Jim Dickrell is the editor of Dairy Herd Management and is based in Monticello, Minn.
The 400,000 Cell Count Mess
Jan 01, 2012
The clock has officially started ticking on the European Union 400,000 somatic cell count export certification requirement.
If you haven’t heard by now, the marketing requirement went into effect this past Sunday, Jan. 1, though dairy farms will have until May 1 to comply.
The new standard has been under discussion since June 2009. In fact, on Jan. 20, 2010, USDA had announced the industry would have to meet the new standard by Feb. 1 of that year. The announcement caused such an uproar that the agency retracted the requirement and spent the next 22 months crafting the new requirements.
Prior to this ruling, processors who exported dairy products to Europe merely had to certify that their silos and co-mingled tanker loads of milk from multiple farms met the 400,000 SCC limit. Now, like in Europe, individual farms must meet the standard.
“The 400,000 E.U. certification requirement is not a U.S. regulation, but simply meets a marketing requirement,” says Ken Vorgert, chief of USDA’s Dairy Grading Branch.
The standard for Grade A and Grade B milk within the United States remains at 750,000 cells/ml. “Dairy farmers with milk above 400,000 SCC can still sell milk within the United States as long as it meets the 750,000 SCC,” he says.
In effect, however, the 400,000 SCC level will become the new national standard. That’s because milk is processed into ingredients which then go into various dairy and other food products. Once it does, there’s no telling which ingredient was made from milk with more or less than 400,000 somatic cells.
The Europeans allow their farmers exemptions to this rule. So, in the spirit of equivalency, USDA will as well. U.S. farms will be able to apply for one of two temporary exemptions, called “derogations.”
An annual derogation can be applied for if the farm is not meeting the 400,000 SCC average but is making progress toward that standard, says Vorgert. “If the farm is at 750,000 SCC six months of the year, we’re probably not going to grant derogation,” he says.
“And there have to be reasons, other than hygiene or sanitation, why the farm is out of compliance.”
As long as the farm is making progress, USDA will likely renew the derogation for a second year.
The second type of derogation will be for seasonal problems. Here, farms must be in compliance for nine months of the year and have a consistent history of problems due to seasonality the other three. Seasonal derogations will have to be renewed every three years.
USDA will bill processors $136 per application. Processors, in turn, will likely pass that cost plus their own administrative costs on to farms. So farms could be looking at a total cost of $200 to $300 per derogation application.
All of this could have been avoided if delegates to the National Conference on Interstate Milk Shipments had done their job last spring, and rolled the Pasteurized Milk Ordinance requirement back down to 400,000 cells/ml. But that tally failed by one cowardly vote.
Now co-op fieldmen will have to babysit high-count herds, submit derogation applications, make up reasons high cell counts aren’t due to hygiene or sanitation, and track progress in case they have to re-submit the applications in a year or three.
It’s all pretty much a waste of time when, for the good of cow health, dairy profitability and consumer confidence, a 400,000 SCC national standard makes so much more sense.