Managing on-farm drug usage (OTC, LDU, ELDU) (Proceedings)

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Managing on-farm drug usage (OTC, LDU, ELDU) (Proceedings)

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Aug 01, 2010

Supervision of the drug usage on the dairy is a foundation stone for achieving the VCPR and is referenced frequently in the regulatory documents that we are obligated to comply with. In 1996 the Animal Medical Drug Usage Clarification Act (AMDUCA) became the law that regulates extra-label drug usage (ELDU). In Wisconsin a guide was developed to help our dairy veterinarians incorporate this law into their daily practice. Early in 2000 Wisconsin developed a software program as a tool to aid in organizing basic information about reconciling past drug usage, organizing the drug protocols used in treatment plans, and a software for preparing the prescriptions for the drugs used on the dairy based on past usage and expected future needs.

Two requirements from AMDUCA; by or under the supervision of a veterinarian and in the presence of a valid VCPR; served as the emphasis in the development of this program. The objective was to develop four parts; reconciliation of drug usage on a dairy, a template for a written treatment plan for the dairy employees responsible for health care delivery (seen in written protocol section), prescriptions of drugs for the dairy in responsible quantities, and a records plan that enables the holder of the VCPR to efficiently supervise all treated animals and assume the responsibility for treatment failures. Best practices Wisconsin achieved 3 of the 4 (reconciliation, protocol writing, and prescriptions) with interactive software to the drug list for a practice.

The records portion is still under development. Organizing individual cow recordings has been and will be the thread that runs through the levels of cow and personnel supervision and our consulting on production medicine decisions for the dairy.

As we were developing the treatment protocols we initiated a 1 defined condition / 1 treatment / 1 recording plan. To keep the recording simple we included only information at the cow side recording that had value for the management either by the cow side personnel or by management for the care of the cow. Our effort to keep the recording simple does improve record keeping compliance which does meet the intent of the law, but as proposed it does not meet the letter of law using the AMDUCA records requirement as our yard sick. The AMDUCA records requirement is ID, species, number treated, condition, drug name, dosage, duration, and withdrawals. Obviously we need to meet the letter of the law while we are keeping the recording system simple and seamless cow side.


Figure 1 Spectramast treatment protocol from Best Practices Wisconsin
As we were writing treatment protocols we developed two layers of protocols, the simple top down protocol for cow side workers that serves for the simple easily defined cases and then an in depth protocol for the responsible person that gives additional instructions and can incorporate the information that meets the letter of the law into either the written treatment instructions or the drug protocol while we keep cow side recording simple and limit it to information that has value in managing the cow.

Figure 1 Spectramast treatment protocol from Best Practices Wisconsin

Notice the last line of the drug protocol added the exit recording entry that potentially has a lot of value for the management of the economic aspects of the treatment protocol as our method of meeting the letter of the AMDUCA records requirement about doses. This addition to the recording plan, which we needed to meet the letter of the law, is likely to be met with resistance unless we can include some information that has true value to the dairy such as also including days out of the tank.


Figure 2 – questionnaire to prepare for written protocol preparation
The writing of treatment protocols was initiated by a questionnaire of conditions the dairy treated, drugs used on the dairy and desired outcomes.

Accounting for the mild cases for each condition was the critical step for supervision of drug usage, especially label usage. Next we need to plan the drug protocols for moderate and severe cases. These are a fact of life that will need to have either a drug protocol plan or instructions to seek professional care. The questionnaire gives us information about what is currently. If treatments are not currently medically appropriate we need to replace the therapies with a new plan and then prove the changed treatment plan is superior.

Superior could be:
         Equal but with improved food safety
         Improved as defined by judicious drug usage
         Improved clinical effectiveness
         Improved economic effectiveness




The drug protocol for moderate and severe may well reach ELDU. AMDUCA is written to regulate extra label drug the use and its algorithm gives us the sound template for drug choices when ELDU is a consideration.