Several of the supply points are in severe need for those.

Contact Jessica Escobar at (512) 803-7847 or Jessica.Escobar@TexasAgriculture.gov if you can help.

Southwest FarmPress reports that hay drops are underway to reach cattle that are lost, stranded, or unable to be reached by ranchers “where flood waters remain standing in fields and roads are still closed and impassable.”

Fortunately, aviation units from the Texas National Guard, from Alabama, Oklahoma, Louisiana and Mississippi and other states are responding, loading bales of hay and  launching what promises to be the largest air drop of hay in history, an attempt to provide rescue food for livestock until waters finally recede and herds can be collected, treated, and moved to safety.

 

Choppers have been flying non-stop as state animal biologists and state animal health veterinarians with the Texas Animal Health Commission (TAHC) attempt to identify where small groups of animals are stuck in mud or stranded in water from aerial photographs, from satellite photos and by using UAV (drone) fly-overs.

Still, the loss of livestock, yet to be determined, is expected to be devastating.

 

Reports from two animal-related trade organizations provide insight into the current status and goals of animal rights organizations intent on eliminating the use of animals by humans, without regard to how humanely those animals are treated.

Based on these revealing comments from activists it remains vitally important that the public is exposed to the differences between animal rights activists and animal-related industries whose goals are to ensure that animals under the care of humans are treated humanely.

Members of the National Association for Biomedical Research and the Animal Agricultural Alliance attended the 2017 Animal Rights National Conference held on August 3-6 in Alexandria Virginia.

As advertised on the website

The Animal Rights National Conferences have been organized since 1981 by Farm Animal Rights Movement (FARM) with some breaks between 1987 and 2000, then every year since 2000. They are typically co-sponsored by more than a dozen national organizations.

Farm Animal Rights Movement (FARM) is a national non-profit organization working to end the use of animals for food through public education and grassroots activism. We believe in the inherent self-worth of animals, as well as environmental protection and enhanced public health.

Speakers at the conference talked about the “Power of confrontation in advancing animal rights,” and alleged abuses of animals used for all human purposes including: animals in Entertainment (circuses, rodeos, zoos, aquariums), animals in science (education, product testing, drug research),animals in Fashion, Companion animals, food Animals, and animals in the wild.

Kay Johnson Smith, Animal Agriculture Alliance president and CEO described this year’s conference:

The speakers at this year’s Animal Rights National Conference made their goals clear – ending all forms of animal agriculture, regardless of how well animals are cared for . . . Their persistent focus on pressure campaigns targeting restaurant, retail and foodservice brands is of great concern to the Alliance and our members. We encourage anyone with a vested interest in producing, processing or selling meat, poultry, eggs and dairy, to read this year’s report and hear how determined these groups are to eliminate food choices and make our society vegan.

The alliance reported that speaker encouraged attendees to protest and conduct rescues from farms without permission, and that “[b]reaking the law can often be a good thing to do.”

The Alliance also reported that one speaker, David Coman-Hidy with the Humane League encouraged attendees to damage the reputation of food companies.

Consistent with previous years, another key message from conference speakers was for attendees to focus efforts on eliminating farms of all types and sizes, not only the large-scale, modern operations (declared to be “factory farms”) that have historically been targeted.

National Association for Biomedical Research reported about the following speakers and their comments at the conference, intent on eliminating the use of animals in research:

  • Justin Goodman, lobbyist for the White Coat Waste project (WCW), an animal rights group that promotes itself as a fiscally conservative consumer watchdog group, spoke about WCW’s “defund” campaign to “take money away so [research institutions] can’t buy the animals to do the testing.” He continued to focus on making sure universities and other institutions that conduct animal research “don’t get their money.” 

  • Michael Budkie explained [Stop Animal Exploitation Now] SAEN seeks to end animal research by “hanging them with their own paperwork.” We understand this to mean the group attacks the reputations of research institutions and individual scientists by deliberately misusing or mischaracterizing written statements provided by the institutions to government agencies like the NIH and the USDA.

  • Speaking again on behalf of SAEN, Michael Budkie explained his approach to stopping animal research by targeting researchers: “We like to paint them as idiots. They are criminals. SAEN’s job is to let people know animal research is meritless. We will ruin their reputation and credibility. We are coming after them…It becomes news and we’re changing public opinion of what labs do.”

