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

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00:00:35: listening!

00:00:36: Welcome back listeners to the Herd Health podcast.

00:00:38: my name is Tim Neckl and I'm a technical services veterinarian with Borneo Rungalime Animal Health.

00:00:43: today i'm joined once again by Dr Patricia Dowling From CG Ferrad And we'll continue our discussion talking about some of the lessons learned in The Request Received By CG Ferrid.

00:00:53: welcome Trisha

00:00:54: Thanks Again For Having Me Tim.

00:00:56: Let's talk About Some Of This.

00:00:57: Specific Lessons You've Kind Of Learned Over The Years With CG ferrad.

00:01:01: Yeah, we've had some very fun cases and I learned a lot.

00:01:05: And i know the compendium of veterinary drugs backwards and forwards these days.

00:01:10: to kind do it in humorous way...I kinda center around the definitions of no-and-zero.

00:01:17: So here are examples from actual drug approvals that were worth mentioning.

00:01:27: Sometimes when you look on a label zero isn't actually zero and This is kind of not written down legally anywhere, but this is what both the US in Canada uses for Zero For livestock withdrawal tissues.

00:01:44: It's actually eight to twelve hours.

00:01:46: So that means you really can't be injecting the seft if your as a steer walks into the slaughter plant.

00:01:52: Great to do that.

00:01:54: for milk it's actually twelve hours.

00:01:57: based on The original milking schedules everyone did of every twelve hours.

00:02:03: And then we had Darry's doing three times a day and now he have the robotic milkers where cows can milk themselves up to four times per day, but other issues with milk.

00:02:16: so I'm not quite sure how that impacts what the label withdrawal time are.

00:02:21: or were going talk more about labels for mills.

00:02:24: For poultry it is actually six-hours.

00:02:26: most their products feed.

00:02:29: They're pulling the feed six hours before they go to slaughter.

00:02:32: So a lot of it 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 were not.

00:02:41: you know We are kind taking into account that animals aren't going immediately to slaughter right after we give them that dose but It also means there's That little time frame needs pass before their ready-to-go.

00:02:58: So zero, so is there a point in time where nothing is zero?

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

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

00:03:07: Ketoprofen 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: yeah we do have an MRL for ketoprofin I mentioned earlier.

00:03:18: ketoprovins are human drug So it's quite high, and so no milk withdrawal period is needed.

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

00:03:28: And then... Sometimes nothing is zero but its for meat!

00:03:33: This one kind of weird.

00:03:35: On the twenty percent sodium iodide bottle People use for treating lumpy jock There are seventy two hour milk withdraw time But silent on the meat withdrawal.

00:03:45: Well, it turns out that the iodine in milk is a human food safety concern.

00:03:51: And so that's why there's a withdrawal time for milk but they really wouldn't be anything to detect in the meat.

00:03:58: So then they just are silent and no withdrawal period for meat as necessary.

00:04:02: But one of those cases again where that's not explicitly stated on the label?

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

00:04:09: 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 with...meat-or-milk MRLs for dexamethasone.

00:04:50: And so if there's no MRL see if I 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.

00:05:04: Right?

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

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 Because they're resuming.

00:05:19: nothing

00:05:20: is 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 Dr Ron Johnson from the Ontario Veterinary College much better at raising money than I am.

00:05:38: he secured the fundings so we could do the study.

00:05:41: We carried out dexamethasone residue studies in meat and milk.

00:05:45: it was published in twenty twenty three in our Journal of Veterinary Pharmacology and Therapeutics.

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 Direct could legally establish the MRMs that were recommended.

00:06:15: Finally just recently, the pharmaceutical companies 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.

00:06:50: I think that really just highlights the service it provides to the industry.

00:06:55: Those Dexamethylzone 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 Farad was able do this.

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

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

00:07:40: but Canadian milk supply is provincially based and regulated.

00:07:46: The processors are provincially based.

00:07:49: So, for example in Saskatchewan I dug through the milk regulations and a legal statement is no person shall sell supply or offer for sale any milk that contains antibiotics insecticides herbicides so on and so forth.

00:08:06: they don't say antibiotics above It just says antibiotics.

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

00:08:24: so this is where a withdrawal time that was established on the label Doesn't always

00:08:30: an MRL.

00:08:31: Yeah

00:08:32: not the limit of detection of a test.

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.

00:09:58: they're what 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 out most cases and I don't need say this way but... If one cow gets treated with these no-withdrawal needed drugs But still has residues that would be above the limit of detection If her milk gets diluted in the bulk tank and then diluted into a tanker truck, it's just fine.

00:10:56: It

00:10:57: won't be picked up

00:10:58: right?

00:10:58: But you know if many cows get treated You've got respiratory outbreak or something like that.

00:11:05: Or your tanker... Your bolt-tank makes up The whole tanker.

00:11:09: trucks are big dairy.

00:11:11: This could an issue And so the governments and processors 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 above detection or below MRL.

00:11:43: But the producers have to keep the 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

00:11:58: milk truck sitting there

00:12:00: waiting for the confirmatory tests.

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: Right.

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.

00:13:04: 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 test 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 can 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.

00:13:58: 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.

00:14:15: 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 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.

00:15:22: but Where three or three thousand dollars worth of milk was getting dumped every other day for weeks and when they Contacted us so 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.

00:15:43: who can pinpoint what drug?

00:15:44: It was and what the concentration was, and So a sample was sent to Bureau Veritas and They tested for over twenty different sulfa drugs including a bunch human ones for type two diabetes.

00:15:58: Okay, that's it for everything.

00:16:01: and then lo and behold there was a positive for sulfa thiesol at four parts per billion And the limit of detection Of The assay That Was Used For The Screening Was One Part

00:16:14: Per Billion.

00:16:15: Yeah So Are There Times When You Know We Talk About That Definition As Zero?

00:16:20: Is There Times when Something Should Have A zero On It But Doesn't?

00:16:24: Oh, yeah.

00:16:24: This one came up some years ago and it's 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 is at risk of things like mastitis feet leg problems early culling.

00:17:02: those are just facts.

00:17:04: then they came to us.

00:17:06: so it's 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

00:17:15: Canada.".

00:17:16: So yeah... That's very interesting!

00:17:20: They kind of noticed oxytocin can be injected into a dairy cow to increase milk let down.

00:17:27: so sometimes people will do with nervous heifers when their coming into the 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 one mil IV.

00:17:54: Canada is only country we can find in whole world with withdraw times for oxytosin.

00:18:00: The synthetic products is chemically identical to the natural hormone.

00:18:06: You

00:18:06: 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 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 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 right.

00:19:39: one 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-label drug use, we do give a minimum twenty four hour milk withdrawal recommendation.

00:20:03: Okay?

00:20:03: That's 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 We're honoring the spirit.

00:20:21: Yes, and if you're going to do it.

00:20:25: You know we don't want a circumvent getting labeled products And so you're gonna get a twenty four hour recommendation from us now.

00:20:33: our recommendations are not legal.

00:20:35: We aren't an advisory service.

00:20:38: So you can say well okay?

00:20:41: We're just gonna Do whatever we want to do.

00:20:43: but that puts all the liability back on The prescribing veterinarian.

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- Yes

00:21:01: 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: You said 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 and 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 You 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 kinda making It up out Of 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 We have been in operation Right.

00:22:28: We do know that on occasion CFI has checked our recommendations like did some residue testing and nothing was discovered.

00:22:36: in the United States.

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

00:22:51: And so we've had a few where people tried to use somebody else's or something like that, and we can check back and say no.

00:22:59: That was done here for this situation right?

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

00:23:08: They had asked years previously 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 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 You Have Some Examples Of That?

00:23:44: 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.

00:24:13: Not In a year or not in six months, it's an absolute never.

00:24:17: So that is the legal law and veterinarian who prescribes such would be quite liable.

00:24:27: And if you look on the label for something like nitrofurescent ointment there are warning states do NOT use food producing animals.

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

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

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

00:24:52: and Nitrofierosone used to be given orally 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 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.

00:26:01: It has a horse, a cow.

00:26:02: A sheep, a goat...a pig and chicken on it!

00:26:05: And those are kind of food animals.

00:26:08: so

00:26:09: people don't read the small print.

00:26:10: they're looking at a band drug.

00:26:15: Is there a website or repository for these drugs?

00:26:21: You said that isn't very many but is this place to access them?

00:26:26: Well if you have time

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.

00:26:47: Then Its About Administering The Product.

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

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

00:26:59: you know, when no means no and when it doesn't.

00:27:02: And what does zero mean?

00:27:04: Lots of different things.

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

00:27:11: of?".

00:27:12: Well I got one for a while even kinda stumped me...I gotta request about administering five units per site of Botox to beef

00:27:22: heifer

00:27:23: 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 faces 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 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.

00:28:41: 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 A Beef Heifer.

00:28:53: She Wasn'T Going To Slaughter Any Time Soon But the practitioner was doing their due diligence because they were using a human drug, extra label and food

00:29:02: animal.

00:29:02: Yes there you go perfect.

00:29:05: so I'm sure you've got other situations in kind of the 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.

00:29:19: 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.

00:29:56: And so you, get away to the cow and then put the appropriate mount-on.

00:30:01: but he didn't think that was very efficient.

00:30:03: So I like to joke there's extra label.

00:30:08: Then there is extra ladle.

00:30:12: He puts several ounces of product rather than the twelve mils.

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.

00:30:37: 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 is 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 in says this pest control product is to be used only in accordance with the directions on the label it as 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.

00:32:04: Not heck no!

00:32:05: You get That Now if you dive into the PCP act cause 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.

00:32:40: 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 toxins.

00:33:21: Yes Yeah well all I could say is I remember having headaches after After preg checking on on those animals.

00:33:29: just cuz it I had never have my arm out of the cow before The.

00:33:33: uh Before the producer applied the product to the back so I'm sure i got some exposure.

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

00:33:47: All right vaccines we haven't talked really a lot about that but their not drugs either.

00:33:53: No,

00:33:55: yeah.

00:33:55: Vaccines are a different branch of health Canada that deals with biologicals.

00:34:01: so biologicals or things like plasma products, colostrum replacer interestingly you know some of your Mab products and things like but mostly what we deal.

00:34:10: their vaccines.

00:34:12: they don't really fit under our mandate because there not drugs.

00:34:16: the Canadian food inspection agency is pretty happy when assist with withdrawal guidance when vaccines are used.

00:34:23: extra label.

00:34:24: And some of them are pretty innocuous, like there's poultry products that're supposed to go in the water but they spray it on the birds because that's easier and then the birds preen themselves and they ingest it?

00:34:36: There 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 to cause a detectable residue in tissues.

00:34:51: That's just not the issue,

00:34:53: right?

00:34:54: And so when you read the actual regulations on biologics it kind of says we should use them according their label.

00:35:03: The only knot is if vaccination will create a certificate.

00:35:10: So that would be for rabies.

00:35:13: One example I give there You can't vaccinate dog hybrid for rabies because you've got to produce your certificate, but that is not a dog.

00:35:24: Right?

00:35:25: Nor full wolf either right.

00:35:26: so I'd rather they be vaccinated than not vaccinated.

00:35:29: But legally we can't all right.

00:35:30: So um That's the only case where it's a real knot if the animal can be slaughtered for consumption.

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.

00:36:00: why!

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

00:36:05: many years ago somebody looked to him said i guess we should have it with roll time on these.

00:36:09: how long?

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

00:36:12: So I believe it's really about injection site lesions because some of the products are quite irritating.

00:36:20: The newer vaccines though, they're not irritating like the old Clostridials and so there is no residue issue.

