Beyond the label: extra-label drug use and food safety - Part 2

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00:00:54: Thank

00:00:56: Let's talk about some of the specific lessons you've kind of learned over the years with CG Farad.

00:01:01: Yeah, we have had very fun cases and I've learned a lot... And i know that the Compendium of Veterinary Drugs backwards and forwards these days!

00:01:10: To do it in humorous way- I kinda center around definitions no to zero.

00:01:16: So here are my paperclip examples from actual drug approvals that are kind of worth mentioning.

00:01:26: So sometimes when you look on a label, zero isn't actually zero and this is kinda not written down legally anywhere.

00:01:37: but this what both the US and Canada uses for zero For livestock withdrawal tissues it's actually eight to twelve hours.

00:01:46: so that means really can be injecting this if your as steer walks into the slaughter plant.

00:01:54: For milk, it's actually twelve hours based on the original milking schedules everyone did of every twelve hours.

00:02:03: And then we had Darrys doing three times a day and now we have the robotic milkers where cows can milk themselves up to four times per day.

00:02:13: But we have other issues with milk but I'm not quite sure how that impacts what the label withdrawal time are.

00:02:21: We're gonna talk more about label withdrawal times for milk.

00:02:24: And then for poultry, it's actually six hours.

00:02:26: Most of their products are feed and so they're pulling the feeds six hours before they go to slaughter.

00:02:32: So a lot is even though zero isn't zero in those cases The practical implications aside from the dairy one where we'll talk bit more about really We kind of taking into account that animals aren't going immediately to slaughter right after we give them That dose but also means there there is that little bit of timeframe that needs to pass before they're ready to go.

00:02:56: Is that right?

00:02:57: Yeah!

00:02:58: So zero, so...is it a point in time where nothing's zero?

00:03:03: Well sometimes nothing is zero.

00:03:06: and this one came up.

00:03:07: Keeter Proven has approved for lactating dairy cows but the label is silent about a milk withdrawal time.

00:03:13: It just doesn't say anything.

00:03:15: But we do have an MRL for keto proven and I mentioned earlier.

00:03:18: ketoprofen is a human drug So it's quite high.

00:03:21: And so no milk withdrawal period as needed.

00:03:24: They just forgot to say anything on the label which sometimes makes people wonder a little nervous, right?

00:03:29: Sometimes nothing is zero but It's just for meat.

00:03:32: and so this one is kind of weird.

00:03:34: On the twenty percent sodium iodide bottle would people use for treating lumpy jaw.

00:03:40: There's a semiti to our milk withdrawal time, but it silent on the meat with drawl time.

00:03:45: Well... It turns out that iodine in milk is human food safety concern and so thats why there are withdraw times for milk But they really wouldn't be anything to detect in the meat.

00:03:57: So then they just are silent.

00:03:59: no withdrawal period as necessary.

00:04:02: One of those cases again where its not explicitly stated on the label.

00:04:07: You kinda have to be aware.

00:04:08: And then sometimes nothing isn't zero.

00:04:11: So when I came to Canada and started working with the CG Farad, I noticed something really interesting.

00:04:17: Dexamethasone had labeling for treatment of ketosis in cows.

00:04:22: Ketosis is a kind of disease of dairy cow.

00:04:25: so that also implies milk right?

00:04:28: But label was silent.

00:04:29: no meat or milk withdrawal times!

00:04:31: And i knew steroid hormones in food supply does not sound like good headline and that there was no way, then the veterinary drugs director had never established meat or milk MRLs for dexamethasone.

00:04:50: And so if there's no MRL CFI by default goes to limit of detection.

00:04:55: So I knew it really couldn't be zero.

00:04:58: But veterinarians and producers tended to interpret it that way because... That was kind of true for ketoprophin, right?

00:05:04: And so at the CG Fair ad we looked and found very limited data.

00:05:09: Very, very limited date!

00:05:12: So we gave a very conservative withdrawal time if anybody ever asked us.

00:05:16: but there were whole lot people who weren't asking us cause they're resuming.

00:05:19: nothing is

00:05:20: actually zero.

00:05:22: So we tried for a really, really long time to get funding for this.

00:05:27: And I got to say that finally my co-director gone Dr Ron Johnson from the Ontario Veterinary College much better at raising money than i am.

00:05:38: he secured The Funding so We could do the study?

00:05:51: It was the most downloaded publication that year, showing that this information was of great interest on a global scale.

00:06:00: And in it we recommended MRLs and based on our data recommended the MRL's that are used for dexamethasone in the European Union.

00:06:09: So then The Veterinary Drugs Directed legally established the MRRs that were recommended... ...and finally just recently the Pharmaceutical Companies That Produced Dexamethasone Products are able to add the withdrawal times based on our work onto their labels at no cost, so this is a fantastic example of how we noticed an issue.

00:06:34: We got research done and basically changed law and approved labeling for everybody's benefit.

00:06:47: Yeah, that's a big feather in the cap for CG Farad.

00:06:49: I think that really just highlights the service it provides to the industry.

00:06:55: Those Deximethylzone products are approved here in Canada.

00:07:00: It wouldn't be something they would have undertaken on their own because of costs involved.

00:07:06: But its great that CG Farads was able do this.

