Milk is Defined by Safety

In an era of evolving food policy (and the worries that entails), it’s good to know that food-safety safeguards that have existed for generations are still doing their jobs, no matter what the anxiety of the month may be.

Milk is Exhibit A of the tried-and-true in action. The Pasteurized Milk Ordinance (PMO) regulating all Grade “A” milk is more than a century old, making sure that a product that caused 19th century panics has been a trusted source of premium nutrition well into the 21st. The PMO is pretty mundane: Its exhaustive rules and regulations make a great cure … for insomnia. And that’s the point. By outlining in extensive prescribed detail how milk must be handled, tested, and then mandating those procedures, the PMO goes to great lengths to ensure the safety of milk – so you don’t have to worry about it.

Here’s a taste of the required testing milk must go through, from farm, to processing plant, to store shelf. And these are the minimum requirements – many dairy farmers and milk processors go above and beyond, to protect the health of consumers and their own success in the marketplace.

According to the PMO:

Within two hours of milking, all milk must be cooled to 45 degrees Fahrenheit (7 degrees Celsius) and refrigerated properly until a milk truck driver arrives, in a vehicle that’s highly regulated to ensure proper cleanliness. When the driver arrives at a farm to pick up milk, the driver takes or picks up samples from each farm’s bulk milk tank (and/or silo) and holds those in a cooler for further follow up if any anomalies are identified in subsequent testing.  When the tanker arrives at the processing location, each tanker is tested for animal drug residues as required by the Pasteurized Milk Ordinance (PMO). And if the results find antibiotics (specifically, beta lactams), the milk is rejected and removed from the animal and human food supply. b. Tankers are also tested for somatic cells to assess quality and tested for added water, which is illegal, and would render the milk adulterated. In addition, the milk’s temperature is checked to ensure it’s been stored properly and inspected for any adverse physical signs, such as off color or odor.

Once the milk arrives at a processing plant, the PMO requires every milk truck to be tested for beta lactams  before it enters – (If this is starting to seem obsessive, note that it brings results: In 2024, only 1 out of every 17,083 tankers, less than six thousandths of one percent, tested positive for a drug residue, the lowest ever.)

Once all those hurdles have been surmounted, milk enters the plant and receives the gold standard treatment: Pasteurization. For more than 100 years, pasteurization has been keeping consumers safe from threats that ranged from tuberculosis (second only to cancer as a cause of death in 1925) to bird flu, which pasteurization renders harmless in milk, according to repeated tests taken last year when the virus was identified in dairy cattle.

Here’s how pasteurization works. Under HTST (High-Temperature Short-Time) pasteurization, milk is heated to a specific temperature, typically at least161°F (71.5°C), though many plants go even higher. The heated milk is held at the specific temperature for a set time — typically no less than15 seconds for HTST. This allows the heat to effectively kill harmful bacteria.

Alternative methods, like vat pasteurization, use lower temperatures (145°F or 63°C), but for longer periods (30 minutes). In general, the higher the temperature, the longer the milk’s shelf life. Ultra-pasteurized milk, for example, is heated to temperatures around 280°F (140°C) for a short time, resulting in longer shelf life. And Ultra-High Temperature, which is processed and packaged in a commercially sterile environment, may go even higher (e.g., 285°F or 140°C), resulting in shelf-stable milk.

In every case, the combination of temperature and time allows the heat to effectively kill harmful viruses and bacteria. And keep milk safe.

After pasteurization, the milk is then rapidly cooled down, usually to around 40°F. This prevents further bacterial growth and maintains the milk’s quality.

Pasteurized milk also undergoes its own tests — pasteurized milk goes through a phosphatase test to confirm efficacy. What’s a phosphatase test, you ask? The phosphatase test, specifically the alkaline phosphatase (ALP) test, is used to determine if milk has been properly pasteurized. ALP is an enzyme naturally present in raw milk but is inactivated by heat during pasteurization. ALP activity in milk indicates insufficient pasteurization or contamination with raw milk after pasteurization.

From there, the milk is packaged and sent to the store.

If all this seems overly detailed, technical and mind-numbingly repetitive, well, that’s the point. Milk is a product of proven safeguards and processes, backed by state and federal regulations and an industry that doesn’t want to be associated with food scares and illness outbreaks. Do outbreaks still occur? Unfortunately, yes. Nothing in life is 100 percent foolproof, and fools, and mishaps, will always exist. But given the billions of pounds of milk produced each year, such outbreaks are exceedingly rare. And when they do happen, regulators and the dairy industry learn and do better.

Dairy is defined by many things. Quality, nutrition, nourishment across the globe. But safety is fundamental to all of these. That’s been true in the past. It’s true today. And it will be tomorrow, thanks to the farmers, testers and workers from farm to fork, working to make it so.

