For decades, the National Conference of Interstate Milk Shipments (NCIMS) has served as a model cooperative program between the U. S. Public Health Service/Food and Drug Administration, the states, and the dairy industry. NCIMS brings together all dairy stakeholders to maintain and update the Grade “A” Pasteurized Milk Ordinance (PMO), which provides uniform regulations for the dairy industry.
The 39th National Conference on Interstate Milk Shipments met April 11-16 in Minneapolis, MN, to deliberate many important issues facing FDA’s National Grade “A” Milk Program, the PMO, and related documents. Delegates representing 49 states and Puerto Rico attended, along with representatives from FDA and industry organizations. Attendees reviewed and discussed 81 different proposals for changes to the PMO, nine of which were submitted by NMPF on behalf of its members. All proposals relate to the 2023 Pasteurized Milk Ordinance (PMO), the 2023 Methods of Making Sanitation Ratings of Milk Shippers, the 2023 Evaluation of Milk Laboratories, and the 2023 Procedures Governing the Cooperative State-Public Health Service/Food and Drug Administration Program for Certification of Interstate Milk Shippers (Procedures) document. Delegates approved 56 proposals either as submitted or as amended. Success can be achieved by raising the issue to the attention of conference participants, by generating discussion, or by obtaining formal answers and gaining consensus of all stakeholders. NMPF had favorable outcomes for the proposals it submitted, including Proposal 311, which clarifies language around Animal Treatment Record requirements, and a proposal updating the rules for cleaning on-farm bulk tanks and silos to be consistent with the rules for bulk milk hauling trucks and trailers.
One issue NMPF brought forward at the conference was the confusion caused by the “Dear Veterinarian Letter” FDA published Oct. 11 regarding use of aspirin products in lactating dairy cattle. In the letter, FDA says that veterinarians and dairy farmers should stop use of unapproved aspirin in lactating dairy
cattle and use FDA-approved products to control pyrexia and pain. This letter has caused confusion and concern across the industry for the past 6 months, highlighting the difficulty dairy farmers face to determine whether medical and drug products openly sold for use in dairy cattle are legal or illegal to use which could result in debits during required PMO farm rating inspections. NMPF used the conference as an opportunity to gain clarity from FDA on its position and ensure that federal regulators are on the same page as the states and industry. NMPF worked with FDA before and at the Conference to thoroughly discuss the issue, resulting in an NCIMS vote in favor of creating a study committee to engage FDA, USDA, industry, and other appropriate stakeholders in exploring drug and chemical storage requirements and the administrative procedures for unapproved animal drugs, homeopathic/all natural drugs and medical devices.
Study committees will also be formed to further explore topics that delegates felt did not have enough information to pass a proposal during this conference. One study committee will look efficiencies within the PMO, born from several proposals focusing on milk sampling and inspection frequencies, and another will evaluate whether certain vitamins should be added before or after pasteurization. Two study committees that were created previously, which are focused on strained yogurt and on food defense, will continue their work ahead of the next conference. NCIMS also voted in favor of Resolution 10, a resolution to re-establish a committee on water.
This conference also dedicated some time to celebrate the centennial of the PMO in 2024. FDA ran a campaign throughout the year to showcase what 100 years of the Pasteurized Milk Ordinance has done for milk safety in the United States.
NCIMS is an incredibly important collaboration between industry and both state and federal regulators. Leaders from NMPF and its member cooperatives are very involved in NCIMS, and many serve on the NCIMS Executive Board, Councils, or committees between conferences.
Important proposals
Proposal 105
Proposal 105, submitted by NMPF, updated the rules for cleaning on-farm bulk tanks and silos, allowing them to be cleaned once in every 24-hour period as long as they are in continuous use, similar to milk hauling trucks and trailers, instead of being cleaned every time the on-farm tank is emptied. This proposed rule will save time and money for many dairy farmers who have multiple milk shipments a day and may have a positive environmental impact from less frequent chemical washes. This proposal was passed with some committee amendments by the delegates. Special thanks to Steve Lehman from Michigan Milk Producers Association for his work in committee and council to help get this measure passed.
