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7 minute read
Winning Through
Determined Defense Dairy’s biggest regulatory successes often come from a regulation not being proposed or a decision postponed. NMPF kept dairy from being dragged into commentary around per- and polyfluoroalkyl substances (PFAS) chemicals, which are an environmental-contamination issue focused on water. The regulatory team also worked closely with FDA and the National Conference on Interstate Milk Shipments Appendix N committee to develop a new antibiotic sampling program to further confirm the safety of the U.S. milk supply. NMPF also pushed back against a non-binding guidance from FDA that attempted to justify its decades of action on the labeling of plant-based imitators, even as the agency supported new nutritional disclosures on plant-based beverage labeling, an advance for dairy and its consumers.
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Key Advances
Pressured FDA to ensure integrity in dairy labeling despite non-binding “guidance” justifying agency inaction.
2 Shaped the upcoming FDA antibiotic residue sampling assignment to ensure farmer and cooperative needs are being met.
3 Brought in elements from the Secure Milk Supply (SMS) Plan for Continuity of Business to support advanced development of the FARM Biosecurity module.
4 Worked with USDEC and DMI leadership to secure the 2023 International Dairy Federation World Dairy Summit for the U.S.
5 Kept dairy at the periphery of debates over PFAS, which remains a water issue.
Benefitting Dairy Through Environmental Efforts
PFAS and Waters of the United States (WOTUS) continued to be the main themes for NMPF’s environmental regulatory work. PFAS, which entered conversations in the 2010s when it was found on dairy farms in New Mexico and Maine, has been a focus for the Environmental Protection Agency (EPA) under the Biden Administration.
Recent EPA regulatory moves this year on PFAS have included proposing adding both PFOA and PFOS, two main PFAS chemicals, to the Comprehensive Environmental Response, Compensation and Liability Act list of hazardous chemicals also known as Superfund. NMPF submitted comments on November 7th, firmly against this move, stating the potential impact it could have on thousands of dairy operations. EPA has also announced an effluent guidelines program which includes a new study looking at Concentrated Animal Feeding Operation discharges including both nutrient and PFAS, from production and land application areas.
Other topics tackled in 2022 included speeding the pace of animalfeed additive approvals. While such additives hold promise toward moving dairy toward its promised net-zero future, their pace of approval lags that of competitors such as the European Union due to current FDA processes. NMPF in November urged FDA to allow feed additives to be treated as foods rather than as drugs, so the U.S. can maintain and advance its global leadership in dairy sustainability. NMPF and Newtrient in June supported USDA’s plan for a modernized “NRCS Conservation Practice Standard 592—Feed Management” to include ammonia, volatile organic compounds, greenhouse gases and dust, which will expand the opportunity for dairy farmers to use that standard for enteric methane-reducing feed additives.
NMPF’s long-term advocacy on climate smart agriculture paid dividends to the U.S. dairy industry in 2022. In September, USDA funded climate smart projects by California Dairies Inc., Dairy Farmers of America, Land O’Lakes, and the Maryland & Virginia Milk Producers Cooperative Association—which are
$245M leading or partnering on specific projects that may receive up to $245 million in funding. USDA’s support recognized the robust efforts dairy farmers are leading to develop and implement climate-smart solutions that will benefit the entire food chain, from producer to consumer.
USDA FUNDED CLIMATE SMART PROJECTS BY CALIFORNIA DAIRIES INC., DAIRY FARMERS OF AMERICA, LAND O’LAKES, AND THE MARYLAND & VIRGINIA MILK PRODUCERS COOPERATIVE ASSOCIATION—WHO ARE LEADING OR PARTNERING ON SPECIFIC PROJECTS THAT MAY RECEIVE UP TO $245 MILLION IN FUNDING.
Enhancing Animal Health
NMPF has been active in efforts to enhance animal health and protect the U.S. dairy herd from foreign animal diseases. While USDA continues to modernize the Bovine TB and Brucellosis eradication programs, NMPF supported the Department’s efforts to modernize animal indemnity value determinations, including more frequent updates to reflect current animal values. NMPF supported updates to the USDA National Organic Program Livestock and Poultry Standards that further aligned with the ISO-accredited National Dairy FARM Program Animal Care Standards. NMPF also continues to convene the Tuberculosis Working Group, made up of both federal and state stakeholders, working to develop guidance for dairy farmers on human to cattle tuberculosis transmission.
A second year of USDA funding further strengthened the National Dairy FARM Biosecurity Program, with publication of the FARM Everyday Biosecurity Manual and further integration of the Secure Milk Supply Plan into the program. NMPF also joined an agriculture coalition letter to House and Senate leadership, supporting the swift passage of the Beagle Brigade Act. The Beagle Brigade is used at ports of entry (airports, seaports, land crossings) to detect fruits, vegetables, and meats entering the U.S. as part of the system used to minimize the risk of Foot and Mouth Disease being introduced into the United States.
NMPF also worked with FDA and State regulatory officials on the design of a new three-year National MultiDrug Residue Raw Milk Monitoring Project that starts in 2023 and will guide the food safety risk assessment process to ensure drug residue testing requirements reflect the latest science, thus affirming the safety of U.S. milk. Only 1 out of 12,400 milk tankers tested positive for antibiotic residues last year, according to the 2022 National Milk Drug Residue Database annual report released by the U.S. Food and Drug Administration. The data illustrates the continued long-term national pattern of improvements in milk quality practices by the industry.
Reinforcing Dairy’s Importance to Diet
NMPF’s regulatory team also remained active in nutrition policy, a Biden Administration priority. Staff worked closely on comments on the transitional school meal standards rule as well to the proposed rule to the special supplemental program for women, infants and children. In addition, the 2025-2030 Dietary Guidelines for Americans process started, which has included submitting comments on the proposed scientific questions that determine the focus of the scientific committee.
