FDA 483 OBSERVATION · #315 OF 1,932 MOST-CITED

ELDU without veterinary client-patient relationship

FDA cited this observation 91 times across 89 firms in recent inspections. Below: how it breaks down by program area and fiscal year, and real examples of how FDA worded it on Form FDA 483.

What this grouping is not

An observation-type page groups FDA’s published citation records. The grouping, the compliance steps and the root causes are SPEQ synthesis, not an FDA classification of any citation, and a count measures what FDA published rather than risk.

BY PROGRAM AREA
Veterinary Medicine91
BY FISCAL YEAR
FY20261
FY20252
FY20241
FY20233
FY20223
FY20204
FY20197
FY20189
FY201725
FY201636

What this observation is associated with

Firms cited for this observation also appear in FDA compliance actions — warning letters, injunctions, or seizures — at 1.4× the rate of the average FDA-cited firm (11.2% vs 7.8%), across 89 FEI-matched firms.

This is an association, not causation, and reflects co-occurrence in FDA's records — not a claim that the observation caused or preceded the action.

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How FDA worded it — real examples

You used an animal drug in a manner contrary to label directions without benefit of a valid veterinary/client/patient relationship.

S&C Livestock, LLC · Lebanon Junction, Kentucky · Veterinary Medicine · 2026-02-13

You used an animal drug in a manner contrary to label directions without benefit of a valid veterinary/client/patient relationship.

David J. Frahm, Sr · Edgar, Wisconsin · Veterinary Medicine · 2025-08-07

You used an animal drug in a manner contrary to label directions without benefit of a valid veterinary/client/patient relationship.

Alvin Zimmerman · Lewisburg, Pennsylvania · Veterinary Medicine · 2025-02-04

You used an animal drug in a manner contrary to label directions without benefit of a valid veterinary/client/patient relationship.

Blake Malone · Ottertail, Minnesota · Veterinary Medicine · 2024-03-06

You used an animal drug in a manner contrary to label directions without benefit of a valid veterinary/client/patient relationship.

Blaken Farms · Melrose, Wisconsin · Veterinary Medicine · 2023-07-19

You used an animal drug in a manner contrary to label directions without benefit of a valid veterinary/client/patient relationship.

I.G. Raak · Jasper, Minnesota · Veterinary Medicine · 2022-11-17

Related SPEQ references

Where to read the requirements behind this observation area on SPEQ. These are SPEQ's topic and audience pages — not an FDA classification of the citation.

Veterinary industry →

Examples are a representative sample of FDA's published inspection observations. Open the 483 observation explorer →