00:07:09: So is there times when zero isn't zero?

00:07:14: Yeah, unfortunately we got that.

00:07:16: Antimicrobials like seftifur and cephapyrin for intrauterine use used to have zero milk withdrawal times on their labeling.

00:07:24: so the legal MRLs in milk for sefti fur is a hundred parts per billion.

00:07:30: So remember my paperclip?

00:07:31: And twenty parts per million for the cephaphyrin!

00:07:36: These are the legal MRL's established federally but the Canadian Milk Supply is provincially based and regulated.

00:07:46: The processors are provincially-based, so for example in Saskatchewan I dug through the milk regulations And a legal statement is no person shall sell supplier offer for sale any Milk that contains antibiotics insecticides herbicides So on and so forth.

00:08:06: they don't say antibiotics above the legal MRLs.

00:08:10: It just says antibiotics.

00:08:12: So the processors are free to choose the antimicrobial screening tests for the tanker trucks that have limits of detection, and they're below the legal MRLs.

00:08:24: So this is where a withdrawal time established on the label doesn't always... Is based

00:08:29: in an MRL?

00:08:31: Yeah

00:08:32: Not the limit of detection.

00:08:35: And so it kind of goes back to the people who make the screening tests or analytical chemists, and they just want to get better and better.

00:08:43: They offer the processors these multi-residue tests... ...and for milk they'd offer them for penicillin sulfas in tetracyclins but not the other antimicrobials.

00:08:54: But the milk is always screened for those three classes of drugs by using a screening test.

00:09:01: So the one that is probably most commonly used now, it's something called the charm triotas.

00:09:06: And thats three classes checks for beta-lactam, tetracyclins and sulfonimides... ...and it detects all of drugs in those class below the legal MRL.

00:09:17: every single one of them!

00:09:19: So for sephifera can detect as little as fifty-three parts per billion.

00:09:24: so about half to legal MRR.

00:09:26: and sephapyrin can be detected at fourteen part per billion.

00:09:31: It is extremely self-sensitive for the sulfonamides.

00:09:35: All sulfonimides have a legal MRL of ten parts per billion, and The Charm Trio can pick some of them up at one part per billion.

00:09:44: So one tenth the actual legal safe limit.

00:09:48: so Detections that these concentrations are not false positives But test.

00:09:53: people get really excited if you call them false positive because the drug Is actually there but it's just legal.

00:10:00: So we call them sub-violative positives.

00:10:04: Unfortunately, veterinarians and producers do not understand that the milk can be dumped for sub-violentive positives... ...and the producer is going to incur the penalties of having caused a hot tanker because usually the contract going through down to the producer.

00:10:25: No antibiotics in the milk.

00:10:27: And so what usually saves us is, The solution to pollution is dilution.

00:10:33: So it helps us out In most cases and I hate To say this way.

00:10:37: but the solution to Pollution Is Dilution.

00:10:41: If one cow gets treated with One of these no withdrawal needed drugs But still has residues That would be above the limit Of detection.

00:10:52: If her milk gets diluted in the bulk tank and then diluted into a tanker truck, it's just fine.

00:10:56: It

00:10:56: won't be picked up

00:10:58: right?

00:10:58: But if many cows get treated you've got respiratory outbreak or something like that... Or your tanker makes-up of whole tanker trucks are big dairy.

00:11:11: this could an issue And so governments know on very rare occasions perfectly safe and legal milk will be dumped because it tripped the positive test with a screening tests.

00:11:25: The problem here is that, its'a screening test.

00:11:29: It's qualitative but not particularly quantitative And so just as positive...it doesn't say how positive Doesn't says.

00:11:38: you know..its above the detection But below the MRL.

00:11:42: But producers or processors have to keep their milk supply running.

00:11:47: If you want to do quantitative and specific tests, You have to do things like HPLC mass spectrophotometry.

00:11:54: Those test take days right?

00:11:57: And you can't have the milk truck sitting there waiting for the confirmatory tests Right.

00:12:03: so they simply accept that every now and again That perfectly safe in legal milk will have to be dumped To keep the milk supply rolling

00:12:11: great.

00:12:12: and you gave the example of Saskatchewan's kind of processor and the agreement there, but this isn't just Saskatchewan.

00:12:19: This is across Canada that each province has probably a little different... But it would be similar situation?

00:12:28: Exactly!

00:12:29: And some provinces will have multiple processors using different screening tests so you could have milk positive at one process or negative in another.

00:12:45: So we want to really educate dairy practitioners about this and so for every dairy request, We actually give them a handout that I wrote.

00:12:55: That sort of explains everything About the detection of residues in milk And gives some guidance about different cow side tests you can use what their sensitivities are.

00:13:06: In Saskatchewan The processors is really nice and has set up testing stations where you can test your milk with their same tests so that you can ensure.

00:13:16: And these are all practical safeguards, unfortunately most people don't take advantage of this until they've had a positive task and incurred the penalties.

00:13:26: but we would like to be proactive here.

00:13:29: So for veterinarians who're using drugs in an extra-label manner in lactating dairy cows They could certainly contact us at the CGFARAD if we have any data available, and there are lots of good studies out there about other families say antibiotics that are being used in lactating dairy cows.