  • A celebrated figure in the animal rights world, Richard Couto conducts undercover investigations of factory farms and food enterprises that use animals. He gains access by working as an employee while filming and documenting abuse for later use in criminal prosecutions of his erstwhile employers. Joined by other so-called “undercover investigators,” they encouraged attendees to join their ranks by stating, “anybody in this room has what it takes to be an undercover investigator.”

Clearly, the goals of animal rights organizations, on display at this conference, should concern those who are involved in animal-related industries where animals are owned and cared for by humans.

Sometimes it is important to set the record straight.

That is the case here.  New Jersey stood at the forefront in the country of establishing humane standards of care for livestock and poultry for the state.   In 2003, when the rule was originally proposed, the New Jersey Department of Agriculture explained that they were “adopt[ing] ‘standards for the humane raising, keeping, care, treatment, marketing, and sale of domestic livestock,’ as well as ‘rules and regulations governing the enforcement of those standards.'”  35 N.J.R. 1873(a)(2003, as mandated by N.J.S.A. 4:22-16.1.

While the rules require minimum standards of care,  the Department acknowledged that “many responsible New Jersey farmers meet or exceed” those standards.  The standards were developed in consultation with the New Jersey Agricultural Station, and involved hundreds of hours of meeting with subcommittees established for each livestock group.  Committee members included state and federal animal health officials, academicians, subject matter experts, farmers, transporters and members of the N.J.S.P.C.A.  As the Director of the Division of Animal Health at that time, I chaired those meetings.

The N.J.D.A., the N.J. Ag. Station and N.J. Farm Bureau had approached legislators requesting the amendment to the animal cruelty statute (N.J.S.A. 4:22-16.1) that mandated the creation of these regulations out of concerns that there was no uniform guidance to either professional or volunteer law enforcement officials who were enforcing animal cruelty statutes with uneven hands across the state.  These rules were necessary to provide:

[r]egulatory authorities charged with the enforcement of animal cruelty rules  . . . measurable standards to help them do their jobs effectively and assist in the training of new inspectors.  These defined standards provide authorities with a baseline to use to determine when animal cruelty occurs.  Application of these standards uniformly, across the State will standardize the criteria under which animal cruelty cases are judged.  35 N.J.R. 1873(a)(2003.

In addition to specific standards for the raising, keeping, care, treatment, marketing and sale of: (a) cattle; (b) horses; (c) poultry; (d) rabbits; (e) small ruminants; and (f) swine, they also established “procedural rules for investigation and enforcement actions and [the] use of proper biosecurity protocols.”  Id.   Biosecurity protocols are critical when investigating complaints about animal care “to prevent the spread of infectious or contagious agents on or off farm premises.”  Id. 

Furthermore, because the cause of livestock illness many not be immediately apparent, it is important that any individual who performs investigations be familiar with clinical signs of disease and report any cases of livestock disease or death to the  . . . NJDA as required under N.J.A.C. 2:2-1.5.  Id.

As previously described here, New Jersey was one of the first states to establish comprehensive humane standards of care for livestock and poultry.  At the time, Colorado was one of the few states that had standards for livestock, although not at comprehensive as those drafted by New Jersey.

Well after the rule was adopted and survived legal challenges, the regulations and process used to draft the standards was shared with other states, including, for example, Ohio.  Ohio’s standards were recently heralded as a model to follow for the formation of livestock codes in other states. 

While I agree that the process used and resulting standards adopted in Ohio are a great model, it is important to remember that both started right here in the “Garden State!”

 

The recent horrific attacks in Syria reminded me of the concerns following 9/11 about potential attacks on livestock and poultry.  Those concerns rose to the highest echelon in our government and others, exemplified by the first International Symposium on Agroterrorism, held in Kansas City, Missouri on May 5, 2005.

I attended that meeting and was awestruck by the opening video-a poignant memorial to the farmers and others involved in agriculture from across the country, highlighting their back-breaking work that feeds and clothes everyone in the United States, and much of the world.  I would love to see that video again-if anyone has a link, please share.

FBI Director Robert S. Mueller, III greeted the attendees, describing the unique challenges involved in distinguishing intentional acts of agroterrorism from natural disease outbreaks:

This distinction is important. If a car bomb explodes outside of a building, we know the attack was intentional. But if a cow contracts Foot and Mouth Disease or a soybean plant exhibits rust, it can be difficult, if not impossible, to determine whether the attack was intentional or occurred naturally.