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

00:36:30: then shorter what actually on their.

00:36:32: And if its going to go into public food supply the veterinarian answer has The owner of the animal is going to slaughter it for their own consumption.

00:36:44: That's, they're right!

00:36:44: They can do that and we don't see a human food safety issue from...

00:36:49: Right?

00:36:49: And I think when you talk about injection site lesion kind-of makes sense.

00:36:54: We do some vaccines Usually its kinda oil based vaccines where we even see a sixty day withdrawal on those vaccines.

00:37:02: But again with oil based vaccine generally your gonna see more reaction at that injection site.

00:37:09: And part of it is there's reason for that to stimulate the immune response, but something where this kind makes sense like you said we can't really give a recommendation or anything entering food chain on public side things.

00:37:23: But I do get some questions coming in once in awhile too.

00:37:26: Where your handling those animals going through shoot breaks its leg and what does he with?

00:37:32: We just don't see human safety concern for a residue concern, but the legal label says twenty-one days.

00:37:40: And so as veterinarians that's what we must say.

00:37:43: Yeah So how do you know that CGFairout is on the job?

00:37:49: As I said when we started... A lot of time were kind of quietly working in the background and people don't realize

00:37:57: Don't see it

00:37:58: What impact our service can be especially if it comes to food supply 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.

00:38:18: 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.

00:38:26: 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 good story to talk about.

00:38:54: how much impact can we get from it.

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 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 Don'T Live Long Enough To Show Benefit.

00:39:25: So The lifespan Of a broiler chicken Is More Like Thirty Five Days Than 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 Tylosin was also added to the feed.

00:40:09: Nobody noticed a mistake?

00:40:12: The feed went out to one hundred thousand broilers!

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

00:40:21: 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.

00:41:46: 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 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 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 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 whatever 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?

00:43:11: 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 going to

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.

00:43:43: It's really NOT absorbed into the system it just stays in the GI tract And it's also a very safe drug, so no human food safety 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.

00:44:32: You'll see clinical 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

00:45:03: 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.

00:45:18: bassid tracin Wasn't approved for the cattle right and then wasn't approve for

00:45:23: 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?

00:46:19: One day you are holding up new animals coming in and when we looked at rodenticides and swine it hangs around their liver.

00:46:27: 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

00:46:35: just euthanized.

00:46:37: yeah so there's a lot of that kind of information That-that's really valuable but most of time we've been able To say you know it is not an issue.

00:46:45: had a poultry case where There was bit of over dose drug The trucks 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 veterinary 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

00:47:15: How are you officially?

00:47:18: You know euthanize them.

00:47:19: 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

00:47:47: 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 need 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've 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

00:48:53: CG

00:48:53: 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!

00:49:31: that you want to say right now or?

00:49:35: I'd just

00:49:35: like to say here at the end, it's been an honor and a privilege to bring this concept of Canada.

00:49:40: As veterinarians we do lot great things lots on individual basis.

00:49:46: for me coming home in the day knowing i help protect Canadian food supply is real feel good kind thing.

00:49:53: We all wanna make difference 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.,

00:50:28: they're government funded so their budget goes up-and down 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 on

00:50:46: your own

00:50:47: 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 CGFERD and just the pharmacology around use drugs Use of pesticides use of vaccines in our production animals.

00:51:16: I think this is really valuable key message for those vets that are listening and producers as well, if you're using products extra label we have an excellent resource here in Canada with CG Farad reach out.

00:51:31: they can provide a lot of 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 Just a reminder, if you enjoy today's podcast please subscribe and leave us a review.

00:51:45: And we look forward to joining for our next episode.

00:51:48: The information shared in this podcast does not replace the advice of a veterinarian.

00:51:52: We encourage you reach out to your veterinarians For more information about topics discussed.

00:51:57: Bullringer Engelheim cannot recommend use products outside Canadian product approved labeling.

00:52:03: Find more episodes on Spotify, Apple Podcasts or wherever.

00:52:08: Thanks again for listening.