Author: Joan S. Bowen, DVM, Bowen Mobile Veterinary Practice, Wellington, Colorado
Publish Date: Summer 2015
The American Association of Small Ruminant Practitioners listserv held a very lively discussion regarding use of social media as a way for livestock producers to seek veterinary information about their sick animals. Many producers search the internet to self-diagnose their animals’ health problems, but they lack the ability to thoroughly examine their animals and the knowledge to distinguish between fact and fiction. At least one Facebook group offers producers a forum to describe abnormal health conditions in their animals and seek diagnosis and treatment recommendations from veterinarians who participate in this group.
The veterinarian who started this website has good intentions for helping people who say no veterinarian is available in their area or they cannot afford veterinary expenses. Those supporting this concept say the veterinarians participating on this website are providing help through improved management practices, nutrition and health care while encouraging producers to seek veterinary care and decrease unnecessary or illegal drug use in their sick animals. One respondent commented that increased use of video clips from cell phones and the ability to video chat with a veterinarian online will be another way that veterinary medicine will be provided in the future.
The practice of veterinary medicine has changed dramatically over time. Prior to the Food, Drug and Cosmetics Act of 1958, veterinarians could prescribe or administer almost any drug available for treatment of adverse health events in animals without concern for drug residues that might occur in those animals. By 1968, Congress passed legislation that strengthened the provisions of the Food, Drug and Cosmetics Act pertaining to regulation of drugs used in treating animals. Animal drugs, medicated feeds and food additives had to be safe for the animals for which they were intended, and if food-producing animals, safe for human consumption and the environment.
Over time, regulations for drug use in animals have become more restrictive due to concern for the presence of potential drug residues in food products from treated animals and for development of bacterial resistance to antibiotics. In the 1950’s, chloramphenicol was approved for treating very serious bacterial infections in people and later for use in dogs and cats. However, the drug was never approved for use in livestock species because it caused fatal aplastic anemia in some people. In 1981, a feedlot producer treating cattle with pneumonia accidentally got chloramphenicol in a cut on his hand and died several months later from aplastic anemia. FDA notified veterinarians nationwide about the danger of using this drug in animals and finally banned use of the drug in 1986 due to the alarming number of drug residues found in animal products intended for human consumption. Over the past thirty years, FDA has banned 7 drugs or classes of drugs in food-producing species, restricted the extra-label use of 5 classes of drugs from food-producing species, and restricted an additional 4 drugs from use in dairy cattle. Yet low numbers of violative residues continue to occur in animal products for human consumption.
Recognizing that very few drugs are licensed or labeled for use in animals, Congress passed the Animal Medicinal Drug Use Clarification Act in 1994 (AMDUCA) which gives veterinarians greater flexibility for using their professional judgement to treat animals. Under AMDUCA, veterinarians may use drugs in animals that are approved for use in humans or animals, drugs approved in one species for a different species, or at a dose different from that on the label if certain requirements are met. An important requirement of this legislation is the obligation to establish a veterinary-client-patient-relationship (VCPR) between the veterinarian and the owner of the animal(s).
AMDUCA, state veterinary medical practice acts and the American Veterinary Medical Association code of Ethics list five requirements that must be met in order to establish the VCPR which would allow a drug to be used in an animal different from its label. The veterinarian assumes the responsibility for making clinical judgments regarding the health of the animals and the client agrees to follow the veterinarians’ instructions. The veterinarian has sufficient knowledge of the patient to initiate at least a general or preliminary diagnosis of the medical condition of the patient. The veterinarian must be personally acquainted with the keeping and care of the patient by virtue of a timely examination of the patient by the veterinarian or medically appropriate and timely visits by the veterinarian to the operation where the patient is managed. The veterinarian is readily available for follow-up evaluation or has arranged for veterinary emergency coverage and continuing care and treatment. The veterinarian provides oversight of treatment, compliance and outcome. Patient records are maintained.
Both producers and veterinarians are in violation of AMDUCA when producers use social media to contact veterinarians who have not visited their property, examined the animals in question, observed the management practices or agreed to work cooperatively together to diagnose and treat the animals. The long distance veterinarian on social media is unlikely to be available for follow-up evaluation or continuing care, and patient records are unlikely to be maintained. Only veterinarians have extra-label privilege, and the producer who searches the internet to self-diagnose their animals’ illness cannot legally administer drugs to their own animals in a manner different from the product label.
A better practice would be for the animal owner to contact a local veterinarian prior to needing emergency care to develop a working relationship with that veterinarian. When livestock are involved, the owner should have the veterinarian visit his or her property at least annually so that the veterinarian can observe the animals, evaluate their condition and become aware of the management practices of that premise. This annual visit can be very useful to the client as the veterinarian can examine the nutritional program, body condition score the animals and look for subtle conditions that the client may not have observed. The ability to examine the affected animals in their natural environment is invaluable when trying to diagnose health challenges and develop treatment, control or prevention programs. The onsite visit provides both parties with the opportunity to ask questions, exchange information and meet the requirements of VCPR so that the veterinarian can choose from a greater variety of medications when health problems occur. To overcome long distances between producers and veterinary services, several clients could schedule their annual visit at the same time to share the cost between them. If the local veterinarian is less experienced with the species involved, then several clients might share the cost of an excellent medical reference or pay dues for that veterinarian to join a species specific veterinary medical association.
When an animal owner seeks veterinary advice over social media, the veterinarian is dependent on the ability of that owner to accurately observe the animal, determine its health status and convey that condition to the distant veterinarian. Veterinarians are familiar with normal anatomy, behavior and physiology of multiple animal species and have been trained over several years to observe, examine, sample and test animals to determine a diagnosis and develop an appropriate treatment program. The veterinarian trying to diagnose health conditions over social media based on the observations of a producer he or she has not met may not receive all of the information necessary to develop an accurate diagnosis. The opportunity for misdiagnosis and inappropriate administration of drugs with resulting violative residues is far greater when the producer and veterinarian have not met the requirements of the veterinary client patient relationship as required by law.
Helpful references for drug use in animals: