And What This Means for You
The upcoming change to the European Union (EU) milk quality requirements for U.S. produced and exported milk has gotten lots of attention in the last 6-months. On paper, the regulations may appear only slightly different than in the past. Producers who sell milk to processors that do not export milk may believe the changes won’t affect them. However, the new regulations could result in real short and long-term milk quality implications for most dairy farms.
This article presents what we know about the new EU milk quality export requirements. It also describes the difference between the EU regulation and the U.S. Pasteurized Milk Ordinance. General information on how milk processors are handling the new regulations is also included. In this article, the term milk processor is used broadly and includes milk buyer, milk supplier, milk plant, and milk cooperative.
It is important to talk with your own milk processor about specific impact of regulations for your farm and based on your farm’s history of milk quality. Each processor that exports milk must meet minimum mandated requirements. Processors that do not export milk are not required by law to follow the new EU Regulation but will continue to follow the Pasteurized Milk Ordinance as a minimum requirement.
Many specialists believe that all processors whether directly exporting product or not will follow suit and require individual dairies to meet the EU regulations as a minimum requirement. In fact, many milk processors currently have similar regulations for their individual producer dairies or have incentives in place to encourage producers to meet or exceed these same milk quality standards. The goal of this article is to aid understanding so you can better ask questions of milk quality advisors and can prepare for potential impact of the new EU regulations on your dairy or client’s dairies.
What is the new EU Milk Quality Requirement?
The EU requirement starts April 1, 2012. Individual dairies are being given between January 1, 2012 and March 31, 2012 to meet this requirement. The EU regulation states that all milk to be exported from the U.S. to any member or allied EU country must meet milk quality standards of somatic cell count (SCC) and bacteria count (Standard Plate Count = SPC) of less than 400,000 cells/ml and 100,000 cfu/ml, respectively.
The main difference between the new and previous EU regulation is that the requirement is now for milk from individual dairies and not for pooled milk (multiple dairies) from the processor. In the past, milk could be collected from several farms and as long as the average of what was exported to the EU met the quality regulations, the milk or milk product could be exported with no problem. Now each individual farm’s milk average must meet the requirement.
The farm’s SCC requirement to meet the EU regulation is a 3-month rolling average. The term rolling average is similar to that used by DHIA. It means that the SCC used will be the average of the current month’s SCC and the two previous months. The three-month rolling SCC average is recalculated each month. According to the regulation, at least 1 official SCC per month must be used by the milk processor to represent a farm’s monthly SCC. However, many milk processors take the average of several official SCC tests to represent the farm’s monthly SCC and may continue to do so.
The farm’s SPC requirement is a 2-month rolling average. It means that the SPC used will be the average of the current month’s SPC and the previous month. This 2-month rolling SPC average is recalculated each month. The EU regulation requires that the average of two official SPC in a single month be used to calculate a herd’s monthly SPC average.
According to the EU Regulation, the 3-month rolling average SCC and 2-month rolling average SPC can be calculated by using either the arithmetic average or geometric average. The arithmetic average is currently used. Most milk processors will likely continue using the arithmetic average at this time. The geometric average is the actual midpoint of several tests whereas high or low tests may have a greater influence on the arithmetic average. If your SCC is generally consistent over time, this difference is not that important. The geometric average is used by most milk processors from countries outside of the U.S. to evaluate herd milk quality. Microsoft Excel has formulas to calculate an arithmetic or geometric mean and can be easily used to estimate your rolling average for SCC and SPC.
The US Pasteurized Milk Ordinance and EU Requirement
The Pasteurized Milk Ordinance (PMO) contains milk quality standards that are minimum requirements for all U.S. dairy producers. The PMO requires that milk from individual farms be less than 750,000 SCC and less than 100,000 SPC. The new EU Requirement does not change the PMO requirement. This may seem confusing but remember the EU Requirement (400,000 SCC) is only for milk from individual farms that will be exported from the U.S. to EU or allied countries. In theory, individual dairies whose milk processor will not export product are required to only meet milk quality standards of the PMO or their milk processor. As mentioned previously, many milk processors have milk quality standards superior to the PMO.
Some Short-Term Exceptions Are Allowed
The EU requirement states that individual farms may request a temporary exception if their milk quality does not meet regulations. You may also hear this referred to as a derogation. According to the EU requirement, an application can be submitted by the milk processor to the United States Department of Agriculture-Agricultural Marketing Service (USDA-AMS) requesting an exception. It is expected that the cost for the milk processor will be about $200 per application. Milk processors are then required to work with the farm to resolve the cause of high SCC or SPC.
If a farm has long term challenges in meeting the EU requirement the milk processor will be required to stop picking up milk from that farm, or will need to segregate milk to comply with EU requirements. To qualify for a seasonal exception, a farm must have 9-months of milk quality results that meet the EU requirement. The farm must also demonstrate through records that this seasonally high SCC or SPC rolling average isn’t due to poor hygiene or unsanitary procedures.
Impact
The new EU Regulations will take place for US dairy producers on April 1, 2012. As described, the requirement specifically applies to individual dairy farms that sell milk to processors that export dairy products to the EU and allied countries. The requirement states that each of these dairy farms must meet the regulation for a 3-month rolling average SCC below 400,000 and 2-month rolling average SPC below 100,000. It is very likely that all dairy farms should be prepared to meet these minimum requirements for milk quality. Many milk processors are changing milk quality premium schedules to further encourage producers to meet the demand for quality milk in the US and by other countries.
To further expand and supply export opportunities for US dairy products it is likely that the trend for improved milk quality will continue and grow. As milk processors and individual farms work to meet these new standards they will improve quality milk in the U.S. resulting in a lower average SCC for U.S. milk.
More information, including frequently asked questions, can be found at the following website: http://nmpf.org/washington_watch/labeling/SCC
Dr. Sandy Costello is owner and mastitis/milk quality specialist at Milk Quality Pays and provides on-farm milk quality consulting, training, and product and applied research to aid producer decisions. The mission of Milk Quality Pays is to ensure clients produce and sell milk of the highest quality while maximizing profitability from milk income and maximizing customer assurance of product quality, safety, and worker & animal well-being. Dr. Costello can be reached at 570-768-6140 or scostello@milkqualitypays.com.
Sunday, March 4, 2012
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