Director Mueller highlighted the federal, state and local public-private efforts then recently adopted and deployed to investigate a potential threat:

Several months ago, the State Department received an anonymous tip that an unknown individual had threatened to introduce a virus to a large pig farm in Kansas. The State Department passed this information to the Secret Service, which notified one of its agents in Kansas. This agent was part of the FBI’s local Joint Terrorism Task Force. Together, we got the investigative ball rolling.

We coordinated with a local veterinarian, the USDA, and the FDA to assess the threat. Working with INS and local law enforcement, we found this man and questioned him. As it turns out, he had recently returned from South Africa, and it was possible that he could have transported a virus with him.

In the end, this investigation turned out to be a poison pen letter. The man we questioned had no intention of spreading a damaging virus. But because of our established networks, we were able to quickly assess the threat and move to prevent any attack.

In 2008, the FBI, Department of Justice and USDA published the “Criminal Handbook for Agroterrorism,” which “represent[ed] a joint effort of the Federal Bureau of Investigation, Counterterrorism Division; the Food and Drug Administration, Office of Criminal Investigations; the Food and Drug Administration, Center for Food Safety and Applied Nutrition; the Department of Homeland Security; and the U.S. Department of Agriculture, Office of the Inspector General.”

The handbook was considered important since “[a]n attack against the food or agriculture sector . . . requires a high level of cooperation . . .  to identify . . . the threat, prevent . . .the spread of the disease or further contamination of a food product, prevent . . . public panic, and apprehend . . . those responsible. Lack of mutual awareness and understanding, as well as the absence of established communication procedures, could hinder the effectiveness of joint law enforcement investigations. Due to the continued likelihood of attacks against the U.S. food and agriculture sector, the effective use of all resources during an incident will be critical to ensure an efficient and appropriate response.”

Protecting the food supply in this country remains a priority of the FBI, according to Mollie Halpern (not a relative), explaining:

One way the FBI ensures the safety of the nation’s food from farm to fork is through agroterrorism workshops. Our 56 field offices across the country host these workshops, which bring together the public and private sector—such as farmers, law enforcement, federal regulatory agencies, and academia. Supervisory Special Agent Kelly Decker says outreach, liaising, and awareness are the best defenses against agroterrorism.

USDA has continued its efforts to protect the nation’s food supply.  The Office of Inspector General at USDA published a report in March 2017, “Agroterrorism Prevention, Detection, and Response

“to evaluate if USDA’s [Office of Homeland Security and Emergency Coordination’s] OHSEC had developed and communicated effective plans and procedures to prevent, detect, and respond to agroterrorism threats.”

The OIG recommended:

Development and implementation of written processes to effectively oversea USDA’s agroterrorism prevention, detection, and response activities;

Development and implementation of a comprehensive process to track USDA’s compliance with Homeland Security Presidential Directive (HSPD)-9; and

Improvement of the process used to create the Sector Specific Plan (SSP).

The recommendations were largely accepted and will hopefully be completed before they are needed.

 

I recently reconnected with colleagues at the annual meeting of the National Institute for Animal Agriculture in Columbus, Ohio on April 6, 2017 where a special session was held, titled “Animal Care Standards: How Laws, Commitments, & Public Perception Have Changed the Landscape.”

A special shout out to the attending former and current State Veterinarians, including Dr. Glauer-State Veterinarian Ohio (ret.), and Dr. Tony Forshey-State Veterinarian Ohio.  State Veterinarians are a state animal health officials charged with protecting the health and well-being of animals in their state.  I served as the New Jersey State Veterinarian for nearly a decade.

Also attending were presenters, including: (1) Dr. Janet Helms, National Director of American Humane; (2) Chelsea Good, J.D., VP government and industry affairs, Livestock Marketing Association; (3) Candace Croney, Ph.D., Director, Center for Animal Welfare Science, Associate Professor, animal Behavior and Wellbeing, Purdue University; (4) Judge Linda Chezem, Indiana Court of Appeals (ret.) and others representing retail, private and public organizations.

One topic discussed was how governmental and private animal care standards of care benefit animals and consumers.  There is some concern that consumers, unfamiliar with the different certifying standards available, may be confused by labeling at the point of sale.  This is compounded by the fact that most consumers are unfamiliar with animal agriculture―fewer than 2% of the US population is directly involved with animal agriculture facilities that provide food and fiber to the rest of the US population and much of the rest of the world.

