Inhibit the growth of parasites

hello, my name is richard wallace, i'm a dairy technical services veterinarian with pfizer animal health. as formally the dairy extension specialist at the university of illinois, this presentation today was given atthe 2012 dairy summit sponsored by the illinois milkproducers association. today, were going talk about your risk forcausing meat and milk residues on dairy operations. the dairy industry is now under increased drug residue surveillance and i guess the question we need to ask is whyare we seeing that happen.

if you look at the top sources of beefcarcass drug residues cull dairy cows and calves sold from dairies are typically a highest residueviolation sources. dairy calves sold from dairies can be listed as "bob veal calves" or special fed veal calves and where we see the greatest number ofresidue violations are in those young calves that are sold at less than 21 days of age orunder a 150 pounds.

we take a look at a graphic herelooking at the frequency of residue violations on this vertical axis and then over the last 6 years from2005 to 2010. then on this axis were looking atthe class of animal. so, if we just take a look at the non dairy species that are used for food production, you can see that beef cows have the highest residue violations ofthe non dairy animals. when we take a look at where the cull dairycow and the veal calf, you can see that

the majority of those violations over the last 6 years are coming through from the dairy species animals or dairy animals coming off the dairy farms. if you look at these are the2009 data and visit the slaughter violative residue comparisons between beef cows and then dairy cows and thenfed cattle. so, fed cattle would be dairy steers and heifers. you can see there's over 27million animals harvested

and only 16 adultery violations found in those 27 million. now, keep in mind that no 100 percent of these animalsword were tested. it is a random sampling approach and thenthere is a target approach which will talk about a little bit later. but, if you take a look at the dairy animalsonly 2.6 million dairy cows were harvested but, 800 violations were in those2.6 million. so again, the risk from dairy cattle as of 400 times that of fed cattle

and at least 20 times that of beefcattle. so, if we took a look at a summary of thethe reasons for those dairy carcass violations, we can see that this is all based out of the 209 data sets. it is a biased data set because it's coming from inspector generated samples. so, in other words inspector suspected that the animal or the carcass might have a violation.

you can see the top 3 antibioticswhich account for 75 percent of the violations come from penicillin, flunixin meglumine, and sulfadimethoxine. many of you may know flunixin asbanamine as another term. so, this is the most current data that wehave is 2009 and you can see the majority those violations are comingfrom those 3 classes of drugs. when we look at the rest of the violationsyou can see that under 10 percent of

violations are coming from these otherclasses of antibiotics. so, if we could focus on preventing these 3 will have a major reduction in theresidue violations occurring in cattle. interesting to note, if you look at thosegentamicin listed right here, 5.6 percent 2009. in the early or late 1990'sand an early 2000's, i was giving extension meetings on residueviolations and i pulled this slide out from one of my old presentationsfrom a dairy day talk and at the number one violation in1999

was gentamicin at 39 percent. if you remember back to the previousslide we were at 5.6 percent 10 years later. i guess the question we need to askourselves is why has gentamicin dropped so dramatically? when i think about what's happened with this class of antibiotics gentamicin or the amino glycosides. that was in the in that late 90'sthat we actually have voluntarily as a veterinary organization many organizations but,

as an industry agreed not to use amino glycosides in food producing animals in particular in dairy cattle. primarily because of the extended meatwithholding time for tissue residues that occur in these classes of antibiotics. so, when i look at this number andthis is what we can do voluntarily if we know what the rules are as an industry we can get this leveldown to 5.6 percent. quite frankly,

i think we need to do it a little bit morework because that should be 0 percent there for gentamicin. if you take a look the number 2antibiotic that was found in 1990 was penicillin and that is now the number 1 drug nowthat gentamicin has moved out of that top spot. you'll also see sulfadimethoxinestill listed in there as number 3 and sulfadimethoxine when youlook at the name brand of that, that would be albon.

