The Food and Drug Administration's expanded food safety requirements for on-farm milk and security at dairy processing plants under the Food Safety Modernization Act should be revised, the National Milk Producers Federation wrote in Monday comments to FDA on the proposal.
Under the new requirements, on-farm milk destined for pasteurization is categorized as a "high-risk food" and is subject to additional food safety requirements.
But NMPF says milk is leaving farms for further processing, and it is not a significant public health risk from intentional adulteration.
Raw fluid milk for pasteurization moves among various regions of the country and is in constant flux to meet specific processing demands, NMPF says. Because of the challenge of predicting the precise processing facility and type of product or ingredient to which an individual farm's milk is ultimately destined, NMPF concluded that "activities on dairy farms should not be addressed through this rule."
The dairy provision is just one part of the larger rule, which is intended to enhance the safety protocols around foods that may be subject to intentional adulteration, by terrorists looking to threaten or injure people, or cause economic harm to certain companies or industries.
In its comments, NMPF argued that dairy farmers currently implement a number of general security strategies to protect the investment of their property, equipment, animals and milk supply, "which further reduce any risk that may be represented by on-farm milk destined for pasteurization."
Because of farmers' own biosecurity efforts, new security measures would only be warranted "when a credible threat of intentional adulteration against the milk supply is identified," NMPF said.
NMPF suggested more collaboration with federal and state stakeholders – as well as the dairy industry --- through the National Conference on Interstate Milk Shipments to develop specific aspects of food defense regulations.
Dairy processing regulations
In addition to its perspective on food defense and dairy farms, NMPF also submitted comments, along with the International Dairy Foods Association, focused on preventing intentional adulteration at dairy processing plants.
Those comments also expressed concern with the direction of FDA's proposal, and asked the agency to "fundamentally reconsider its proposed approach."
Like dairy farms, dairy processing facilities have worked with FDA to take an active approach in applying food defense concepts to their manufacturing operations, according to the two organizations.
IDFA and NMPF proposed that FDA only require basic food defense plans consisting of cost-effective mitigation strategies, allowing facilities to then identify reserved focused mitigation strategies that can be quickly implemented in response to heightened concerns or credible threats, should they be deemed necessary.
The joint comments also emphasized that each processing facility and dairy farm is unique. If FDA were to require food defense plans, the dairy industry must have the flexibility to address intentional adulteration in ways that are custom-tailored with respect to their individual attributes, rather than prescribing "one-size-fits-all" specific criteria.