One of the longest standing third-party certification program, American Humane Certified™, was established by American Humane.  This nonprofit was “f]ounded in 1877 . . . [and] is committed to ensuring the safety, welfare and well-being of animals.”

As described on its website “The American Humane Certified™ program is a voluntary third party animal welfare audit program that is rapidly setting the standards for the way that food animals are raised in the U.S.

The American Humane Certified™ Animal Welfare Standards are species-specific and grounded on solid scientific research. The standards were created with input from renowned animal science experts and veterinarians and are frequently reviewed by our Scientific Advisory Committee to reflect current research, technological advances, best practices, and humane handling methods. Our Animal Welfare Standards were built upon the Five Freedoms of Animal Welfare, which require that an animal be healthy, comfortable, well-nourished, safe, able to express normal behavior, and free from unpleasant states such as pain, fear, and distress. American Humane Certified producers are audited for their compliance to the standards.”

There are numerous private and publicly available standards of care for livestock and poultry, but American Humane’s emphasis on obtainable, scientifically-sound practices and its commitment to partnering with livestock producers to provide consumers with safe, healthy, and humanely raised animals sets it apart from many others.

The challenge for livestock producers is to make sure that consumers can rely on labeling or standard certifications to insure that the animals raised are treated humanely and that the food produced is healthy and safe.

 

At the request of New Jersey Department of Agriculture (NJDA), New Jersey Agricultural Experiment Station (NJAES), and New Jersey Farm Bureau, State legislators adopted a law in 1996 “which directs the Department of Agriculture—in consultation with the New Jersey Agricultural Experiment Station—to adopt ‘standards for the humane raising, keeping, care, treatment, marketing, and sale of domestic livestock,’ as well as ‘rules and regulations governing the enforcement of those standards.’”  35 NJR 1873(a) 2003.  At the time, livestock owners were increasingly concerned about the uneven-handed enforcement of the State’s animal cruelty statutes by state and county societies for the protection of animals (SPCA), who often had minimal, if any, knowledge about the proper care of livestock and horses.  As the State Commission of Investigation reported, there were “no standards, rules or guidelines governing [SPCA’s] composition, operation, training or activities, there is no consistency or uniformity in their make-up, functioning or enforcement of the laws.”  NJSCI Report 2000.

The law was adopted to “[p]rotect. . .  the health and well-being of New Jersey’s livestock . . . to ensure farm animals are humanely treated.  This includes livestock farmers whose livelihood depends on raising healthy animals and who, therefore, have an added financial incentive to properly care for their animals.”  35 NJR 1873(a) 2003To ensure that experts qualified to investigate complaints of cruelty involving livestock the law also requires notification of NJDA of complaints received by investigating authorities.

The NJSPCA, county SPCAs or other State or local government authority receiving a complaint shall immediately notify the New Jersey Department of Agriculture and, if the complaint is in writing, provide a copy to the NJDA at the address provided in N.J.A.C. 2:8–8.3(c).

Unfortunately, while the standards mandate humane care, the enforcement of those standards remains problematic.  It is not clear if NJDA has been notified immediately upon receipt of complaints to SPCA’s, as required by law.  This notification is critical to ensure that only the approved standards are used as guidelines, and to ensure that all inspections are conducted in accordance with accepted biosecurity protocols referenced herein to prevent the spread of infectious or contagious agents on or off farm premises.

I recently discussed these ongoing issues at the 2017 New Jersey State Agricultural Convention, where the delegates adopted a resolution to address “continued concerns from stakeholders because of humane-law enforcement personnel’s inconsistent and inappropriate enforcement of animal cruelty statutes against the owners of livestock and poultry in New Jersey, by largely ignoring the Humane Standards, even when they are being followed by the livestock owner, have not changed since the adoption of the law, despite the clear rules to guide the investigation of complaints.  See Resolution No. 6, Humane Treatment of Livestock.

The delegates “urge that New Jersey’s agricultural community evaluate the consistency and appropriateness of the implementation of the Humane Standards by the SPCA and other humane-law enforcement personnel who are tasked to respect and follow them with enforcing animal-cruelty statutes.”

They also encourage the Legislature to adequately fund the implementation and enforcement of the Humane Standards and to require SPCA agents to comply with the provisions set forth therein.