it is approved for use in dairycattle but they are only, we'll talk about that a little later here, they're only approved uses that can beused otherwise i think all other use is prohibited. so, when we look at these other 2 we need tosort of make some decisions on why this might be happening. so, i guess the first question is: whatis it about penicillin? why is penicillin the number one in 2009 and why

was it number 2 in 1999. i guess the question we need to ask ourselvesis why do we use penicillin on farms and and most prisoners will tell me isbecause it's cheap. it is a very inexpensive antibiotic. i ask the question though, whatare the label indications? that is what i usually ask a producer, what are you allowed to use penicillin based on the label that'son the bottle. if you would read the bottle as says we can use it for in cattle and sheep for bacterial pneumonia

or what we might call shipping fever that's caused by pasteurella multocida. now, i could probably go out to any dairy farm in the united states and take some swabs out of the nasalpassagesof some calves and i probably will find pasteurella multocida. it is a very common pathogen that just sort of lives in the upperrespiratory tract. it really does not cause disease or pneumonia until viruses

or other active actions actually cause respiratory immune system to bedepressed and then it can take over and causedisease. so, it is very common fine pasteurella and can see why it's very easy to use penicillin on label for an pneumonia. but, we see penicillin used on dairy farmsfor many diseases like lameness conditions,

post surgical, just about any bacterial infection,metritis, you see penicillin used quite often. now, when i think about it what is thedose of penicillin and you think about what is the labeled dose and the label doses 1 cc per 100 pounds of body weight in the muscle 1 a dayfor 3 to 4 days for a maximum of 4 days. now, when i was in veterinary school,this was back in the late 70's and

early 80's, they told us that a dose of penicillinyou need to get 3 to 5 cc's per 100 pounds of body weight to beeffective against anything. so, even back then we're talking25 to 30 years ago now penicillin was not used according tolabel. the label has not changed sincethat time and we think about it we were probably overdosing these animals. the overdosing to get effectiveness but alsooverdosing them and when you think about

what that might do to create residuesthen. the other part that says on the labelis no more than 10 cc's are or 10 ml per injection site. now, the beef quality assurance program says that 1 injectionsite is 1 hand with or 6 inches a part. so, that would mean that if we'regoing to give an animal upwards of 20 to 25 or 30 cc's that wouldbe given in 3 different injections 6 inches away and that's all im.

then if you'd follow these 2 guidelines as far as the dose and the amount per injection site and duration the milk withdrawal after the lasttreatment would only be 48 hours. that actually makes sense when you givesuch a low dose but, when you think about where we're seeing milk withdrawals onpenicillin on farms if your testing the cows

for penicillin upwards of sometimes up to 2 weeks. that is because we're probably givingmore than 10 cc's per injection site and were also probably giving much more than 1cc per 100 pounds of body weight. when you look at the slaughter sideof things the meat withholding is 10 days if you follow these labeling route and durations. but, again because we typicallyexceed this duration or we give it subcu instead of im

you are going to see extended meat andpossibly milk with holdings when you give it in alternate locations and alternate injection volumes. now, typically if you look on the bottle itsays exceeding the recommended daily dose of 3000 units per pound of bodyweight and administering the recommend level more than 4 consecutive days and/or giving 10 cc's per injection site may result in antibioticresidues on the withdrawal time. so,

the companies that make this penicillinthey've got this disclaimer on here that if you don't follow directions you mayhave longer withdrawal times. so, we have to keep that in mind thatjust because in big bold print it says 48 hours milk and 10 days on themeat doesn't mean that that's what ourwithholding time is. so, i guess the question is if your a dairyproducer how much would you give a 1500 hundred pound dairy cow? would you stop at 15 cc's and ithink most producers realize that

is not an effective dose to treat nearly any condition you mightbe using. we also have to keep in mind the reasonfor using other conditions then bacterial pneumonia then all the sudden you're using it inan extra label fashion. anything that you do that is notlisted appear above in these first three bullet points is considered extra label and if you use a product extra labeledthere are certain conditions that apply.