Continuous Improvement
The FARM Program updated and improved each of its program areas—Animal Care, Antibiotic Stewardship, Biosecurity, Environmental Stewardship and Workforce Development. Major highlights include furthering the development of Animal Care Version 5, publishing an updated Milk and Dairy Beef Drug Residue Prevention
Manual, publishing the Everyday Biosecurity Manual, launching the Environmental Stewardship Conservation Practice Questionnaire (CPQ) and beginning Environmental Stewardship Version 3 development, leading its first inperson Workforce Development Evaluator Training, and making FARM website and FARM database changes and bug fixes that improve user experience.
Key Advances
1 Hosted more than 50 meetings or engagements on updating FARM Animal Care Program standards.
2 Received recertification from the Professional Animal Auditor Certification Organization for FARM Animal Care.
3 Published new resources including the 20222023 edition of the FARM Drug Residue and Prevention Manual and corresponding pocket guide, and the Everyday Biosecurity Manual.
4 Unveiled a new FARM Environmental Stewardship Conservation Practice Questionnaire enabling dairy farmers to better share their sustainability story.
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5 Expanded the Workforce Development Program and conducted the first in-person Workforce Development Evaluator Training.
Heading Toward Version 5
The FARM Animal Care Program made progress toward its Version 5 standards updates through surveys, committee and task force meetings, and a public comment period. FARM Animal Care certified or re-certified 411 new and experienced animal care evaluators this year who together completed 8,625 Animal Care Version 4 evaluations in 2022. FARM Animal Care received Professional Animal Auditor Certification Organization (PAACO) recertification for the second year in a row. The FARM Program also released new and updated resources in 2022, including a Fitness to Transport video in conjunction with industry partners Elanco and Cargill, posters, fillable farmer resources available in English and Spanish, and optional trainings from partner organizations.
milk and meat. To make this critical information even more accessible, the FARM Program also released the Drug Residue and Prevention Pocket Guide that provides farmers and evaluators with a quick, easy reference to the updated list of approved drugs, screening tests, and withdrawal times under the FARM Program.
Adding Biosecurity Resources
8,625 ANIMAL CARE VERSION 4 EVALUATIONS COMPLETED BY FARM ANIMAL CARE CERTIFIED EVALUATORS IN 2022.
NMPF and FARM worked with the FARM Antibiotic Stewardship Task Force—composed of animal scientists, veterinarians, and animal health professionals—to draft and release the 2022-2023 edition of the FARM Drug Residue and Prevention Manual. This resource is the primary educational tool for dairy farmers on the judicious and responsible use of antibiotics, including avoiding drug residues in
The FARM Biosecurity Program, developed in 2021 through a cooperative agreement with USDA National Animal Disease Preparedness and Response Program, published the Everyday Biosecurity Reference Manual as well as other everyday biosecurity resource materials. Co-branded FARM/Secure Milk Supply materials for enhanced biosecurity, including the secure milk supply plan template, were created this year. FARM Biosecurity will help prevent the devastating impact and reduce the spread of potential disease events through planning and preparedness. In 2023, FARM Biosecurity plans to create additional resources that will help farms develop enhanced biosecurity plans for their operations including a training focused on how to develop a secure milk supply/ enhanced biosecurity plan.
Workforce Evaluation Progresses
The FARM Workforce Development (WFD) Program equips dairy owners and managers with tools to enhance their safe and thriving work environments. Since launching the FARM WFD evaluation in 2020, more than 300 evaluations covering HR and safety topics have been conducted on farms with a collective 6,300+ employees. The evaluations completed to-date offer a window into HR and safety practices of participating farms. In addition to three successful virtual evaluator trainings completed in 2022, the Workforce Development Program hosted its first in-person evaluator training in Syracuse, NY. Fifty-seven Workforce Development evaluators were certified in 2022 across 17 program participants.
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Moving FARM ES Toward RuFaS
FARM Environmental Stewardship (ES) continued its widespread program implementation with evaluators conducting more than 750 evaluations. FARM ES launched a Conservation Practice Questionnaire (CPQ) as an optional add-on to the FARM Environmental Stewardship evaluation. The CPQ is designed to share a more holistic picture of dairy farmers’ sustainability story, address priorities covered in the industry-wide 2050 environmental stewardship goals and incorporate additional topics of customer interest. FARM Environmental Stewardship also released GHG fact sheets on the FARM website, which provide more background on sources of emissions on dairy farms and opportunities for GHG mitigation. The FARM Program, Dairy Management Inc. (DMI), and Ruminant Farm System (RuFaS) are collaborating to adapt the RuFaS model for the next version of FARM ES. The FARM ES Version 3 Working Group convened four times in 2022 to inform the evolution of FARM ES. Also in 2022, on-farm field testing of the scientific model began on six farms, with more slated for testing in 2023.
The FARM Program made website updates; fixed database bugs and made progress toward a database overhaul scheduled for 2023; and refreshed hundreds of free templates and resources for farmers and evaluators to use. To help with the improvements across all program areas, the FARM Program filled three open roles—program coordinator, information systems analyst, and communications lead—and worked with DMI to find a fit for their open customer outreach role. In the year to come, the FARM Program will continue to work with dairy producers, cooperatives, processors, and industry partners to demonstrate the highest standards on U.S. dairy farms.
SINCE LAUNCHING THE FARM WFD EVALUATION IN 2020, MORE THAN 300 EVALUATIONS COVERING HR AND SAFETY TOPICS HAVE BEEN CONDUCTED ON FARMS WITH A COLLECTIVE 6,300+ EMPLOYEES