Dairy Regulations for Milk and Milk Products Entering Commerce
Grade “A” Pasteurized Milk Ordinance
The primary dairy sanitation standard for Vermont is the Grade “A” Pasteurized Milk Ordinance (PMO). This is overseen by the National Conference on Interstate Milk Shipments (NCIMS); a group that has representation from state and federal government, industry, academia, and consumers. All PMO amendments are subject to review by technical committees, which are councils made up of both industry and state government, and by the voting delegation, consisting of one vote from each state. FDA interacts with the process by providing technical guidance, and FDA has the right to veto proposed changes after they confer with the NCIMS Executive Board.
The PMO is available to download by clicking here. All milk used in Grade “A” products must follow this ordinance to assure smooth interstate shipment of products. All of the US states and territories are members of the Conference and have agreed to accept products made following this standard.
Regulatory Program Oversight under the PMO
The FDA oversees the inspection process for Grade “A” milk supplies. All dairy farms that operate under the Grade “A” milk program have a checks and balance system in place to assure all states are enforcing the PMO in an equivalent manner. The following is a simplified explanation of a complex process and will provide a general overview.
Farms are divided into Bulk Tank Units (BTU) or groups of farms all selling through the same milk handler. These are typically divided regionally on large cooperatives but may be a single farm for a producer-dealer that is processing and selling their own milk. State inspectors inspect all dairy farms at least every six months. Every 18 months, there is a “Rating” or an additional inspection to a random group of the producers within a BTU by an inspector trained and validated by FDA. Each group of producers must achieve a weighted average score of 90 points on the inspection that is done or further action will need to be taken if the group want to sell their milk into interstate commerce. In between ratings, FDA does check ratings. During this process, FDA regional inspectors go to a random sample of the farms within the BTU. If the check rating does not meet a minimum standard, the BTU must be rated again. This process assures farmers that the regulations are fairly enforced and assures consumers the milk supply is safe.
Processing plants fall under a similar program with quarterly inspections by Dairy Section staff as well as an equivalent rating program overseen by FDA.
Milk for Manufacturing Purposes and its Production and Processing
The PMO is developed for Grade “A” products and there are occasions when it is not practical for non-grade product processing. In 2011, the legislature, at the Agency’s request, approved the use of the USDA Recommended Requirements for Milk for Manufacturing Purposes and its Production and Processing as a secondary standard to be utilized at the Agency's discretion in instances when the PMO is not practical. This gives the Dairy Section some leeway to use processes that are not allowed under the PMO such as the use of cheesecloth for straining cheese curd. A copy of this guideline is available by clicking here.