DRUGS: WHEN, HOW, & FOR WHAT REASONS CAN WE USE THEM?
When we treat cattle, we treat them under the regulation of the FDA and the Animal Medicinal Drug Use Clarification Act (AMDUCA). According to the algorithm or procedure set down by AMDUCA, we should use drugs and medicines in this order:
1. If there is a drug that is labeled for the specific species we are dealing with and the specific disease orprocess we are dealing with and it is effective at its label claim, we should use this drug according to the label.
2. If there is no drug that fits level 1, then we should next use a drug that is approved for use in food animals and effective, but not labeled for the particular use we need or the particular dose, duration, and route of administration we need for effectiveness.
3. If there is still no drug that fits level 2, then we should next use a drug that is approved for use in humans or non-food animals and effective, but not labeled for the particular use we need.
4. If there is still no drug that fits level 3, then we are allowed to compound a drug that is effective. Honestly, we do not get to level 3 often and level 4 is very rare.
As the scrutiny of use of antibiotics and therapeutics is intensified, this algorithm will become more and more important. The FDA is currently concluding a study of milk bulk tank sampling for multiple drugs that are currently not being tested for on a consistent basis. The results of that study will likely affect how we can continue to use therapeutics and how intensely milk and meat will be tested.
There are a few key factors to using drugs extra-label:
1. ANY deviation from dose, duration, or route of administration of ANY drug is an extra-label use. (ex. using Penicillin at a dose higher than the labeled 1cc/100 pounds is extra-label)
2. When using a drug extra-label, the labeled withdrawal times are no longer valid.
3. To use a drug extra-label legally, you need a valid, vet-client-patient-relationship to establish need and withdrawal times.
4. There is a list of drugs that are illegal to be used extra-label in food animals. Common ones that may be on your farm include Albon and Baytril.
Moral of the story is that keeping excellent records, testing milk before returning cows to the bulk tank, testing urine samples before shipping treated animals, and establishing correct withdrawal times for extra-label use of drugs will help keep you off the violators list and in the milk and meat producing business.