Assembly bill No. 2052 includes the following definition of “necessary care: in the definition section of New Jersey’s animal cruelty statute that could be problematic for farmers raising livestock and poultry in the state, if it were to apply to them:

“Necessary care” means care sufficient to preserve the health and well-being of an animal, and except for emergencies or circumstances beyond the reasonable control of the person responsible for the care of the animal, providing the following: (1) food of sufficient quantity and quality to allow for normal growth or maintenance of body weight; (2) open or adequate access to drinkable water of an appropriate temperature in sufficient quantity and quality to satisfy the needs of the animal; (3) access to adequate protection from the weather, including an enclosed non-hazardous structure sufficient to protect the animal in which there is adequate bedding to protect the animal against cold and dampness; (4) adequate protection for the animal from extreme or excessive sunlight and from overexposure to the sun, heat and other weather conditions; (5) veterinary care to alleviate suffering and maintain health; and (6) reasonable access to a clean and adequate exercise area.

The reason for concern is that provisions (3), (5), and (6) are inconsistent with the provisions set forth in the Humane Treatment of Domestic Livestock (N.J.A.C. 2:8-1.1 et seq.) as provided for in N.J.S.A. 4:22-16.1. which provides:

Rules and regulations; standards for humane treatment of domestic livestock-

  1. The State Board of Agriculture and the Department of Agriculture, in consultation with the New Jersey Agricultural Experiment Station and within six months of the date of enactment of this act, shall develop and adopt, pursuant to the “Administrative Procedure Act,” P.L.1968, c. 410 (C. 52:14B-1 et seq.): (1) standards for the humane raising, keeping, care, treatment, marketing, and sale of domestic livestock; and (2) rules and regulations governing the enforcement of those standards.
  2. Notwithstanding any provision in this title to the contrary:

(1) there shall exist a presumption that the raising, keeping, care, treatment, marketing, and sale of domestic livestock in accordance with the standards developed and adopted therefor pursuant to subsection a. of this section shall not constitute a violation of any provision of this title involving alleged cruelty to, or inhumane care or treatment of, domestic livestock;

(2) no person may be cited or arrested for a first offense involving a minor or incidental violation, as defined by rules and regulations adopted pursuant to subsection a. of this section, of any provision of this title involving alleged cruelty to, or inhumane care or treatment of, domestic livestock, unless that person has first been issued a written warning.

  1. For the purposes of this act, “domestic livestock” means cattle, horses, donkeys, swine, sheep, goats, rabbits, poultry, fowl, and any other domesticated animal deemed by the State Board of Agriculture and the Department of Agriculture, in consultation with the New Jersey Agricultural Experiment Station, to be domestic livestock for such purposes, according to rules and regulations adopted by the department and the board pursuant to the “Administrative Procedure Act.”

CREDIT(S) L.1995, c. 311, § 1, eff. Jan. 5, 1996.

The bill statement for A2052 states:

This bill amends the definition for “necessary care,” established 43 by P.L.2013, c.88 (designated as Patrick’s Law), to provide for 44 additional specific care requirements.

Before consideration by the senate, since the bill statement clearly indicates its intention was to provide for domestic companion animals and not domestic livestock, the definition of “necessary care” should be amended to exclude provisions regarding domestic livestock which are prescribed in N.J.A.C. 2:8-1.1 et seq. as the legislature previously mandated.

A2052 was passed by the Assembly on December 19, 2016.

As recently reported by Stephanie Strom in the NY Times (Business Section, Oct. 21, 2016), hens housed in aviaries have been observed to suffer higher morbidity and mortality rates, compared to hens housed in cages.  As egg farmers, veterinarians  and scientists previously warned, concerns about the welfare of hens housed in aviaries results from the well-known cannibalistic behavior of hens.  That behavior historically lead to the husbandry practice known as beak trimming, a practice activists consider a “mutilation.”

As discussed previously, the husbandry and housing techniques used to protect of animals raised for food or fiber has developed over time, informed by animal scientists researching and testing different methods that provide for the health of the animals, their welfare, the safety of their caretakers, and to minimize negative impacts on the environment.

In “A Comparison of Cage and Non-Cage Systems for Housing Laying Hens,” as reported by the AVMA, there are many factors that must be considered:

contributing to the hens’ welfare, including whether hens are free to move; whether the system allows them to engage in behaviors that are normal for hens; whether they are protected from disease, injury, and predators; whether food and water are available in the appropriate amounts and type, and are of high quality; and whether the hens are handled properly.