Proposal 120
Proposal 120, submitted by NMPF, updated language in the PMO about Animal Treatment Records. The proposal was amended at conference to strike all of the treatment record language in Appendix C of the PMO because treatment record requirements are already sufficiently covered by CVM guidance and National Dairy FARM Program requirements.
Proposal 301
Proposal 301, submitted by NMPF, provided a definition of equivalence for the USPHS/FDA responsibility to determine whether a foreign country’s regulatory program and government oversight of that program has an equivalent effect on the safety of the regulated milk or milk product. The term “equivalence” is important for international trade; unfortunately, the PMO has long lacked a definition. This proposal used the exact language that was approved by delegates at the 2023 NCIMS conference but was not ultimately enacted due to a procedural issue. FDA opposed this change and because FDA and NMPF could not agree on a new definition of equivalence, NMPF recommended a no action vote.
Proposal JC-1
Proposal JC-1, submitted by NMPF, provided clarity for drug and chemical storage requirements and the administrative procedures for unapproved animal drugs, homeopathic/all natural drugs and medical devices. This proposal would help clear confusion caused by the “Dear Veterinarian Letter” FDA published Oct. 11 regarding use of aspirin products in lactating dairy cattle. In the letter, FDA said that veterinarians and dairy farmers should stop use of unapproved aspirin in lactating dairy cattle and use FDA-approved products to control pyrexia and pain, which could result in debits during required PMO farm rating inspections. Delegates passed an amended proposal requesting the establishment of a study committee to engage FDA, USDA, industry, and other appropriate stakeholders in exploring drug and chemical storage requirements and the administrative procedures for unapproved animal drugs, homeopathic/all natural drugs and medical devices. FDA also said on the record twice — at Council and on the delegate floor — that aspirin on farms would not result in debits during PMO farm rating inspections.
Proposal 311
Proposal 311, submitted by NMPF, requested the establishment of a “Farm Practices” committee to review any submitted proposals that relate to on-farm practices, rather than sending those proposals to currently existing committees like the hauling committee. This proposal was amended to request an ad-hoc committee instead of a standing committee and it was ultimately passed as amended.
100 Years of the Pasteurized Milk Ordinance
This conference also dedicated some time to celebrate the centennial of the PMO in 2024. FDA ran a campaign throughout the year to showcase what 100 years of the Pasteurized Milk Ordinance has done for milk safety in the United States. The “Saluting Our States” campaign set an engagement record for FDA’s social media accounts.
Other industry partners also celebrated the centennial in different ways, including an award-winning feature story in New York Archives, and a deep dive about the PMO in the Food Safety Matters podcast. NMPF celebrated the centennial in multiple NMPF newsletters and publications throughout the year.
2025 NCIMS CONFERENCE
PROPOSALS TRACKING SHEET
= Oppose
JOINT COUNCIL
# Committee Submitted by Short
JC-1 Liaison
Jonker, NMPF Clarifies drug & chemical storage requirements of 15r
JC-2
Other Species, Scientific, MMSR, ICP
Turpin, Other Species Comm. Updates Section 8 disease testing requirements, aligns PMO and MMSR
JC-3 Lab, ICP
Traas, Harold Wainess & Assoc. Allows TPCs to use Proficiency Test Providers
tracking sheet is provided as a courtesy by NCIMS. Information was current as of 4/16/2025.
COUNCIL III
301
*New Proc Jonker, NMPF Creates a definition for Equivalence
Change
303
*Proc Change Wilson, MMSR Comm.
Extends FDA editorial abilities to update NCIMS forms
Prevents state ratings and check ratings from being conducted simultaneously
MMSR *Proc Change Wilson, MMSR Comm. Clarifies language regarding reinspections and re-ratings
305 MMSR *New Proc Wilson, MMSR Comm.
306 SSCC *New Proc Sobeck, Wisconsin
307 MMSR *Proc Change Wilson, MMSR Comm.
Establishes requirements for when a new facility requests an initial listing
Allow SROs to be (re)certified for single service facilities, separate from dairy plants
Aligns PMO and Procedures for delegation for evaluation of Industry Plant Samplers to industry