Century of PMO and interagency collaboration

By Miquela Hanselman, Director, Regulatory Affairs

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 (FDA), 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 to 16 in Minneapolis, Minn., to deliberate many important issues facing the FDA’s National Grade A Milk Program and the PMO. Delegates representing 49 states and Puerto Rico attended, along with representatives from the FDA and industry organizations. Attendees reviewed and discussed 81 different proposals for changes to the PMO, eight of which were submitted by National Milk Producers Federation (NMPF) on behalf of its members.

The conference provides a unique forum for the industry and its regulators to come together. Sometimes the most valuable advances at the conference do not come from the proposals that pass but from issues that are raised for conference-wide attention.

One issue NMPF brought forward at the conference was the confusion caused by the “Dear Veterinarian Letter” the FDA published October 11 regarding the use of aspirin products in lactating dairy cattle. In the letter, the FDA stated that veterinarians and dairy farmers should stop the use of unapproved aspirin in lactating dairy cattle and use FDA-approved products to control pyrexia and pain. This letter has perplexed the industry for the past six months, so NMPF used the conference as an opportunity to gain clarity from the FDA on its position and ensure that federal regulators are on the same page as the states and industry. Though the proposal that NMPF submitted didn’t pass, NMPF is pleased that the issue was thoroughly discussed and that NCIMS voted in favor of creating a study committee to engage the 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.

NMPF also had favorable outcomes for other proposals it submitted, including a proposal clarifying language around animal treatment record requirements and a proposal updating the rules for cleaning on-farm bulk tanks to be consistent with the rules for bulk milk hauling trucks and trailers.

Leaders from NMPF and its member cooperatives are very involved in NCIMS, and many serve on the NCIMS executive board or on committees between conferences. Brad Suhling of Prairie Farms was elected to the open industry from the central region for the NCIMS board. Suhling previously served on the Single Service Committee, and that vacancy will be filled by Charlie Mack (Prairie Farms). Amanda Rife (Land O’ Lakes) was elected the open industry from the eastern region for the NCIMS board and will serve as chair for Council I, Dave Kedzierski (United Dairymen of Arizona) will serve as the chair for Council II, Damon Miller (Dairy Farmers of America) will continue his term as the chair for Council III, and Clay Detlefsen will continue to serve in the NMPF staff representative seat. Finally, by unanimous vote, Antone Mickelson (Darigold/Northwest Dairy Association) will continue as vice chair of NCIMS executive board.

This year, attendees at NCIMS also celebrated the centennial of the PMO in 2024. The FDA ran a campaign throughout the past year to showcase what 100 years of the Pasteurized Milk Ordinance has done for milk safety in the United States. 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.

Protecting milk quality and safety is crucial for public health. The PMO has done that effectively for 100 years, and with continued collaboration through NCIMS, it will continue for many more.


This column originally appeared in Hoard’s Dairyman Intel on May 1, 2025.

NMPF Represents Members at Successful NCIMS Conference

The National Conference on Interstate Milk Shipments (NCIMS) addressed 72 proposals submitted to revise the Pasteurized Milk Ordinance (PMO) and its related documents at a meeting in Indianapolis from April 3-7.

NMPF staff advocated positions of interest for dairy cooperatives and their producer members. Many NMPF members also attended and played key roles in the deliberations of the conference. The 2023 conference featured more than 400 attendees — a record — after taking a four-year hiatus due to the COVID-19 pandemic. NMPF was pleased with many of the outcomes of the proposals and made significant progress in achieving reasonable solutions on many key issues.

The conference once again highlighted the successful collaboration between the U.S. Public Health Service/Food and Drug Administration, state regulators and dairy industry representatives to continue to promote and protect a safe supply of Grade A milk and milk products.  A total of 40 proposals were passed by the delegates either as submitted or as amended. Below are the outcomes of the NMPF-submitted proposals.

  • Proposal 207 was submitted to require a 48-hour notice prior to on-farm inspection. Reasons for this include the risks to human health following the COVID-19 pandemic, the farm’s biosecurity and overall personnel safety. The proposal was amended at the conference and passed through the delegates to be assigned to a standing or ad-hoc committee to review sections 8, 13, and 14 of the PMO. This is an important first step in recognizing the importance of biosecurity measures on dairy farms and will hopefully lead to further discussion of inspection notices.
  • Proposal 301 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 passed through the delegates as amended to include a plain language definition in line with that of the World Trade Organization. Defining equivalence provides clarity for industry, state and Federal stakeholders about foreign countries’ obligations to participate in the PMO. This proposal reinforces the importance of transparency when analyzing equivalence for foreign countries.
  • Proposal 302 was voted no action as 301 was decided to be the proper pathway for equivalence.

Also to note, Antone Mickelson, NMPF’s NCIMS committee chair, was re-elected to fill the western states industry seat on the NCIMS Executive committee and NCIMS Vice Chair. The next conference will be held in 2025 in Minneapolis.