so, we'll talk about that in 1 minute but,i think this is probably the reason why penicillin was number 1 in 2009 and and stillnumber 2 in 1999 10 years ago. this is most the reason: it's a veryinexpensive drug and it's not used according to label. so, i guess the next thing we need to sortof think about is that what is that number 2 on drug that we found listed in 2009 and it was

flunixion. if you look back at the 1999 data flunixion wasn't even on that list i guess we need to ask a questionand why was flunixion not there. i will answer that for you and is thatwe were testing for it then. flunixion was available for use in cattle in 1999 but, it was there was no diagnostic test to pick it up in the meat or in tissues. so, when we look at what/why cattle are now tested for

antibiotics there is the random testing program. so, there are some otherrandom samples that are pulled but, there is also a targetedresidue testing program. if a black-and-white dairy cow comes to the slaughter plant and has any of these conditions: mastitis, metritis, peritonitis from a surgery,

pneumonia, or an injection sitelesion that it was probably going to beretained and tested for further antibioticresidues or tissue residues. so, these injection sites they don'tknow,the meat inspectors that are in the plants, don'tknow if they're from a vaccine, or a bruise or from an actuallyantibiotic injection. but, if they do see it

that is a red flag that then theyneed to test the rest the carcass for residues. so, we need to talk about ways that wecan reduce injection site lesions by using good beef quality assurance injection techniques but, also keeping cattle on the farm longenough for those injection sites to heal up and the carcasses is ready then for human consumption. lets take a look at some

intramuscular flunixion meglumine injection sitelesions. flunixion meglumine is only labeled forintravenous use in dairy cattle and if you use it intravenouslyaccording to the proper dose then it is a 46 hour milk withholding and 4 day meat withholding. but, if you give this injectionintramuscularly and these are very good pictures here you can see how the tissue has just been damaged. it iswhat we call necrosis is in the center of these, these brown spots. this is basically aburnt piece of tissue

and it's been chemically burnt by thecompound that was used in the flunixion. so, when you look at the damagethat is done here. you can see that this is not a healthy piece of of muscle and it's not going to be healthy ora quality piece of beef after that. so, when they see these injection sitelesions in the slaughter plant they have to trim it out number one but, then it also flags that carcass for further testing.

i want to take a look at one otherthing here. when we take a look at the different antibiotics listed here in theleft column these are different types of antibiotics you might find used in cattle. there is a maximum residue limit incattle tissues. the fda has said that at these levels these tissues are safe for human consumption. lets just focus on one antibiotic: oxytetracycline. there are many different nadas and a lot of different companies have

oxytetracycline. the allowable level in the maximum residue limit that is allowed in tissue is 12-parts per million in the kidney and 2 parts per million in the muscle. the tests that they run on the carcass in the slaughter plant is called the kis test or the kidney inhibition swab test. it will pick up ted tetracycline at .05 parts per million. at a very much lower level,

but at this point the kidney inhibition swab test is simply just a test the says there is an inhibitor in the kidneys. essentially whatthey do is they take a little cotton swab and they stab it intothe kidney a bunch of times and then they incubate it. if there are inhibiters or antibiotics on that swab the media will not change color and it basically triggers a positive test. at this point in time, we don't know thatit was oxytetracycline. all we know is

that the kidney had some kind of an inhibitor in the tissues. then they actually will pull muscle, kidney, and probably also liver from thatcarcass and test it specifically to find out what was the inhibitor that was inthe tissues. if the tissues were at lets say15 parts per million in the kidney then the carcass would be discarded andthrown away. if it was 5 parts per million in the muscle again the carcass will be

disposed of. on the other hand if it was down around10 or 5 parts per million in the kidney or 1 to .5 parts per million in the muscle the carcass would be good to go and because the levels are low enoughthat we know the safety of that food product is now safe even at that much lower level of oxytetracycline. but, the point is that these swob tests there is a lot of different false-positive. all these greens

will be triggered as false positives but the rest of the carcass would gettested. so the important thing to understand is that if you even have anyextra oxytetracycline in the animal from a quality standpoint is that really what message that wewant to send out to our consumers. one thing we need to keep in mindthat is if you get caught with shipping an animal into the slaughterplant that has a volatile of residue there are consequences and it is all part ofthe public record.

here are 2 websites that everyone has access to. there is one the same sourcesupplier list and then there's also the repeat violator list as well as the thein the fda warning letters that are sent out once a month. so, you can actually pull this up and get a list of anybody that hashad an antibiotic violation. we need to keep in mind that all thisinformation if you have a residue violation is part of the public record.

