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Arguing that milk leaving U.S. dairy farms is an unlikely target for a terrorist attack, NMPF asked the Food and Drug Administration to exempt dairy producers from “intentional adulteration” regulations being issued under the major rewrite of federal food safety laws enacted in 2011.

In comments filed with FDA on June 30, NMPF said it’s hard to predict where milk from any one dairy farm will go because of constantly changing processing needs around the country. As a result, NMPF said, milk leaving a dairy farm is unlikely to be a target for intentional adulteration and “activities on dairy farmers should not be addressed through this rule.”

NMPF also pointed out that dairy farms already employ a number of general security strategies that further reduce risks to plant-bound milk and that many anti-terrorist procedures are already being used on these farms.
In addition, NMPF submitted comments jointly with the International Dairy Foods Association questioning FDA’s proposed regulations focused on preventing intentional adulteration at dairy processing plants. Like dairy farms, the two organizations said, processing facilities have taken an active approach to applying food defense concepts.

In all, FDA has proposed seven major regulations under the Food Safety Modernization Act signed into law in January 2011. Only this rule addresses terrorism, while the others have less direct impact on dairy farms. NMPF will be submitting comments at the end of this month on a major proposed FSMA regulation addressing sanitary transport.