00:13:48: And what we will do is we will recommend a minimal withdrawal period and then say followed by testing .

00:13:56: If you can't recommend the test ,we'll tell them to contact their processor because if the processor says it's good, then its going to be good.

00:14:11: So we really do hope that people will do that Now We Do Have Some Advice In The Case Of A Positive Test Happening.

00:14:20: If They Will Call Us Because As I Said The Tests The Processor Use Screening Test And There Could Be Subviolative Positives.

00:14:28: We Asked That You Try To Get A Sample of The Positive Test as Soon As You Can and Send It To A Laboratory that can do that quantitative and specific kind of testing.

00:14:40: And so the two that we usually talk people into contacting is Bureau Veritas, it's a contract laboratory for The Canadian Food Inspection Agency ,and they do an amazing job.

00:14:53: I recommend them but its gonna cost you somewhere like three hundred to six hundred dollars as sample if you want an urgent answer.

00:15:02: The Agriculture and Food Laboratory at the University of Guelph also offers residue testing services.

00:15:09: So, this is really important!

00:15:11: And I wrote this up as an article for the Canadian Association of Bovine Practitioners newsletter.

00:15:18: so if you want the whole story that's going to be coming out in the news letter but where three or three thousand dollars worth of milk was getting dumped every other day for weeks.

00:15:31: And when they contacted us, we said that you need to send a sample and it was positive for solvus.

00:15:39: We needed to send the sample To one of these laboratories who can pinpoint what drug It Was and What The Concentration Was?

00:15:47: So A Sample was sent to Bureau Veritas And they tested for over twenty different Sulfa drugs including a bunch of human ones, type two diabetes.

00:15:58: They tested it for everything and then lo and behold there was positive for Sulfathiasol at four parts per billion.

00:16:08: The limit detection that the assay used on screening is one part

00:16:14: per billion.

00:16:15: So are their times when... You know, we talk about that definition of zero.

00:16:20: Is there times when something should have a zero on it but doesn't?

00:16:24: Oh yeah this one came up some years ago and its oxytocin

00:16:30: right.

00:16:31: so

00:16:31: I was on the original committee That was asked to evaluate bovine somatotropin BST for its use at increasing milk production.

00:16:41: There was another Committee that looked at human safety and couldn't find any issues, but I was on the veterinary committee.

00:16:48: And basically we proved everything on the label.

00:16:51: if you make a dairy cow produce more milk guess what?

00:16:55: She's more at risk of things like mastitis feet leg problems and early culling.

00:17:02: those are just facts!

00:17:04: Then they came to us said so it is bad for cows And we go, We didn't say that.

00:17:11: Then they decided the vet committee said it was bad for cows and did not approve BST in Canada.

00:17:16: so yeah That's very interesting.

00:17:19: So then They kind of noticed oxytocin can be injected into a dairy cow to increase milk let down.

00:17:28: Sometimes people will do this with nervous heifers when their coming into parlor.

00:17:33: But I guess there was a fear that instead of being able to use BST, they would just be giving oxytocin to everything.

00:17:41: So... There's different labels on different labels for the same product which is little weird but it carries a twenty-four hour milk withdrawal time unless you give just one mil IV.

00:17:54: Canada as only country we can find in whole world has withdraw times for oxytosin The synthetic products is chemically identical to the natural hormone.

00:18:06: You couldn't determine a residue unless you radioactively labeled this stuff, and then that would be all another set of problems for using it!

00:18:16: So there's no residues to measure or human safety concern.

00:18:21: so this one really bothers me because any demonstrable residues.

00:18:30: This is trying to control production practices with a withdrawal,

00:18:34: right?

00:18:35: And we also kind of see this little bit with prostaglandin products as well where no actual residue data was used to develop the withdrawal time.

00:18:45: that's on the label.

00:18:46: so We just kinda saw and we cannot give advice to shorten illegal label

00:18:52: Right.

00:18:52: So...

00:18:54: That's kind of what it says.

00:18:56: Perhaps that might be something down the road.

00:18:57: That CG Farad is able to kind of change some of that, but Of course you are dealing with...

00:19:04: We did write an opinion piece But-but that's what they got.

00:19:07: was twenty four hours

00:19:09: Right right?

00:19:10: and then we talk about warnings on labels where You know?

00:19:15: You should not use it in this type of animal or in this stage of production.

00:19:20: Is there times when no doesn't mean No?

00:19:24: Yeah, there's a lot of time when no actually doesn't mean.

00:19:26: No A Lot of products will say not for use in breeding animals and that usually just means they didn't test it breathing animals.

00:19:34: So you know again?

00:19:35: We'll look at that.

00:19:36: go yeah There's no issue here

00:19:39: right one

00:19:39: That comes in commonly for us is vitamin E and selenium products that have warnings Not to be used in lactating dairy cattle.

00:19:47: But we can think of a scientific reason why this would either be a human food safety concern or a residue problem.

00:19:54: But since it's extra-labeled drug use, we do give a minimum twenty four hour milk withdrawal recommendation.

00:20:02: Okay?

00:20:03: That is not illegal thing in Canada but under Amduka and the United States... It says that in case of extra label drug use they greatly extended withdrawal recommendations should be given.