this is just an example of one of those reports you can get fromthat website. you have the source ofthe producer. you have the plant that the animalwas actually slaughtered in. then you have the type of animal andwe take a look at this you can see this one has dairy cows they found penicillin in the kidney andthey give a value. the value was .16 parts per million and the tolerance level for penicillin is point .05

so exceeded the tolerance level. you can see that was oneof the violations. here is another one here that are veal calves. these are the calves less than 21 days of age and not only inthe kidney liver and the muscle they found a drug called tulathromycin. it was detected and you notice there is no tolerance for tulathromycin at any level because this drug is not approved for use inveal calves. which means that it was used in an extra label manner and

will get to that in a minute becauseextra labeled drug use requires that will be no drug residues. here is one with a steer withflunixin and 0:17:12.470,0:17:13.230sulfadimethoxine. you can again see there is avalue and tolerance level for steers. in the holstein here you can see gentamicin.this is one of the ones that we have voluntarily agreed not to use, but it was detected again and there is no tolerance level listed. so, if we take a look at the reports thenthis is something that one of the

the reports you get from the warningletters and you can sort of read down through the information. i am going to highlightactually several comments that they have in there, but if you think about pulling thisinformation off the website and how dramatic the wording is: "you hold animals under conditions that are so inadequate…" "adulterated flunixin meglumine, sulfadimethoxine, oxytetracycline…" "drugs not used according to labeldirections thus is extra label…"

"extra label use must be by or on the order of a licensed veterinarian within the contextof a valid veterinarian/client/patient relationship…" this wording is very inflammatory and it is not wording that obviously you want have associated with your dairy operation. all these residue violations have led toan increase scrutiny for milk production and so milk is now under the same kindof scrutiny by the fda. we have to keep in mind that these assignmentsactually began in january 2012.

so, the fda is now under theassumption that we really do a great job of testing milk for the beta-lactam classes of drugsand we will talk about those in a minute. but, there are other drugs that are usedon farms that we really don't have a routine drug testing program for. with that increased number of drugresidue violations seen in cows and calves off dairy farms this has led the fda to be concernedthat there is a lack of control on dairy farms, which could lead to these drugsactually being present in the milk

since were only testing the milk rightnow for the beta-lactam classes of antibiotics. so what are those beta-lactam classes?the pasteurized milk ordnance requires us to test all tanker loads that leave dairy farms for penicillin, ampicillin, amoxicillin, ceftiofur, cephapirin, and cloxacillin. everybody kind of knows what penicillin is. ampicillin, a trade name for that might be poly flex.

amoxicillin, a trade name for that would be amoxie mast. ceftiofur line of products would be like excenel, naxtel, exceed, and spectramast. those that would be the typicalceftiofur products. cephapirin would be products liketoday and tomorrow or sufedrin sufla lac and then cloxacillin. you might find that in dairy clocks or been in dc. so, you can see that all thesedrugs are very commonly used of for

mastitis or for taking care of of illdairy cattle and so we do test all tanker loads. so all tanks are clean of that before they're even off-loadedand used for human consumption. on the other hand, this new drug test that the fda has started to do as of january 2012, is to look at other classes ofdrugs that were seen in carcass violations that may be also be shedding in the milk. so, again they are concerned that because we're seeing these

increased number of residues in dairy carcasses potentially there are all these other drugs that are found in milk. we need to keep an understanding at howthis testing is going to be applied. currently, the fda just wants toknow what is the prevalence of increased residues that might be inthe milk that we're not testing for. so, they are really not interested in creating a violator list on the milk side because right now all the milkis being tested for beta-lactams then that milk is being dumped and those violators are being dealt with.

but, this is going to be a double blindedprocess so neither the milk processor nor the fda will know the source ofthe milk. they will have 900 samples comingfrom the repeat violators. if you look at the repeat violators list right nowthere is about 1800 producers on the repeat violators list. that willbe a producer that had 2 violations within 1 year on the meatside of things on the beef side. so, we are going to roughly test about50 percent of those producers and then they're going to pull900 samples from non-violators. that means we have roughly 63 thousand

dairy producers in theunited states and so you're going to be about 1.4percent of the non-violators to just see if there is any potential. i was down at the national mastitiscouncil in florida this past january/february and that matt mcknight, who is with the u.sdairy council, had a presentation where he mentioned that they are also going to test 300 commercial products and to see if we actually see if there are any

residues coming out on thecommercial side as well. so, all this is pretty scary stuff if we have some concerns that producers are not doing the right thing and holding the milk properly. i guess the question is what are you as a producer and what do you as a veterinarian to do to get this under control and make surethat we're not creating extra residues? first, we need to understand which setof label directions to follow. there

basically are 3 different kinds ofdrugs on a dairy farm. there are the over-the-counter product that you can buy from farm & fleet or any farm store without a veterinary prescription. penicillin is a great example of an otc product. then there are other products that are called prescription products and every prescription product has thislabel on it, "caution: federal law restricts this drugto use by or on the order of a licensed veterinarian".

