Approved & not Approved Pesticides

[casportpony]

Extra label is allowed except for these limitations, and one being:
(c) Extralabel use resulting in any residue which may present a risk to the public health; and

And who determines this?

 

[Lady of McCamley]

Your first list takes us to the AMDUC which states:
The Animal Medicinal Drug Use Clarification Act of 1994 (AMDUCA) permits veterinarians to prescribe extralabel uses of certain approved new animal drugs and approved human drugs for animals under certain conditions. Extralabel use refers to the use of an approved drug in a manner that is not in accordance with the approved label directions. Under AMDUCA and its implementing regulations published at Title 21, Code of Federal Regulations, Part 530 (21 CFR 530), any extralabel use of an approved new animal or human drug must be by or on the lawful order of a veterinarian within the context of a veterinarian-client-patient relationship (VCPR). Extralabel use must also comply with other provisions of 21 CFR 530. A list of drugs specifically prohibited from extralabel use appears in 21 CFR 530.41.

My quote is from 21CFR 530.11 (c)
https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfcfr/CFRSearch.cfm?fr=530.11

(c) Extralabel use resulting in any residue which may present a risk to the public health;

 

[Lady of McCamley]

And who determines when this?

We are then back to the FDA approved drug listings and residues lists from FARAD.

If a drug is not approved, any residue then is not sanctioned.

 

[Lady of McCamley]

We are back to this:

http://www.usfarad.org/treating-layers.html
per FARAD: "Discerning which medications are approved for use in laying hens can be confusing. In order to determine if a medication is approved for use: 1. check that the medication is labelled for "chickens, all classes." The label may even state for use in layers or laying hens. 2. Determine that the label does not exclude "Laying hens" 3. Determine that a tolerance in eggs exists for the drug. This may be done by checking the VetGram orFDA Animal Drugs websites. For more on tolerances see "Rules & Regulations."

Here is the current VetGram...note any antibiotics are excluded from layers.
http://www.farad.org/vetgram/egglayers.asp

 

[casportpony]

We are back to this:

http://www.usfarad.org/treating-layers.html
per FARAD: "Discerning which medications are approved for use in laying hens can be confusing. In order to determine if a medication is approved for use: 1. check that the medication is labelled for "chickens, all classes." The label may even state for use in layers or laying hens. 2. Determine that the label does not exclude "Laying hens" 3. Determine that a tolerance in eggs exists for the drug. This may be done by checking the VetGram orFDA Animal Drugs websites. For more on tolerances see "Rules & Regulations."

Here is the current VetGram...note any antibiotics are excluded from layers.
http://www.farad.org/vetgram/egglayers.asp

That's FARAD, it's not the FDA.

 

[Lady of McCamley]

That's FARAD, it's not the FDA.

FARAD is responding to FDA rulings...they are a databank that lists specifically drug residues to avoid: Farm Animal Residue Avoidance Databank (FARAD).

ETA: OOps...typo...that's Food Animal, not Farm Animal.

 

[casportpony]

Conditions for Extra-Label Drug Use in Food-Producing Animals
If you’re a food animal veterinarian, you should be aware of the additional requirements for extra-label drug use in food-producing animals. Before prescribing any approved human or animal drug for an extra-label use in food-producing animals, you must:

• Carefully diagnose and evaluate the condition for which you are prescribing the drug;
• Make sure procedures are in place so your client maintains the identity of the treated animal or animals;
• Establish a substantially extended withdrawal period supported by appropriate scientific information. You may get this information from such sources as scientific literature, academia, or the Food Animal Residue Avoidance Databank (FARAD) ; and
• Take measures to assure that no illegal drug residues occur in the treated animal or animals. Your client must follow your established withdrawal period.

If you want to use a drug approved for people or a drug approved only for companion animals in food-producing animals, you must also have an appropriate medical rationale for using the drug. In addition, if scientific information is unavailable on the safety of food products made from animals treated with the particular drug, you must take appropriate measures to assure that the animal and its food products will not enter the human food supply.

Remember, you may not prescribe an approved human drug for food-producing animals if there’s an animal drug approved for food-producing animals that you can prescribe instead.

The FD&C Act doesn’t allow the extra-label use of any drug in animal feed. However, for some minor species, you may determine that extra-label use of a drug in animal feed is needed to prevent suffering and death in these animals. (Minor species are all animals that aren’t one of the seven major species: cattle, horses, swine, chickens, turkeys, dogs, and cats.) Please refer to FDA’s Compliance Policy Guide on extra-label use of medicated feeds for minor species.

 

[casportpony]

FARAD is responding to FDA rulings...they are a databank that lists specifically drug residues to avoid: Farm Animal Residue Avoidance Databank (FARAD).

I know what they are.

 

[Lady of McCamley]

" In addition, if scientific information is unavailable on the safety of food products made from animals treated with the particular drug, you must take appropriate measures to assure that the animal and its food products will not enter the human food supply."

Most vets, in my experience, at least the ones my daughter worked for and who I have used, have interpreted that to state "do not use this animal for food production from now on."

Now do the vets personally adhere to that? No. and Yes. Some would prescribe an off label drug and tell me they'd be willing to still buy eggs. Others no. But they all warned me that selling the eggs to the public was problematic. That animal was no longer sanctioned for food use ever again unless the FDA and FARAD has specifically stated withdrawal times for that species in that use.

So, technically, if a drug does not have established residue levels for food, it is not sanctioned for food use. That is how it is interpreted in the industry.

Yes, it is a morass of federal rules and regulations.

Again, for the small holder, it boils down to personal comfort as to the risk of residue ever being found. It also is beginning to boil down to finding a vet who is willing to treat as they begin to feel more pressure from the government as more concern is brought upon backyard livestock entering the food chain.

Remember, my philosophy is knowledge is power. Each decides their own risk level and personal response.

And it is very challenging to keep up with the FDA rulings, which are regularly changing.

It is why I personally do not sell to the general public anymore. (One of the reasons...the other being that a "hobby" was becoming "work.) I don't feel it is worth the risk. I simply follow FARAD pull times and share eggs to friends on a casual basis.

LofMc

 

[casportpony]

" In addition, if scientific information is unavailable on the safety of food products made from animals treated with the particular drug, you must take appropriate measures to assure that the animal and its food products will not enter the human food supply."

That's very different than saying extra label drug use is not allowed, or saying that one can never eat the eggs after using ivermectin, fenbendazole, albendazole, piperazine, etc, which I have seen people do.