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NMPF Comments on FDA’s Risk-Ranking Model for Animal Drug Residues

August 4, 2015

NMPF submitted comments last week on the Food and Drug Administration’s Multicriteria-based Ranking Model for Risk Management of Animal Drug Residues in Milk and Milk Products. The comments will help influence the extent to which the FDA alters the current testing system it administers, along with state regulatory agencies, to prevent antibiotic residues in the dairy supply.

The risk-ranking model was developed in response to a 2008 request from the National Conference on Interstate Milk Shipments (NCIMS) to conduct a risk analysis of drug residues in the milk supply. It represents a science-based analytical approach to collate and incorporate relevant public data and information to assist with evaluating milk residue testing programs.  

NMPF offered feedback on the model’s design, assumptions and data, and the clarity and transparency of the model, as well as its potential implications for residue testing requirements of the Pasteurized Milk Ordinance (PMO).  The model is one of the many tools the NCIMS Appendix N Committee will use to develop a pilot program to expand testing for non-beta-lactam drugs through the PMO.  A proposal directing the Appendix N Committee to develop the pilot program was passed at the 2015 NCIMS in April.  

FDA recently extended the comment period on the risk-ranking model to October 27th.