we look at extra label drug use then thatis an over-the-counter or a prescription product that is not used according to labeland used obviously than in an extra label or off label approach. we need to keep in mind that thereare appropriate uses for each of these products and then you need to understand which ofthose labels to follow. lets talk a little bit about extralabel drug use because that is when you take a productwhether it is over-the-counter or prescription product and use it in amanner that is different than what is

written on the label. so when otc drugs that are used notaccording to label that requires there is a prescription. just like you go to your doctors and geta prescription for any other medication this is the same kind of thing withover-the-counter products used not according to label or an extra labelfashion. that prescription then requires that is being done within the context of what we call a valid

veterinary client patient relationship. so, lets talk a little bit about whata vvcpr is or valid veterinary client patient relationship. i have highlighted what i think are the key points that are sort of the sticking points in the vvcpr. currently, the avma and many of the otherveterinary medical organizations are trying to establish what are thedefinitions and the boundaries of a vvcpr. you will hopefully see that coming out of fully before the end of 2012.

but, we think about it the definition ofthe vvvcpr from the end of the medicinal drug use clarification act states that there is sufficientknowledge of the animals by the veterinarian to at least initiate a preliminarydiagnosis of the problems of the animal. in other words, the veterinarian has to have seen theanimals on the farm and certainly know what the the problems that are going on. that means that the veterinarian has beenthere or personally acquainted with the keeping care of those animals eitherthrough an examination

or what we might call herd health visits ormedically appropriate timely visits to the farm. now, what is timely? is that once a month?i guess really kinda depends on the operation. if the operation is you know a large feedlot and may not need to havean veterinarian there once a month, but dairy operation where

it is kind of a continuous flow process. it probably needs at least monthly visits to make what we would call a medicallyappropriately timely visit to make sure that things are working in a proper manner and that conditionsare being cared for. a practicing veterinary also has be readilyavailable for follow-up in case there is adverse reactions or failure of treatment therapy. so, we look at the definition of vvcpr youcan see it is fairly encompassing

but it's also a little bit broad.there is some fine tuning that need to be done. again, the avmaand other veterinary medical associations are trying to take care of that. but, as a veterinarian prior to prescribing or dispensing aproduct in an extra label manner the first thing i need to make sure isthat i will not create an illegal drug residue. so i need to make sure i take appropriate measures to get the producer to understand you have to hold the milk an additional length of time and

you have to hold the the animal on the farm additional length of time until there are no residues left. so that is sort of the circularargument as we get around it because that is our are caveat or tenant thatwe have to follow as veterinarians when we prescribe the product in an extra label fashion. when we think about when a producer istaking a bottle penicillin from lets a farm and fleet and buy it at the farm store and using it

extra label without a veterinary prescription then that limits the producersand is considered an illegal use because it has to be done again underveterinary prescription to be used in an extra label fashion. so, lets just take a look at the list ofdrugs right now that the fda is prohibited for use so everybodyunderstands. those first 2 ecp and diester patrol those are 2 estrogen products.

