Somatic cells were perhaps the biggest news coming out of the joint annual meeting of National Dairy Board, National Milk Producers Federation, and United Dairy Industry Association October 26 to 28 in Reno, Nev.
At the meeting, NMPF directors approved a resolution to cut the current 750,000 maximum somatic cell count level in raw milk to 400,000 over a three-year period: to 600,000 on January 1, 2012, to 500,000 a year later, and then to 400,000 a year later.
The proposal will be made at the next meeting of the National Conference on Interstate Milk Shipments beginning April 28, 2011 in Baltimore. If adopted into the Pasteurized Milk Ordinance by the U.S. Food and Drug Administration, it would bring our milk quality standards into line with the most stringent levels used in other nations.
Most milk producers in the U.S. already easily meet the proposed lower limit. According to the USDA Animal and Plant Health Inspection Service, milk weighted average bulk tank SCC in the U.S. in 2009 was 227,000. It also says 75 percent of all milk shipments were under 400,000.
During the meeting we interviewed NMPF president and CEO Jerry Kozak about the SCC cut proposal. Here are his comments:
Were you surprised that NMPF delegates adopted a resolution to cut the legal SCC limit to 400,000?
"No. I can't tell you how proud I am of representing National Milk, because since I've been here there's never been one occasion, whether it's on somatic cell counts or animal care or food safety, where our membership hasn't allowed us as staff to do all the right things.
"With the success of any company or organization, 95 percent is advance preparation. We had prepared ourselves, we had discussed it within our membership. I've been traveling all around the country lately on "Foundation for the Future," so I've heard their concerns and their ideas and I wasn't surprised at all.
"In looking at what was going on with the European Union somatic cell count issue, listening to what was happening in the competitive environment that our co-ops were dealing with, and hearing some of their concerns about retailers and processors imposing different guidelines, it was my sense that we ought to as staff bring forward those issues to our membership.
"The only question was, are we going to have a two or a three-year transition? Our original proposal was a two-year transition. There were obviously concerns raised by some that because of the climate in certain geographic areas they needed a little bit more time. That was the only issue."
In the past NMPF has opposed proposals by other groups to lower the SCC limit. Why now, what changed?
"I've seen all sides of the industry in my career. I worked 10 years at the state level with all food programs. At FDA I was director of the Milk Safety Branch for five years, so the Pasteurized Milk Ordinance was something I was very involved in. Then I was on the processor side for eight years, and now I've been on the producer side for 14 years.
"It became apparent to me that as much as SCCs are not really a public health safety issue, how do you determine what is the most appropriate level? When I was at FDA I asked our chief microbiologist and in those days the limit was 1.5 million how did we arrive at that number? He sort of pulled his fingers out of the air and said, "That's how I got it."
"Because of a listeria situation in cheese, salmonella in pasteurized milk in Chicago, and some other incidents that all happened on my watch, it was clear to me that we needed to continue to look at these standards and improve the quality of our milk. So we cut it in half to 750,000. There's was no magical number there.
"Over the years, well-intentioned groups, and certainly the National Mastitis Council who we have a lot of respect for, continued to try to move those standards down. Their intentions were good, but the fact is at that time a significant amount of our milk would have been impacted by lowering those standards.
"If you look at the last 10 years, which is what Jamie Jonker, NMPF's vice-president of Scientific & Regulatory Affairs did, he showed the progression in all geographic regions of how much we have improved SCCs. So I finally felt we were at a level that wasn't going to impact the ability of any dairy farmer to ship their milk strictly because of a high SCC.
"The final piece was, do we want to control our own destiny? We knew the next NCIMS meeting was coming up (beginning April 28 in Baltimore, Md., and held only every two years) so we couldn't afford to not bring up this subject now so that we were prepared for it. I was concerned that a state or even FDA proposal could arbitrarily set a date, which I don't think is the appropriate way to change policy. I think you should always allow, wherever you can, some transitional mechanism so that people understand "at this point in this year I have to be at that level, and I have at least two to three years to get there." Even as a regulator I always felt you couldn't just be Draconian in your approach. That's terrible policy.
"I think there's also a greater acceptance level [with a three-year transition]. If we had submitted a proposal to the delegates to go straight to 400,000 next July I'd be coming out of the Burn Unit now.
"The best way for us to defend ourselves as an industry, no matter how much we spend on promotion, unless we are doing all of the right things the public will see through that eventually."
The great majority of milk made in the U.S. already meets the 400,000 SCC standard, with one notable exception: the Southeast. How will producers there react to this proposal, and will they work with NMPF?
"It's encouraging so far, because we knew a good portion of our membership in the Southeast could be impacted. There was a statement made by one of our dairy farmer leaders in the Southeast who said, "Look, we'll get there, we'll be OK. But we just need some time to do it." That made me very proud.
"Market forces are clearly dictating some of this, so they have to do it. Secondly, because of the transition they'll be able to pay more attention to getting that level down. Are there some occasions when, out of their control, something may happen? Yes. That's where we hope to have regulations that allow for some flexibility, rather than an arbitrary cutoff.
"That's another reason why I felt we needed to take a stand ourselves, to show the regulatory community that we are sincere about moving toward the countdown. But at the same time we want there to be some discretion for a unique circumstance on an individual farm, such as a hurricane or flood."
The last time the U.S. cut its SCC limit was in July 1993. As we look back in the rearview mirror now, is 400,000 something that maybe should have been done earlier?
"No, I don't think so. Remember, the PMO is literally a food safety document. The dangers and challenges over the years have been to not put in quality-type measures in a public health service document. When you start mixing quality measures in there, you're really starting down a slippery slope."
Because NMPF is now behind a proposal to lower the SCC limit, what do you think are its chances of being adopted?
"I think it's extremely likely this will happen. I have no doubt that because the industry itself, the producer side, is going to go to the NCIMS meeting with a transitional plan to get to 400,000, that the state health authorities are going to embrace it and FDA itself is going to eventually endorse it. I think it's going to happen.
"I think we're at a good time. Will there be some criticism? Sure. Here's where I expect it: People are going to say the transition is too long. But we're trying to send a message about moving forward and making progress, and it's been 17 years since we changed the last time; do we really want to argue about one, two, or three years? You don't just cut somebody's business off in one single stroke."
Lowering the SCC limit seems to fit in well with the current National Dairy FARM (Farmers Assuring Responsible Management) Program. Do you agree?
"Absolutely. Everything we do we should be looking at strategically how all of it fits into the big picture. I don't know how you can lower somatic cell counts unless you're practicing good animal husbandry and you're taking care of your animals properly and the environment they are housed in is good. I don't think we'd be as effective just to lower the somatic cell count but not provide any guidance to the producers out there as we are now. It's got to be linked together."
This article appears in the December 2010 issue of Hoard's West.