00:20:17: so were honoring this spirit Yes.

00:20:23: And if you're going to do it, we don't want a circumvent getting labeled products.

00:20:36: and so

00:20:49: important to clarify too is that even with the recommendation, it's still at the end of day.

00:20:56: It's still on the responsibility of the prescribing veterinarian as far-

00:21:00: Yes and we put that disclaimer all over our responses because were not there

00:21:07: right?

00:21:08: We get just a snapshot what their problem and we don't know that the body weight is accurate.

00:21:17: We do say ultimately responsibility resides with the prescribing veterinarian, but something were to happen.

00:21:29: you got ten billion McDonald's burgers recalled and got hauled into a court of law?

00:21:35: And asked how came up your withdrawal recommendation?

00:21:39: I made it

00:21:42: Yes, that's not

00:21:42: gonna sound quite as good is?

00:21:44: I consulted a scientific advisory service and we would be there to show how he came up with our recommendation And why?

00:21:54: We thought it would be safe for human food consumption.

00:21:58: And right hoped It would be good enough to not have a detection.

00:22:02: But this is something where you know as a vet i mean That just kind of shows us she did your duty due diligence.

00:22:09: I mean, no system is foolproof but it is something where i think that kind of at least gives you Something to lean against.

00:22:15: as far As like he said You're not just making It up out thin air

00:22:19: And Im very happy To say That we've Not had an issue in Canada In the twenty four years.

00:22:25: We have been in operation Right.

00:22:28: You know that on occasion, see if I has checked our recommendations like did some residue testing and nothing was discovered in the United States?

00:22:37: I know they've had two cases.

00:22:39: In one, the veterinarian lied They have not contacted this service And everything is computer recorded.

00:22:48: So every request gets an ID number And so, we've had a few where people tried to use somebody else's or something like that.

00:22:57: We can check back and say no!

00:22:59: That was done here for this situation.

00:23:02: The other one in the United States it actually involved Jentemiacin at a dairy cow.

00:23:07: They asked years previously.

00:23:10: new data came out and withdrawal greatly lengthened.

00:23:15: they have not checked back.

00:23:17: So both services have a really good track record and on the occasions where it was an issue, It Was Determined Not To Be The Fair Ads Fall.

00:23:26: Right that's always... That just kind of you know gives credibility to the organizations And You Know The Value That That Provides The Service.

00:23:36: Okay When Does No Really Mean No?

00:23:41: Or Do Ya Have Some Examples Of That?

00:23:43: Yes The C.T.

00:23:45: Farad is very familiar with the federal law wherein it comes to banned drugs and the list is fairly short, And the drugs are banned.

00:23:55: that means It Is not about residues its About record keeping.

00:24:00: so if an animal or Its products of an animal has ever been administered a band drug That animal Or its product.

00:24:07: So milk in the case Of a dairy cow must never enter the human food supply Not In a year, not in six months.

00:24:15: It's an absolute never so that the legal law and veterinarian who prescribes such would be quite liable.

00:24:22: And in case of breaking a law malpractice insurance usually doesn't cover you.

00:24:28: So if we look on label for something like nitrofurescent ointment there is warning states do NOT use food producing

00:24:39: animals.

00:24:40: Now, nitrofurozone is on the list of banned drugs.

00:24:44: So if treated with cow or milk whatever can ever enter the human food supply.

00:24:50: it's about records not residues.

00:24:52: and Nitrofurosone used to be given orally to animals And that's really what they're talking about.

00:24:57: but the topical falls under the same ban law because the law doesn't say anything without route where it gets complicated, and like that's what is says do not use in food producing animals.

00:25:08: It's not a very strong warning.

00:25:11: you know they could take the lesson from cigarettes.

00:25:14: yes.

00:25:16: so when we look at a jar of phenyl butyzone tablets label says Do Not Use In Food Producing

00:25:22: Animals.

00:25:24: But Phenylbutyzone Is Not Banned By Federal Law!

00:25:27: Its' not great idea because have lots approved NSAIDs for cattle.

00:25:32: But the CG Farad will give withdrawal guidance if we get a request for it being used in food animals, because there's actual data out there.

00:25:41: So this can be very confusing and-and We really wish that was some sort of you know red sticker or something like that.

00:25:50: Because quite often products are misleading Like the Nitrofurosine Ointment The label which is the company's label not specific to this ointment.

00:26:00: It has a horse, a cow.

00:26:02: A sheep or goat.

00:26:03: A pig and chicken on

00:26:04: it.".

00:26:05: And those are trying to food animals!

00:26:08: So people don't read the small print... ...and they don't realize that they're looking at a banned drug?

00:26:13: Right.

00:26:14: Is there a website or repository for those banned drugs...?

00:26:20: You said there isn't very many in this list but is there place where you can access them?

00:26:26: Well if you have time to read The Federal Drug Act

00:26:30: Right.

00:26:34: It's kind of buried in there, but I have pulled it out and so we have it handy.

00:26:41: Okay

00:26:42: Perfect Yeah There is a section B And A Section C So its about selling the product Then Its About Administering The Product.

00:26:49: You Kind Of Gotta Put The Two Together.

00:26:53: From All That I Think Those Are Excellent Examples.