chloramphenicol is an antibioticalong with the nitrofurans.clenbuterol is a sort of a beta agonist and then you've gotdipyrone, glycopeptides, gentian violet, phenylbutazone which is a non steroidal anti-inflammatory much likeflunixin, but it is a now considered aprohibited drug and in adult dairy cattle. so, if we take a look at the drugs thatare prohibited from extra label use and now these drugs can be used in foodproducing animals. there are approved uses

but they cannot be used and it extralabel fashion. here we have sulfonamidies andsulfadimethoxine would be a very good case here because there are approved uses of albonr orsulfadimethoxine in all dairy cattle. in fact there is a meat withholding and a milk withholding but, they need to be used onlyaccording to label. which means if you are using the sulfa albone bolases then you can only use them for pneumoniaand foot rot. there are very

distinct uses. the fluoroquinolone such as baytril and well you cannot use the other fluoroquinolonesbecause they are not approved for use in dairy cattle, but baytril can only be used in dairy heifers. it is not approved for pneumonia so you cannot use it extra label. you cannot increase the does, you cannot use it for different conditions, and you can not use it for scours. that would be a prohibited usebecause it is only approved for in dairy heifers.

the medicated feeds are now prohibited for use. yearsago you used to be able to feed oramicin or trecycline crumbles to dry dairy cowsor something like that. it is now a prohibited use to feed medicated feeds to food producing animals. so, theyare only the approve uses which would be in dairy heifers and some of those other kinds of things. then more recently, here startingapril 1st of 2012,

there is now a prohibition on extra label use ofthird-generation cephalosporins. now, there is a little caveat to that because you can still use them and a veterinary can make arecommendation to use them in an extra label fashion as long as the veterinary stays on thesame route, dose, frequency, and duration of treatment. if you extend those or go on adifferent route or different frequency then that would be prohibited use of third-generation cephalosporins.

so, if we think about that from those standpoints there are some drugs that are prohibited, there are some that are prohibited fromextra label use, and some are approved to be used for their labeled uses. we need to keep in mind that the fdais actually looking for certain and so many of these antibiotics arefound in cull dairy cows but they are prohibited for use in female dairycattle xo over 20 months of age. most all of these are alsoprohibited for use in veal calves

so those young calves. if we findthem in veal calves and they were used extra label and if we find residue in an adult dairy cow that was probablyalso used extra. remember there is no tolerance for residues that are used in an extra label fashion. that is where the circular argument gets that yeah i could go ahead and use the flourfenicol in a dairy cow in an extra label fashion but, i

need to make sure that that dairy cow is kept at the farm long enough so that her meat and milk have no residuesby the time she goes to slaughter. that is the the circular argument weget into with the extra label use and the no tolerance. lets take a look at that how thatmight actually play out in some different ways. this is anapril of 2009 or maybe 2010

residue violation list that we can pull off the internet. you can see we've got that class ofanimal over here bob veal, dairy cows, there are some goats, and you can see the different tissuesthat were found. you'll notice in bob veal the flunixin and it was founded these tissue levels, parts per million, and there is a 0 tolerance listed. this is because flunixin is not approved for use in veal calves. here are dairy cows for gentamicin

found in the kidney detected. they don'teven report the level because of its detected any level because there's no tolerance it's considered a violation. drop down here to tilmicosin and tulathromycin in dairy cows and veal calf. again, both of these drugs are notapproved for dairy cows or veal calves

and detected with a0 tolerance. to play this out a little bitfurther lets take a look at this is again from that april 1st, 2010 residue violation system. you can see that here is a beef cow and there is tilmicosin found in the liver at these levels with a tolerance level of 1.2 and it is approved for use in beef cows.

micatil is approved to treatpneumonia in beef cows. micatil is not approved for use totreat pneumonia in dairy cows. so 2 different classes of animals, 2 different tolerance levels and you think that once you strip thehide off this animal it is basically a beef carcass now. he way that the fsis inspectors in the meat and packing plants

have to look at this is thatthis is a dairy cow. if tilmicosin is found at any residuelevel it must have been used extra label and if the drug was used in an extra labelfashion there are no of residues allowed. so, we get back into that circularargument that it may not be fair to the dairy industry that there is no tolerance but, on the other hand we are out here to produce a safewholesome food for the consumer. so, i get back to my question, why is the dairy industry under increased surveillance?

