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CDFA flags questionable veterinary feed directive signatures; board to research electronic and stamped signature rules
Summary
CDFA told the committee that inspection staff have found VFDs with signatures veterinarians later said were not theirs; the MDC asked staff to research how federal rules (including 21 C.F.R. §11) and other boards handle wet, stamped, and electronic signatures and whether guidance or regulatory change is needed.
The California Department of Food and Agriculture reported that its inspection service is encountering veterinary feed directives (VFDs) that appear to be improperly signed or contain signatures that veterinarians later say they did not authorize.
CDFA told the committee it flags VFDs filled out incorrectly and contacts veterinarians for education and correction; in several cases, the veterinarian later said the signature on the VFD was not theirs. CDFA asked the board for input on what signature formats should be acceptable—handwritten wet signatures, physical rubber stamps, computer‑generated text, or electronic signatures—and whether the board should advise licensees about risks and best practices.
Why it matters: VFDs regulate animal feed use of medically important antimicrobials and are governed by federal rules (VFD requirements and 21 C.F.R. §11 on electronic records/signatures for certain systems). Improper or fraudulent signatures could undermine food‑safety enforcement and expose veterinarians and premises to enforcement action.
Discussion highlights - CDFA asked the MDC to consider whether the board should publish guidance for veterinarians about acceptable signature formats and about how to limit potential misuse of signature stamps or electronic signature systems. - Committee members noted there is no single signature method that is wholly forgery‑proof and that electronic systems and computer‑generated signatures are common in practice management systems. The FDA/21 C.F.R. §11 guidance and CDFA’s interpretation were raised as applicable standards for VFDs; CDFA staff said FDA does not allow rubber stamps on prescriptions, and CDFA is checking whether this practice would be acceptable for VFDs under federal rules. - The Medical Device Committee will coordinate research with other health boards and legal counsel to determine whether regulatory change, clarifying guidance, or outreach is the most effective next step.
Next steps - Staff will examine how other healing‑arts boards and federal guidance treat electronic signatures, rubber stamps, and computer‑generated signatures and report back to the MDC. - The committee asked that any future guidance be coordinated with CDFA and, as appropriate, the FDA’s existing VFD guidance to ensure consistency with federal requirements.