00:27:00: When no means know and when it doesn't, what does zero mean?

00:27:04: And lots of different things.

00:27:06: Are there are that you're not really in the gray zone that your totally not sure

00:27:11: of?".

00:27:12: Well I got one for a while.

00:27:14: even kinda stumped me...I gotta request about administering five units per site of Botox to beef heifer with a salivary fistula!

00:27:26: At first i was sorta like hell.

00:27:28: no

00:27:29: Right.

00:27:30: Because it used to be I got taught a teaspoon of botulinum toxin could kill Philadelphia,

00:27:37: right?

00:27:37: Yeah But

00:27:38: but nowadays people inject the stuff into their face Which is why nobody in Hollywood can make an expression anymore.

00:27:49: And so i thought about this awhile.

00:27:52: and you know realize if your using the stuff for faces then its probably not very concentrated.

00:27:58: And there's actually some literature about botulinum toxin being useful for these salivary fistulas.

00:28:06: But

00:28:06: of course, there is no data on it.

00:28:08: withdrawal time Now certainly are cases where unfortunately somebody bails a dead animal and gets in the hay or the silage.

00:28:17: There was this spectacular case in Aderian California Where all cows were clinically affected with botulism from from a dead animal in the feed, and they did detect botulinum doxin in the milk.

00:28:32: But again that was enough to make the animals clinically ill.

00:28:36: so this is going be much less of dose yeah but I didn't have really explicit data ,but i wasn't concerned about either detection or human food safety concerns .

00:28:49: So just gave very conservative recommendation.

00:28:52: This was beef heifer.

00:28:53: she isn t going to slaughter anytime soon But the practitioner was doing their due diligence because they were using a human drug extra label in a food animal.

00:29:02: Yes,

00:29:03: there you go perfect.

00:29:05: so I'm sure you've got other situations and kind of classic thing if some is good more must be better.

00:29:15: have you had uh...some instances with that?

00:29:18: Yeah this one's great cause it involves pesticides and pesticides are not drugs.

00:29:24: It was a New Year's Eve and I happened to be in the office, an urgent request came in.

00:29:32: And on a particular operation The Herdboss' father decided to help out by administering silent Cyfluthrin which is a synthetic pyrethrin onto the dairy cows that it is approved for use in dairy cows.

00:29:49: so there isn't MRL for milk thing on the top of it.

00:29:55: And so you, get away to the cow and then put the appropriate

00:30:00: mount-on.".

00:30:01: But he didn't think that was very efficient!

00:30:03: So he got a soup ladle...so I like to joke there's extra label than there is an extra ladle right?

00:30:12: He puts several ounces of product rather.

00:30:19: So exposures levels were as high as fifty times the label dose.

00:30:23: And the cows are actually showing clinical signs of Cyfluthrin toxicity, like a cat who got into the dog's permethrin.

00:30:33: they weren't twitching and hyper excitable it was a wreck.

00:30:38: so anyway I got to call in.

00:30:40: i was like oh dear this is bad because cyfluthrin has a pesticide and pesticides cannot be used in an extra label manner.

00:30:49: In Canada, not by veterinary prescription or anything.

00:30:56: The real goal is protecting waterways from pesticides on crops where you would have huge exposures.

00:31:05: but the law of the law.

00:31:06: there's the PCP Act Pest Control Products Act.

00:31:10: You can just read words.

00:31:11: it doesn't make exemptions for treating cows Right.

00:31:15: So because of this, I had to say you have to call the CFIA and so all the milk had to be held it.

00:31:22: how did he tested for days?

00:31:24: This was a waste product is very expensive mistake to make.

00:31:29: Yeah

00:31:31: You can tell that there's going to be a PCP number on instead of drug identification

00:31:40: number.

00:31:41: So PCP, Pest Control Products Number instead of a Drug Identification number.

00:31:47: But the warning is equally Canadian and mild.

00:31:50: in says this pest control product is to be used only in accordance with the directions on the label.

00:31:55: it has an offense under The Pest Controlled Products Act.

00:31:58: use a controlled product In any way that's inconsistent With the directions On the label.

00:32:03: Not heck.

00:32:04: no You get That.

00:32:06: Now.

00:32:07: if you dive into the PCP act because I do such things you actually find that offenses can occur up to a two hundred thousand dollar fine in six months in jail.

00:32:18: Not insignificant, eh?

00:32:21: And this again goes if a practitioner recommends or prescribes us their malpractice insurance will not cover them because it's an illegal act.

00:32:30: so we get this a lot where people want to use pesticide products labeled for cattle on goats or camelids and things like.

00:32:39: And I'm sorry if they have parasites, but we can't break the law

00:32:45: right.

00:32:45: well and II Have to think that this The person that was using the ladle.

00:32:50: I think back to the early days when as in practice When we still had organophosphates?

00:32:55: Of course you're using the dipper To apply that product to the backs of animals instead of the tiny little piece on the top of the jug of the silence product.

00:33:08: Probably partly what was behind this gentleman's thought of using that dippers because that's what we used to do with the with the organophosphates, but

00:33:17: and I'm sure you And i can remember those nice cases of organophosphate taxes.