i want to use a littleanalogy here. i am going to show you a picture and this is a picture if you read down here below this is actually my ford explorer coming around cedar rapids, iowa and you'll see that the speed limit55 miles per hour and i was going 67. this is a speed camera that picked me up andis that a fair

way? actually what happened wasis i got a email from our her leasing agency the said you have an unpaid traffic citation. i looked up the email and said what isgoing on here and sure enough they caught me on a camera. so, when you take a look at it i had a nice 75 dollar fine because i was going over the speed limit plus a 20dollar internet fee, plus a 20 dollar fee so it was like 115 dollars

to a get out of this violation. is it fair? well, if you take a look atwisconsin and illinois that legal speed limit in these 2states is 65 miles per hour. with my new job i actually travel overhere in iowa, missouri, south dakota, nebraska, and kansas. when i'm driving around innebraska and kansas i can legally drive 75 miles an hour, but once into iowa i want you to slowdown the 70 miles an hour. when i get into illinois i have to slow back down to 65 miles an hour.

i guess the question i would ask is am i any less safe driving 75 miles an hour in kansas or 75 miles an hour anillinois? it is just the way that the regulations are. i guess if you think about this is a beef cow verses a dairy cow over here in these states it is of different regulation and thedifferent states and those of the regulations that we need to follow. so, when we start thinking about the reasonswhy we see an increased number of

carcass violations and residueviolations when we see increased testing. now we're were actually flaggingdairy cows more often and the meat inspectors are more suspicious i guessof dairy cows coming in because over the last 6 years we've seenincreased violations from dairy animals. we have more sensitive screeningtests and we've added flunixin into thetesting system. we have tests now the pick up antibiotics or residues at much lower levels

and so when you look harder with a moresensitive test you're likely to find more violations. that doesn't make the violations right it just means that there is more and wehave to be more cautious on how we are taking care of business at the farm level. this has led the fda to becomeconvinced that all the beef residues are a result of 1 of 2 things: extra label drug use or over the counter drug use withoutveterinary supervision.

so, if we take a look at that same listof antibiotics that we found from the fsis residue violationinformation system for 2009 member penicillin was number 1, flunixin was 2 and sulfadimethoxine was number 3. i starred the ones that are actuallyover-the-counter products that you can get over the counter. you can see there is a good number of them particularly 2 of the top 3 are otc products.

again, the fda's concern thatthese residues are coming from antibiotics that are being used over thecounter and use without veterinary supervision. they have actually made hints that all products are going to go prescription only. so, i guess the question is what do weneed to do as a producer? i think if we have adequate treatment records that help us identify which animals have been treated and which animals we need to hold for anadditional period of time. that is going to help us at the farmlevel make sure that no mistakes happen

and no animals get shipped in before their dueto be going to go into slaughter. first off we need to have uniqueidentification of all animals on the dairy. so, just having cow names and being ableto pick cows out by their color and by their spots is not going to be adequateanymore. we need to have some kind of hard idon the animal through and eartag or a clip

or even what we see now rfid or radio frequency id's. we need to maintain those treatment recordsfor a minimum of 2 years. some states like the state of wisconsin requirethat you maintain them for 5 years. think about your tax records. most of the time we maintain those for up to 7 years. then the treatment record needs tocontain the following information: have to have the id of the animal treated, the date she was treated,

the product that was given, the dose, the route and location of administration,and then also on that list has to be the earliest date that animal can be shipped either for slaughter or ifthere was a milk producing animal when you make sure that those milkwithholding times are established as well. i like to actually also have thename or initials of the person that administered the product.

coming from a history of managing adairy operation i understand from a compliance standpoint it's helpful to have that information but, quite frankly the fda does notrequire this. we have the name of the information but, it does certainly help from amanagement standpoint. so, then once we have good treatmentrecords we need to have developed a proactive residue prevention plan and we need to develop a written set of treatment protocols.

they need to be based on sound sciencebehind those treatment protocols. for every condition in that you might actually pull a medicinal out of the cabinet anduse on an animal to cure that animal, we need to have a nice written set of protocols that the fda or anybody couldcome in and look at that would say okay this is why how wetreated animal and how we withhold the milk. incorporating effective products andhave dairy-friendly risk residue profiles is

very important as well. we do have someproducts out here that are approved for use in dairy cattle that have very short withholding times because they are safe for humans after shorter withholding times. we need to follow the label directions. if you have the manufactures label and it is an over-the-counter products or ifusing a prescription product you can follow the manufacture label but againprescription products would be

