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Top 5 Common Corrective Action Requests (CARs) from proAction Validations….

                                                                                                                …and how to avoid them on your validation

The proAction program is built with some flexibility in that it allows for some demerits to be carried forward in each pillar, however, some questions are specific in what must be adapted if non-compliance is found.

Here, we have broken down the five most common corrective action requests (CARs) assigned at validations since the livestock traceability pillar was introduced.

#5: Written veterinary directions for off-label use of medications

A written veterinary prescription is required if a drug is used in a manner not detailed on the label. In the past year, 38% of all validated farms in BC were found to be using a drug off-label or extra-label without written directions from their herd veterinarian. While some uses may seem trivial to obtain written directions for, any off/extra-label use can affect both milk and meat withdrawal times, as well as contribute to increasing antimicrobial resistance. The withdrawal times stated on drug labels have been determined scientifically to ensure there is zero drug residue remaining after the withdrawal period has ended.

Examples of off/extra-label use include:

  • Drugs not certified for use in dairy cattle
  • Using a drug for a longer OR shorter period of time than the label indicates
  • Using a drug at a different dosage than described on label
  • Administering a drug via a different mode than described on label (ex. Intramuscular vs. sub-cutaneous, or using an oral antibiotic dissolved in water as a footbath)

If you have any questions about the use of medications on your farm, please contact your herd veterinarian. Note: Your vet may not advise a longer withdrawal time for some of these off/extra-label uses, but the written veterinary directions provide evidence that you’ve consulted your vet on the product’s intended use and administration, and that the vet agrees that this is an appropriate use of that particular product.

# 4: Birth Records

With the introduction of the Livestock Traceability pillar in 2017 came new requirements for recording births on site. In the past year, 44% of validations in BC have received this CAR. Birth records must include the full 15-digit NLID number, along with your home premises ID number, and the date of birth. This information must be recorded within 7 days of calving.

Maintaining Livestock Traceability records can be made more simple by using a blanket statement at the front of your record book/ above your computer stating:

  • “All birth, move-in, export and tag retirement events recorded in this book / on this computer occurred at premise ID # BC____________, unless otherwise noted.”

Oftentimes, heifer calf births are properly recorded, but bull calves are not. Ensure that you are recording both heifer and bull calf births on your farm to satisfy this requirement.

#3: List of Medicines and Chemicals Used on Livestock (Record 9)


52% of validations completed in the past year have required updating to their record 9. You can avoid this CAR by reviewing and updating your list of medications annually in conjunction with other annual requirements, such as your Cattle Health Declaration.


Many veterinary clinics provide an index of drugs or prescriptions, however, they may not include non-prescription medications. Additionally, as new products are added to your inventory and older products get phased out, it’s easy to forget to update this list. Items that are commonly left off Record 9 are:

  • Topical pesticides (ex. Boss, Bimectin)
  • Udder balms
  • Teat dips/sprays
  • Medicated feed


Record 9 is not intended to be a rolling inventory, but an up-to-date list of the products used on your cattle. It should inform your staff and anyone reviewing records on your farm which products are kept on site, all of which should have labels available in case additional information is required.

#2: Storage of Medicines and Chemicals

Going hand-in-hand with the record above, 56% of farms validated in the past year have been storing some medicines and/or chemicals improperly, or had some expired products on their shelves. This one is an easy fix! Normally, all that is required to resolve this CAR is to dispose of expired drugs or relocate products found to be improperly stored.

The most common reasons a farm might receive this CAR at their validation are:

  • Drugs are expired
  • Drugs are not stored according to the label (i.e., refrigeration)
  • Drugs are stored with needles in rubber stopper
  • Drugs kept in the parlour or milk house are not in a closed container
  • Products used on or around animals are not labeled (i.e., a spray bottle of sanitizer)
  • Pesticides not for use in cattle are stored in the milk house or near cattle medications

A review of your medicine cabinet prior to the validation can help avoid this CAR being assigned during your validation.

#1: Livestock Treatment Records (record 10)

A whopping 70% of farms validated in the past year had inconsistencies or missing elements from their livestock treatment records!

Every farm has their own way of keeping records that works for them and that’s great! However, there are several elements that must be included regardless of the method you use for recording. Additionally, all products with a meat and/or milk withdrawal must be recorded for food safety purposes.

If you record your treatments by hand, the most common items noted to be missing or unavailable at validation include:

  • Calf dehorning treatments
  • Vaccines
  • Dose administered per treatment
  • Expiry check
  • Administrator initials

Depending on which herd management software you use, the most common treatment record CARs include:

  • Calf dehorning treatments missing
  • Dehorning protocols are not complete with all drugs
  • Withdrawal times for drugs are incorrect
  • Dose and mode are missing

Check your treatment records now to ensure that all of these elements are properly recorded for all livestock treatments administered.

If you have any questions about this piece or any proAction requirements, please contact us at 604-294-3775 or

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