00:33:21: Yes

00:33:22: Yeah well all I could say is I remember having headaches after After prank checking on on those animals just cuz it never had my arm out of the cow before The producer applied the product to the back.

00:33:36: so I'm sure i got some exposure.

00:33:39: Yeah, actually am very glad those products are mostly gone because they were very hazardous for humans and animals.

00:33:47: All right vaccines.

00:33:48: we haven't talked really a lot about that.

00:33:50: but they're not drugs either?

00:33:52: They don't have a den.

00:33:54: no yeah vaccines or different branch of health.

00:33:58: canada deals with biologicals.

00:34:00: So biologicals are things like plasma products, colostrum replacer interestingly.

00:34:06: You know some of your MAB products and things like that but mostly what we deal with their vaccines.

00:34:11: so they don't really fit under our mandate because they're not drugs.

00:34:16: But the Canadian Food Inspection Agency is pretty happy when we assist with withdrawal guidance When vaccines are used extra label And some of them are pretty innocuous.

00:34:27: Like there's poultry products That are supposed to go in water But they spray it on the birds because that's easier.

00:34:32: And then, the birds preen themselves and they ingest it.

00:34:36: There are certainly no issues with residues when it comes to vaccines.

00:34:41: Some of them will have a little amount of an antimicrobial like gentamicin in the vaccine but there is not enough of that to cause a detectable residue or tissues.

00:34:51: That just isn't the issue

00:34:53: Right?

00:34:56: When you read actual regulations about biologics It just kind of says we should use them according to their label.

00:35:03: The only not on there is if the vaccination is going to create a certificate, so that would be for rabies

00:35:12: right?

00:35:13: So

00:35:13: one of the examples I give there is you can't vaccinate a wolf dog hybrid for rabes because your God producer's certificate but nor a full wolf either, right?

00:35:26: So I'd rather they be vaccinated than not vaccinated but legally we can't.

00:35:30: Right so that's the only case where it's a real knot!

00:35:35: We do get occasional ones.

00:35:36: were something happens like their processing those steers... They just gave the steer of vaccines and then breaks its leg coming out-of-the-shoot.

00:35:52: So when you look on our vaccines, they pretty much all have a twenty-one day withdrawal time on them.

00:35:57: Yes

00:35:58: And so we looked at that and go why?

00:36:01: As best I can tell is...I don't know.

00:36:05: many years ago somebody looked at him said i guess We should have it with rolltime on these.

00:36:09: how long?

00:36:10: well twenty one days sounds good!

00:36:12: There You Go.

00:36:14: Right.

00:36:14: I believe its really about injection site lesions because some of the products are quite irritating.

00:36:20: The newer vaccines, though are not irritating.

00:36:22: Not like the old Clostridials right?

00:36:25: And so there's really no residue issue.

00:36:27: but again we can't give a recommendation.

00:36:30: then shorter what is actually on their?

00:36:32: and So if it's going to go to the public food supply the veterinarian answer has to be No.

00:36:39: But If the owner of the animal Is Going To Slaughter It For Their Own Consumption That'S They're Right they Can Do It.

00:36:46: We Don'T See A Human Food Safety Issue From

00:36:49: Right, and I think that when you talk about injection site lesion kind of makes sense.

00:36:54: We do see some vaccines.

00:36:56: usually it's the oil based vaccines where we even see a sixty day withdrawal on those vaccines.

00:37:02: but again with oil-based vaccines generally are going to be seeing more reaction at that injection site part.

00:37:10: is there reason for that to stimulate immune response?

00:37:17: we can't really give a recommendation for anything entering the food chain on the public side of things.

00:37:23: But that's, you do get some of those questions coming in once in awhile too.

00:37:26: where like I said your handling those animals going through this shoot breaks its leg and what to do with it?

00:37:32: Yeah Like i said We just don't see human foods safety concern or residue concerns.

00:37:37: but legal label says twenty one days.

00:37:40: so as veterinarians That

00:37:42: is what

00:37:42: we must say.

00:37:44: So how did know that CG Faro does is on the job.

00:37:49: So as I said when we started, a lot of time were kind of quietly working in the background and people don't realize what impact our service can be especially exporting products.

00:38:05: and when the European Union comes over, it looks at our inspection process in everything.

00:38:10: They're very gratified to see that we have the service of the CGFARAD.

00:38:14: It lends a lot of credibility to our exports and things like that.

00:38:17: so but I have to steal this line from my friend Dr Scott Weiss At The Ontario Veterinary College.

00:38:23: he uses about infection control And Our Line is When you are doing your job nothing bad happens

00:38:31: Right

00:38:32: And in kind of a system where people only react when something bad happens, it's easy to forget about us and forget to fund us if you don't really recognize the job we're actually doing.

00:38:45: We don't have a PR department so we are really bad at blowing our own horn!

00:38:50: So this is a very good story to talk about.

00:38:54: how much impact can be had on us.

00:38:57: Ractopamine is a beta agonist drug that's approved for use in cattle, swine and turkeys to make them grow bigger mussels.

00:39:06: A lot of the world does not like that but I don't have control over it.

00:39:11: That is the approved labeling.

00:39:13: And North-and South America we do have rectopamine approved For this purpose.