prescribed by a veterinarian. if the veterinarian has recommended that you use the product inextra lable fashion the veterinarian will put an additional label on thatproduct that will extend the withholding timefor meat and milk. follow the label direction and don't try to shortcut those. we need to be very vigilant abouttraining our employees to how we want things managed on our operation. many of the errors of the violationsthat i've been involved with had been

because of lack of communication betweenmanagement and their employees on what the expectations are for holding animals out until their withholding times are are completed. we need to make sure we keep good records and we think about it daily is much morebeneficial than coming in once a week and plotting all the records downand plugging them in once a week. so, daily records at least writtenrecords in the barn and then maybe once a week you can enter them into thecomputer but,

the main thing is is keeping goodrecords because the records are going to be your salvation. if you have a violation records are going be what you getyou out of it. let me just use an example here real quickly because we had a a producer in northernillinois that had a of violation in young calves and it was a residue violation. what happened was the

cattle buyer that picks up a bull calvesonce a week or twice a week his truck broke down so he couldn't pick upcalves for a little while until the truck was fixed. so the end of keeping their bullcalves around for 2/3 weeks until the guy fixed his truck and as soon as he had gotten his truck fixed he picked up a group of bull calves off this dairy operation. he had a couple that really had grown well and looked great so he sent them to a veal plant to get slaughtered.

well unbeknownst to the cattle buyer and the cattle hauler one of the calves had gottena naval infection. so the girl works the calf barnat this dairy operation read treatment protocol said calf withthe naval infection gets 3 to 5 ccs of penicillin 1 a day for5 days. so, she treated the calf according to what a naval infection gets treated with written protocol and she had documented that the calf had been treated. the only problem was she didn't document

when that calf could go to slaughter. so that calf was shipped from thefarm before the slaughter withholding was met and that farm then had an antibioticviolation and they are on the residue violator list. the fda did come in to investigate that that incident. they were there for a very shortperiod time because all they had to do was open upthe books the books said here's our written protocol for naval infection,here's the cafe got treated, and

we got the treatment records that showwe treated that calf. we just made a mistake and shipped the calf before its slaughter withholding time. so they've implemented differentprocedures then to make sure that any animal that gets treated, calf or cow,has some kind of identification on it until a slaughter time is over. again, the records saved this operationfrom a more extensive investigation and so records will be your salvation there. lastly, we want to make sure that we verify again that meat and milk withholding time for

every animal before goes into the food supply. so one other little story i like to tell here is that had a another producer this is on thecow side that had a pen of cull cows they're ready to go to slaughter.the cattle buyer picked up the cattle and they were is actually 9 cows inthe pen and only 8 were supposed to go but, all 9 cows were on the truck. one of the cows had a residue and it was not intended for that cow to be shipped

but, she end up getting on thattruck as well. now the owner of this operation he creates alist on the day that the cattle buyers coming to pick up and everybody has to cross-check thatlist before the animals leave the operation. there is a double checksystem to make sure that that no cow it's on the trail of the wasn't supposed to. finally, we need to watch out for whatwill call exceptions and again this is the 1 percent.

when a cow is really sick or calf isreally sick through dehydration and kidney and liver do not function properlyeven if you use the drug according to label it may have some residues left in the calf. this is because of the organ failure thatoccurs during some really severe disease. but, these are the exceptionsnot the rule so don't use that as an excuse. if i did have a really sick animal itmay be worthwhile to keep her on the farm

30 to 60 days past her withholdingtime just to make sure everything's cleared up before she could go into slaughter. in summary, we know that residue monitoringare going be come much more stringent and much wider in scope. so, any producers that's making their ownextra label decisions such as extra label use of penicillin and they may be in for an expected outcome.this may mean that they might have an fda investigation coming their way

and that might lead to further sanctions. we also have to keep in mind thatprotocols and prescriptions are legal document between the veterinary and the herd owner. so those directions must be followed. meat and milk withholding times must be adhered to and that if there are any changes to adrug residue protocol it has been done with the authorization ofthe veterinarian. without that the producer is taking that liability in their own hands.

so, lets make sure we take the high road and remember that yes we are here as adairy industry to produce milk but, every dairy cow has 2 careers. it first starts with milk and then itfinishes with beef. so currently the society trust dairy producers to make wholesome milk and beef and wedon't want to violate that trust. thank you for visiting with us on residue violations.