# Antibiotics - The FDA changed a rule to help beekeepers



## JSL (Sep 22, 2007)

Chris,

Thank you for sharing this.

First VFD - Veterinary Feed Directive. Is it fair to say this is basically a rule book/best management guideline for animals used for food and medically important antibiotics?

If I understand this correctly, and as you have stated, the bottom line is beekeepers will need a prescription for access to antibiotics for their bees. The FDA proposed change simply allows beekeepers to then mix and administer the antibiotic on their own as they have done previously. 

What antibiotics are labeled for use in honey bees, Terramycin, Tylan? I know things are changing or have changed, so I am not familiar with what is labeled for honey bee use currently.


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## jim lyon (Feb 19, 2006)

Yes, thanks Chris. I think these proposed changes have the best of intentions but they simply don't address the realities of commercial beekeeping.


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## cowdoc (May 15, 2011)

Hi Joe,

I'll try to keep it short, but who knows.

Starting January 1, 2017, all of the antibiotics that are delivered in feed or water are going to change from being over the counter (OTC) to needing either a prescription or a veterinary feed directive (VFD). These are papers that a veterinarian has to supply with their signature. Prescriptions are fairly easy. The veterinarian or a pharmacy could fulfill this. the water soluble antibiotics would use this. Oxytetracycline, Tylan and Lincomix are the three labeled for bees. 

A VFD could be used also. This paper goes to a feed mill or feed distributor. Prior to this ruling, both of those needed licenses from the FDA. There were limited feed mills in the northeast with that license. Having mostly dairy cows drive the mills in the northeast, there was no need for antibiotics. It is a liability for a mill to even have antibiotics since each tanker of milk is tested and mistakes would be caught easily by the dairy plants. So, a VFD is not a best management thing, it is a law that tells how the antibiotics is to be prescribed. The rule changes are coming about to help prolong the time an antibiotic works for human disease fighting. 

With this rule change, an unlicensed feed mill can get a category I drug and mix it for minor species (like bees) therapeutic uses. Terramycin is the only drug approved for use in bees as a VFD drug. The company that makes it went to great lengths to make it a category I drug by removing approved uses that required withholding in chickens. Category I drugs can be fed with no withholding in the major species while Category II drugs have a withholding period. Prior to this rule change, Terramycin would have been a Category II drug because it was used for bees to control AFB or EFB with a 42 day withholding period. The company may have removed bees from the label in order to protect sales as a Category I drug. 

What is an unlicensed feed mill? Pretty much anyone that mixes feed can be an unlicensed feed mills. A lot of larger farms have their own feed mills. A 50 pound bag of Terramycin will make several thousand treatments, so it may be easier to use prescription drugs anyways as they come in smaller bags. The mill still needs to collect a VFD from the end user to have their paper trail. the FDA will do some auditing of the paper trail, but it is a little harder to do that in unlicensed mills versus licensed mills. I am not sure how they are going to accomplish this part of the regulatory circle. It may be complaint driven, or it may be part of regular FDA food producer inspection. So, bottom line is the beekeeper (or bee supply dealer) may be able to obtain the VFD labeled drug, mix it into sugar, and then sell it or use it when a properly completed VFD from a veterinarian is presented to them. 

Hope that helps, 

Chris
[email protected]


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## DavidZ (Apr 9, 2016)

if you really need this stuff, you can buy all you need labelled as Fish Cycline or from API called Tetracycline Powder
search it out, it's the same stuff used for honeybees and for all farm animals etc, this is just labelled for fish and it's legal.
it comes in bulk, use it as you will, not need for a permit or script this way.


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## Rader Sidetrack (Nov 30, 2011)

DavidZ said:


> if you really need this stuff, you can buy all you need labelled as Fish Cycline or from API called Tetracycline Powder search it out, it's the same stuff used for honeybees and for all farm animals etc, this is just [HIGHLIGHT] labelled for fish and it's legal.[/HIGHLIGHT]


Well, Fish Cycline is labeled for 'fish', so it is legal for fish, but keep in mind that ... 


> It is a violation of Federal Law to use this product in a manner inconsistent with its labeling.
> 
> https://www.vetdepot.com/fish-mox.html


That means the product is not legal for use with bees, as bees are not on the label. However, if you had a prescription from a veterinarian that changes the situation.


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## aunt betty (May 4, 2015)

I'm cornfused. 
You need a prescription to buy the oxytetracyclene HCL (Teramyacin) or not? I don't need any at this time but if I wait until I need it and hit hurdles and brick walls I'm not going to be happy. 
It's for sale on Ebay today right now and that's even more confusing. 
Once I get a bag of the stuff can y'all teach me the right dosage?
I don't have EFB but have had it before around 1980-ish. 
Back then you just ordered the stuff, it was labeled for bees, and easy.
The local bee club is sort of lost on this issue. When I asked my vet about this he sort of snapped at me and said to ask the bee club. 
That's not acceptable.


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## cowdoc (May 15, 2011)

aunt betty said:


> I'm cornfused.
> You need a prescription to buy the oxytetracyclene HCL (Teramyacin) or not?
> That's not acceptable.


I will try to clear things up for you. I wrote an article about this that you can find here: 

http://www.beeculture.com/do-i-need-a-vet-for-my-bees/

As of January 1, 2017, in order to legally use Oxytetracycline, you need to have an order from a veterinarian. The veterinarian could give you these orders via either a prescription or a veterinary feed directive order. 

Prior to that date, you could buy the drug over the counter legally. You cannot do that anymore. 

This is a major change that the FDA brought about to try to preserve the ability to cure an infection using medically important antibiotics. 

Now with that said, are there places you will be able to buy antibiotics without a veterinary order? Certainly. The previously mentioned outlet apparently functions. If you can buy this today, will you be able to buy it tomorrow from the same place? Maybe or maybe not. The FDA will work to educate people about the law for the next year or so and then will start with more harsh enforcement. Is selling these antibiotics like they do illegal? It is illegal, but then again so is going 80 mph on the highway marked with a 65 mph speed limit. Depending on the number of enforcers and their caseload, you may or may not get caught. The fish folks sound like they may be on the low end of the enforcement priorities. 

As a few beekeepers buy Taktic from overseas and import it illegally, it might not be a stretch to imagine they could do this with antibiotics as well. The reputation of honey and beekeepers is very clean and nice. I hope that someone does not make a mistake with some of these illegal medications because all beekeepers will pay the price if there is a mistake resulting in food adulteration.

Chris Cripps
[email protected]


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