The United States Department of Agriculture Agricultural Marketing Service (AMS) has issued its “European Health Certification Program” requiring a 400,000 somatic cell count limit based on a rolling three month average for individual farms, which will go into effect Jan. 1, 2012.
AMS met with industry stakeholders Nov. 21, issued its finding Nov. 22, but apparently told no one else. It wasn’t until today, Dec. 2, that the National Milk Producers Federation notified the industry of the change in its News for Dairy Co-ops on-line newsletter.
The three-month rolling average means that if a farm is above 400,000, it still would be allowed to sell milk for export for four months as long as it was making progress toward reducing the cell count. If it had not reached 400,000 by May, its milk could no longer be sold for export. In effect, shipments into the market would be suspended because processors turn raw milk into dairy ingredients and cannot trace an individual farm’s milk once it enters that process.
The program also allows for “seasonal derogation” where SCCs might exceed 400,000 during certain times of the year. To qualify, the program states: “A seasonal derogation will be granted to a farm that can demonstrate for a majority (at least 9 months) of the year they are in compliance with the EU requirements for somatic cell count; only due to seasonal variations is the farm’s somatic cell count escalated for a period of time during the year. The farm must be able to demonstrate through records that this variation is truly seasonal and not the result of poor hygiene or sanitary procedures. All seasonal derogations will be reviewed during the AMS Dairy Programs review of records to verify compliance with EU regulations. Seasonal derogations must be renewed every three years.”
The full text of NMPF’s release follows:
In August 2011, the U.S. Department of Agriculture’s, Agricultural Marketing Service (USDA-AMS) released a draft of the “European Health Certification Program” to dairy industry trade associations (NMPF, the U.S. Dairy Export Council, the International Dairy Foods Association, and the American Dairy Products Institute) for review and comment. After gathering member feedback, NMPF submitted comments and questions last month to AMS, expressing general support for the program, and requesting additional clarification on specific points.
The effective date for beginning the transition to the new program requirements is January 1, 2012. After March 31, 2012, all shipments of dairy products requiring an EU health certificate must comply with the updated certification program and must be accompanied by an updated Certificate of Conformance.
The major differences between U.S. and EU milk requirements are: 1) the EU somatic cell count (SCC) and bacterial standard plate count (SPC) requirements apply at the farm level, and 2) the EU maximum SCC in raw cow’s milk is 400,000 cells/mL. Additional highlights of the program include:
Milk suppliers, dairy processors, and applicants for EU Health Certificates are responsible for maintaining records to trace their product back one step in the supply chain (toward the raw milk production) for all dairy products/ingredients intended for export to the EU.
Processors of dairy products/ingredients that require an EU Health Certificate will be responsible for maintaining Certificates of Conformance (COCs) demonstrating the dairy products/ingredients meet EU SCC and SPC requirements.
Testing of the farm-level milk supply will be necessary to document compliance with the requirements for export of dairy products to the EU (both Grade A and Grade B milk for SCC, and Grade B milk for SPC). Grade A plants that supply ingredients or raw milk are generally exempt from requirements to keep additional records on SPC to confirm compliance with EU regulations.
Milk suppliers will be responsible for providing COCs to processors, as well as maintaining records of individual farms, to confirm that raw milk meeting SCC and SPC requirements of the EU is received at facilities manufacturing dairy products for shipment to the EU.
With respect to timing and implementation, all farms will be given three months to establish initial rolling three-month means – that is, SCC data collected in January, February, and March will be used to determine the rolling three-month mean for April. Non-Grade A farms will be given two months (January and February) to establish initial rolling two-month means for SPC. This data will serve as the initial basis for updated COCs under the new program requirements. According to the new program instructions, if a rolling mean exceeds EU requirements, the milk supplier must then notify AMS.
The program instructions include a level of flexibility for farms that exceed EU SCC or SPC requirements, but work toward compliance. (For detail on these provisions, see Section F “Milk Supplier’s Responsibility” (pages 6-7), sections b and c.)
Information on the certification program may be found online