Industry leaders also want the VMD to get back into step with risk management realities.
"We responded promptly and in considerable detail last year to a VMD consultation on their proposal to increase residue testing charges, identifying a number of concerns at the time," said Allan Jess, president of the Scottish Association of Meat Wholesalers (SAMW).
"Our views, however, appear to have been substantially ignored by the VMD, who again seem intent on pursuing an overbearing surveillance programme which is out of step with their declared risk management policy."
Jess added: "We have therefore written again to the VMD, asking that all increases over current rates are suspended until the appropriate EU Directive is amended and implemented. We are obviously deeply committed to a high health strategy for meat production, processing and retailing, but are not willing to accept an approach to residue testing which is so far out of step with risk management reality."
Under current proposals, the VMD is planning a 5% increase in charges in November this year, followed by an additional 9% in 2009 and a further 9% in 2010.
A detailed letter from the SAMW highlights several areas of the VMD's approach to surveillance which the association believes require urgent attention. These include the following observation:
"Since 2003, the number of (residue testing) samples taken has increased by around 8% and the number at, or above, reference points has fallen by 20%. This takes no account of risk.
"Two questions arise on Residues of Possible Health Concern. Four such residues were in UK produce, but 24 were found in imported produce. Is this proportionate in relation to the total number of samples taken from home and imported produce?
"The second point relates to the four UK results. Two were in farmed fish, one was in horse plasma and the fourth in cattle plasma. Was the cattle plasma a slaughterhouse sample? Even if it was, the risk from the red meat sector is grossly disproportionate to the intensity of sampling of the sector."
Another extract from the letter, adds: "One of our members is paying £50,000 a year, despite having had only two positives in 10 years. How proportionate, risk-based and targeted is VMD's treatment of that company? The 2007-08 Report contains many fine words, but what we need is action - and urgently."
The SAMW letter, sent to the VMD on Monday, 13 October, was also copied to Richard Lochhead, Cabinet Secretary for the Environment and Rural Affairs at the Scottish Government.