00:39:18: It is NOT approved for broiler chickens Because they dont live long enough To show benefit.

00:39:24: So The lifespan Of a broiler chicken Is more Like thirty five days sixty-five days or longer for a turkey.

00:39:32: So it's not approved.

00:39:33: so they haven't done any of the work and they have an established MRLs, for broiler chickens.

00:39:39: Over in Alberta there was a big feed mill And as best I understand The truck carrying the rectopamine Was supposed to add into beef cattle Feed bin To make up medicated feed for feedlots.

00:39:54: They must've taken wrong turn.

00:40:00: And then Menensin and Bacitracin, broiler drugs were also added.

00:40:06: I believe Tylasin was also added to the feed.

00:40:09: Nobody noticed a mistake?

00:40:11: The feed went out to one hundred thousand broilers!

00:40:15: Then sixty-thousand on Thursdays went to slaughter.

00:40:20: they had just been processed.

00:40:26: So that evening I was at a seminar on dog ear infections because I teach all the pharmacology and A former student got me on the phone And told me what was going down?

00:40:40: It's not going to be zero withdrawal for zero residues and chicken livers,

00:41:02: right?

00:41:03: So And given that rectopamine well I didn't think there'd be a human safety concern from the muscle tissue.

00:41:10: it sensitive Right.

00:41:13: so this is not one that anybody would like bad press on.

00:41:18: yes Oh i had To make The call and say i'm sorry There Would Be liver Residues.

00:41:24: you have to talk to the CFI on what to do.

00:41:27: Yes,

00:41:28: so then samples were getting sent and for some reason they weren't going to use the livers and gizzards or stuff for human consumption.

00:41:37: So they just had to send muscle samples To my friends at Bureau Veritas.

00:41:42: But that's still gonna take a day or two.

00:41:44: And now we're trying hold all these

00:41:47: birds

00:41:49: Plus forty thousand are backed up on farm.

00:41:52: They get bigger everyday.

00:41:55: More birds were to move in.

00:41:56: so just starting to imagine the ramifications

00:41:59: right of

00:42:00: all of this.

00:42:01: and So, the good news is?

00:42:03: The muscle Tested negative by the CFI assay.

00:42:07: And so those birds released.

00:42:10: and then the forty thousand on farm We're sort of following a withdrawal time show.

00:42:14: they were able to be processed so hard again pinpoint all the Implications there.

00:42:24: However, this was over in Alberta and like I made the call on a Thursday night.

00:42:29: On Monday morning my grad student went to the local grocery store next to the university and took a photo for me.

00:42:37: And In The Meat case there's a sign that says chicken shortage due-to problems at the plant.

00:42:43: And you knew what?

00:42:44: You know it was behind them!

00:42:45: Oh

00:42:45: i knew who is fault than It Was.

00:42:47: So That' s My Photo To Show How You Know When Im Doing My Job.

00:42:52: And so I thought that was all said and done there, and luckily the hundred thousand chickens went for wherever food they were going for.

00:43:00: Then about two weeks later i get a call from a feedlot veterinarian who's very excited because steaks are in grocery stores already right?

00:43:10: It was discovered that The beef feedlot feed had contained bassatracin.

00:43:20: An analysis within an hour that said this was not a problem, then the CFIA was going to institute a recall from grocery stores.

00:43:30: Right?

00:43:30: So think of how expensive that's gonna

00:43:32: be!

00:43:32: Yes...

00:43:33: But I was like oh no harm no foul.

00:43:36: Bacitracin is fed to chickens to control intestinal bacteria.

00:43:42: It is really not absorbed into the system it just stays in the GI tract.

00:43:48: And it's also a very safe drug, so no human food safety.

00:43:52: and I didn't believe there'd be any residues to be found.

00:43:56: So... Very relieved!

00:43:58: No recall on the stakes.

00:44:00: Then few days later i get call from my friend of mine at CFA feeds toxicology.

00:44:07: He is telling me we're gonna start getting calls about menensin in swine.

00:44:14: So menensin, as Ionophore is not approved for swine.

00:44:17: Selenomycin is the one approved for Swine and but with ionophores.

00:44:22: It's not really about residues it's about their toxicity.

00:44:25: so if its overdosed or it's fed to a species For whom?

00:44:29: Its toxic.

00:44:31: You'll see clinical

00:44:33: signs.

00:44:33: he was gonna get the animals condemned And that animal metabolize these drugs very quickly.

00:44:38: so there's not much of a residue problem.

00:44:41: So as I'm chatting with my buddy about this, he keeps saying it's all the same feed.

00:44:47: And finally i'm like what are you talking about?

00:44:50: and He goes... It was all the Same Feed!

00:44:52: I had foolishly apparently assume that when The feed problem on the farm there is feed left in the broiler bin.

00:45:00: When That Was Discovered They Had Dumped It

00:45:02: Right.

00:45:03: they took it back and In This Case They Put Some in The Beef Feed and they put some of it in swine feed,

00:45:11: right?

00:45:12: And the three drugs that were in it?

00:45:15: for each Of this other species there was one drug.

00:45:17: That wasn't approved Bacitracin Wasn't approved for the cattle and then soon wasn't approve for

00:45:22: the swine.

