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CDFA subcommittee flags questionable signatures on veterinary feed directives; community blood bank update
Summary
CDFA raised concerns at the MDC meeting about inconsistent and potentially fraudulent signatures on Veterinary Feed Directives (VFDs), and the committee asked staff to research whether clearer guidance or rule changes are needed.
The committee received a report from the California Department of Food and Agriculture (CDFA) subcommittee raising concerns about the form and authenticity of signatures on Veterinary Feed Directives (VFDs).
CDFA told the MDC that federal VFD forms (and FDA guidance under 21 CFR Part 11) do not specify exactly what format a signature must take. Inspection staff have flagged VFDs with unusual or inconsistent signature formats and, in follow‑up, found some signatures the issuing veterinarians said were not theirs. CDFA asked the MDC for help identifying whether the board should issue more explicit guidance on acceptable signature methods or seek statutory/regulatory change to protect veterinarians and the food supply.
In the MDC discussion, subject matter experts were split: some said an electronic, computer‑generated signature that includes an authenticated provider ID could be acceptable; others said rubber stamps or staff‑applied handwritten signatures raise concerns. The committee agreed to research existing state and professional‑board practices and to consult other healing‑arts boards for approaches to signature authentication. Staff reported they had already reached out to medical board counsel for comparison.
Separate CDFA notes: the subcommittee briefly reported that community blood banks supply roughly 5% or less of total blood bank product in the state; three community blood banks remain registered and active, and one additional group had expressed potential interest.
Next steps: MDC staff will gather comparative approaches used by other licensing boards, continue discussions with CDFA and FDA contacts, and return with recommendations on outreach, education, or potential rule changes to address signature authenticity on VFDs.
