AABP will be making comments on this rule. The AABP Committee on Pharmaceutical and Biologic Issues (CPBI) has been asked to prepare comments to be reviewed and approved by the Board of Directors. Conversations with the present and past chairs of CPBI and the Executive Committee suggest that a consensus position is that we are in agreement with FDA that this antibiotic is valuable in the treatment of many diseases in cattle. We are appreciative of the continued availability of this important class of antibiotics for treatment of our patients when needed. We are concerned that any current or future restriction of antibiotic use due to concerns about resistance developing in bacteria responsible for human infections be done carefully, and be based on solid scientific evidence, and not generalizations without evidence. Please do not hesitate to share your opinions on this rule with any of the officers or the AABP office, and feel free to comment directly yourself if you are so inclined. You can find a discussion online at www.fda.gov.

Third was an action by the AVMA House of Delegates the first weekend in January. They voted to approve a new “Model Practice Act”. This new “model” did not contain revised language for what constitutes a valid VCPR (Veterinary Client Patient Relationship); however, new language redefining the VCPR has now been proposed for inclusion in this new document. (It should be noted that this revision will theoretically not affect the definition of VCPR codified in federal regulations that affects the use of extralabel drugs.) The new Model Practice Act is likely to be used as a template when many states revise and adapt their own practice acts. The new suggested definition for a VCPR was submitted a week after the House of Delegates vote, and is available for review and comment. You can view it online at http://www.avma.org/issues/policy/mvpa_VCPR_attachment1.pdf if you are an AVMA member. A vote on its adoption is tentatively scheduled by the Executive Board in this spring and the AVMA House of Delegates in August. At least partly in response to concerns by swine and poultry practitioners, the proposed definition does not require that a veterinarian be on the premises or see the animals on a regular basis if sufficient knowledge of the operation, including treatment records, disease conditions, and other information such as necropsy results are regularly available and reviewed.

While acknowledging differences in practice conditions between species, many of us believe that a change in the definition of a valid VCPR in this manner is likely to lead to confusion and a loss of oversight of drug use in the cattle industry at a time when public concerns are particularly elevated. One suggestion has been for the AABP to adopt a “Standards of Practice” statement that further helps define what we consider to be adequate or appropriate contact with an operation, animal, or group of animals that would be sufficient to provide the necessary veterinary oversight for judicious drug use on the operation. We believe prior to taking such a step there should be an opportunity for significant member input, so the already busy CPBI has been requested to develop a survey for the membership, and some ideas for language for a possible statement regarding standard of practice. This will be a major topic for the Board of Directors at our March meeting. In addition, we will be making comments and suggestions for revisions to the AVMA proposed definition of VCPR based on these ideas. In the near future, watch for an opportunity to participate in this survey.

So, let us know what you think!

Brian Gerloff Less