 For example, sows, known as the “mixing vessels” of avian influenza, are often raised in enclosed structures to prevent the spread of infectious diseases from wild animals and insect vectors.  Their enclosures also protect them from exposure to parasites and protect the environment from their destructive rooting behavior and fecal contamination.  

However, similar to public concerns about hen caged housing, bans on the use of gestation stalls for sows have been enacted throughout the country.  Unfortunately, where these stalls are banned, hog farmers cannot provide updated sow housing techniques and equipment that allow sows a choice-protection in their stalls from aggressive animals or the ability to move around in the group-housing area.

 As the AVMA has repeatedly pointed out, like for hens, there are pros and cons to every type of housing for sows.  In a literature review and analysis, titled “Welfare Implications of Gestation Sow Housing” published on Nov. 19, 2015, the AVMA concluded: 

Gestation sow housing systems vary in their advantages and disadvantages regarding the welfare of the sow. When comparing housing systems for pregnant sows, making a definitive welfare judgment requires assigning weights to an array of contributing welfare indicators including, but not limited to, type, severity and incidence of injuries; behavioral and social opportunities; and exposure to parasites, disease, and harmful or aversive stimuli. As no universally accepted weighting system exists, there is no clear consensus as to which is the superior system across all situations. However, the public is generally more critical of gestation stall housing than other systems, which has led to voluntary and mandatory transition to alternative housing systems by some producers. As such there is an ongoing need to develop an array of housing systems that suit local conditions, effectively provide enhanced opportunities for the sows to move and interact socially, and avoid an unacceptable increase in negative outcomes such as injury associated with aggression or exposure to environmental hazards.

Absolute bans on husbandry and housing techniques should be carefully considered, and informed by animal scientists, veterinarians, and the farmers who know the most about the needs of their animals.

In preparation for the VFD final rule, which outlines the revised process for authorizing use of VFD drugs (animal drugs intended for use in or on animal feed and that require the supervision of a licensed veterinarian), FDA released it’s final version of its industry guidance #233 titled “Veterinary Feed Directive-Common Format Questions and Answers.”

While rejecting a suggestion that FDA require a uniform veterinary feed directive form, FDA has provided a “common VFD format [that] would help veterinarians, their clients (i.e., animal producers), and distributors (including feed mills) quickly identify relevant information on the VFD.”

In addition to providing a list of information that is required, FDA has provided a blank VFD form and several examples of completed forms, several of which are reproduced below.

Blank VFD form
Blank VFD form
Example 1 VFD form
Example 1 VFD form
Example 2 VFD form
Example 2 VFD form

Example 2 VFD form

The information that must be included pursuant to § 558.6(b)(3) on any form utilized includes:

the veterinarian’s name, address, and telephone number;

the client’s name, business or home address, and telephone number;

the premises at which the animals specified in the VFD are located;

the date of VFD issuance;

the expiration date of the VFD;

the name of the VFD drug(s);

the species and production class of animals to be fed the VFD feed;

the approximate number of animals to be fed the VFD feed by the expiration date of the

VFD;

the indication for which the VFD is issued;

the level of VFD drug in the feed and duration of use;

the withdrawal time, special instructions, and cautionary statements necessary for use of

the drug in conformance with the approval;

the number of reorders (refills) authorized, if permitted by the drug approval, conditional

approval, or index listing;

the statement: “Use of feed containing this veterinary feed directive (VFD) drug in a

manner other than as directed on the labeling (extralabel use), is not permitted.”;

an affirmation of intent for combination VFD drugs as described in § 558.6(b)(6); and

the veterinarian’s electronic or written signature.

It would be surprising if veterinarians did not use the forms suggested by FDA to insure they were providing all the information required.

Not everyone is satisfied by the increased restrictions set forth by FDA regarding antibiotics for food animals provided in feed and/or water.

A number of nonprofits filed a citizen petition under section 512(e) of the Food, Drug, and Cosmetic Act, 21 U.S.C. Section 360b(e), “to request that the Commissioner of Food and Drugs withdraw approval of the use of medically important antibiotics in livestock and poultry for disease-prevention or growth-promotion purposes.”

These nonprofits want to prohibit the use of critically important antibiotics that prevent disease in food animals.  Such use is imperative to continue to protect food animals from preventable illness.