00:45:24: so Again don't even know how many swine we're impacted by that.

00:45:30: but again just thinking about if we'd had to either say condemn it or do a hold and test for that, what the ramifications would have been there.

00:45:38: For that from our financial standpoint?

00:45:41: Well I think yeah... And iIthink It really just highlights your role CG Farad in That its not all Just about.

00:45:50: you know saying this won't Or will be an issue.

00:45:53: You Have to Either Hold Those Animals positive outcomes that can come to CGFared as well, where you actually save the industry kind of going through all of that.

00:46:08: And again we have to really think about a recommendation.

00:46:11: if I even call twenty-four hours on broiler chickens... Well one day they're growing right?

00:46:18: One day you are holding up new animals coming in and when we looked at rodenticides and swine it hangs around their liver.

00:46:26: if the pigs and they do, they love to eat rat poison.

00:46:32: They get into the rat poison...they have to be just

00:46:35: euthanized.

00:46:36: yeah so there's a lot of that kind of information.

00:46:40: That-that's really valuable.

00:46:41: but most of time we've been able say you know it is not an issue.

00:46:45: had a poultry case where theres bit over dose drug The trucks had driven off from processing plant were asked come back.

00:46:55: I quickly did the analysis, CFIA accepted the analysis.

00:46:59: The trucks turned back around and the veterinarian told me that was worth about two hundred thousand dollars in product That we kept from having to be tanked.

00:47:09: And even then if were going to tank animals You know what are you gonna do with a hundred thousand broilers?

00:47:15: Right How are you officially?

00:47:18: You know euthanize them um...and..that is really painful.

00:47:23: hard on veterinarians and producers if they have to, to euthanize animals like that.

00:47:28: Things like milk.

00:47:29: what are you gonna do?

00:47:30: If you have a silo of milk You can't pour it down the drain which happened in Saskatoon a number of years ago.

00:47:37: Yeah

00:47:38: And it completely overwhelmed our wastewater treatment station and turned it all into a poop milkshake.

00:47:45: So

00:47:46: the city was not very happy about that.

00:47:49: So they have to put milk back in the taker trucks and haul it into a landfill.

00:47:53: If its already in gallon jugs, then you've got to take gala jugs for landfills.

00:47:58: And things like that.

00:47:59: so sometimes this can be really difficult if we make that call.

00:48:06: We talked about what CGFARAD is.

00:48:11: on label vs extra-label versus compounded products means what zero means and when it doesn't mean.

00:48:21: you probably confuse not confused me treasure but you've made me.

00:48:27: When I look at labels in part of my job is no label as well.

00:48:31: there isn't art to reading those labels sometimes, Having a resource like CG Farad and yourself, the other people that you work with is just something so vital for our food animal industry here in Canada.

00:48:51: And I want to thank CG Farrad and all of you for your work... Like you said oftentimes we don't hear about it.

00:49:00: The best day is Rob Trombley who knows very well You know, that was one of his comments when we talk about vaccines is the best day for a vaccine as well.

00:49:09: Nothing happens.

00:49:11: The Best Day For CG Farad Is When There Is No News Story.

00:49:14: But you Know With Your Last Story It Just Really Highlights How Critical That Is And how We Can Avoid Kind Of Waste As Well As Still Provide That Safety For The Human Food Chain.

00:49:28: So Thank You Very Much!

00:49:30: Is there Anything That We Haven't Touched On?

00:49:34: Or

00:49:34: I just like to say here at the end that it's been an honor and a privilege To bring this concept of Canada.

00:49:40: as veterinarians.

00:49:41: We do A lot Of great things lots on An individual basis, you know.

00:49:46: for me coming home At The end of the day And knowing i help protect the canadian food supply Is is It real feel good kind of thing we all want to make A difference in our profession?

00:50:00: The bottom line is we work for the practitioners, you know?

00:50:03: You guys are colleagues and we want to help you so that you can help the producers.

00:50:08: the pharmaceutical companies and some of the processors, things like that.

00:50:21: So we are very grateful to people who help keep this service running.

00:50:26: Unfortunately our colleagues in

00:50:27: U.S.,

00:50:27: they're government funded so their budget goes up-and down like a yo-yo.

00:50:32: I

00:50:33: don't even know where it is right now when i brought them out into Canada.

00:50:43: You know, administrations change and all of a sudden you're no longer

00:50:46: on your own side.

00:50:47: And so we are kind by the veterinarian producer associations for the veterinarians in producer association.

00:50:56: Right Well excellent.

00:50:58: Thank-you Dr Patricia Dowling.

00:51:00: you've been sharing knowledge and expertise On CGFARID and just the pharmacology around.

00:51:09: use drugs use of pesticides, use vaccines in our production animals.

00:51:15: I think this is really valuable key message for those vets that are listening and producers as well.

00:51:22: if you're using products extra label we have an excellent resource here in Canada with CG Farad.

00:51:28: reach out.

00:51:31: they can provide a lot guidance.

00:51:33: So I just want to thank you again, Patricia for coming and talking with us today.

00:51:38: For the listeners i wanna Thank You!

00:52:03: Find more episodes of this podcast on Spotify, Apple Podcasts or wherever you get your podcasts from.

00:52:09: Thanks again for listening!