| Action | Amendment to lower permissible somatic cell and bacteria counts |
| Stage | Proposed |
| Comment Period | Ended on 12/30/2018 |
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8 comments
VIRGINIA STATE DAIRYMEN’S ASSOCIATION
P.O. BOX 29, BRIDGEWATER, VA 22812
PHONE: 540-828-6960 FAX: 540-828-6962
EMAIL: eric@vsdaonline.com
October 1st, 2018
Ryan Davis
PO Box 1163
Richmond, VA 23218
Re: Petition to amend certain requirements in 2 VAC 5-490 regarding somatic cell count and bacteria count
Dear Mr. Davis,
The Virginia State Dairymen’s Association appreciates this opportunity to comment on the petition to amend Section 50 of 2 VAC 5-490 regarding the somatic cell and bacteria count limits in milk. The VSDA Board of Directors is in support of changing the current limits for SCC and standard plate counts to 500,000 scc/ml and 50,000 spc/ml respectively.
The benefits of higher quality milk are numerous. Higher quality milk has a longer shelf life and can be shipped further. Lower SCC scores are tied with increased cheese yields. It also has an impact on our export market with the current EU limit of 400,000 scc/ml already in place for US exports. We have already seen the pressure that the international community has been putting on our products and this change would continue the process of increasing dairy exports. There is also the possibility that this helps Virginia expand and recruit new processors to locate within our borders. Virginia would join several other states in implementing higher quality standards and would be first state east of the Mississippi River. This would make Virginia the industry leader on the East Coast. We urge the Board to approve the proposed amendments to the regulations.
The Virginia State Dairymen’s Association is a member organization that represents dairy farmers from around the Commonwealth. We have been actively involved in furthering opportunities for dairymen since our inception in 1907.
Sincerely,
Eric Paulson
Executive Secretary
Virginia State Dairymen’s Association
As a small VDACS licensed goat dairy for the past eleven years, Dairy Services just put us out of business. There is no way we can meet those stringent standards, especially within the next 3 months. Dairy inspector, David Dansey, notified of closing 12/31/18. So much for small dairy artisanal cheese.
Cynthia Wilson
Lovers Retreat Dairy
Oct 31 2018
To
Ryan Davis and all concerned
Hello from Rockingham County where the cows and the poultry make it a leading county of the State of Virginia.I am concerned that the dairy industry in this state is at risk of being a memory! To realize that our very own Virginia State Dairymen's Assoc. will request lowering the standards of SCC and bacteria count to the levels proposed is downright outragous and basicly impossible to meet year round. I feel all the emphasis is on the marketing end and none on the producing end. Who cares if Virginia has that chance to lead this movement east of the Mississippi? Virginia is a leading State now. So Whoopty Doo!
You can not push a log chain but you can pull it. But how far can you pull it.
We dairy farmers are being pulled like that chain by these monsters National Milk and State dairy Assoc & etc. just whoever pulls for these kind of changes. But it"s about time you switch directions of your chain, "Lets see you push it awhile. Pushing a chain is no harder than producing milk with a tighting noose around the neck with new regulations to meet and less and less pay to do the new regulations.
It's time to say NO to this Proposed Petition for rulemaking.
Seriously
Bernard Koogler
Spring-Run Holsteins
Dayton, Va 22821
Daniel Deal
Virginia Tech M.P.A.
Ryan Davis
Program Manager, Office of Dairy and Foods
PO Box 1163
Richmond, VA 23218
Dear Mr. Davis,
Thank you for the opportunity to comment on the proposed regulatory amendment regarding the somatic cell and bacteria count limits in milk. I am writing to oppose this amendment because of the financial impacts it will have on the diminishing number of dairy farms throughout the Commonwealth.
Since 2014, the number of Virginia dairy farms has decreased by nearly 20 percent. Often, reduced milk prices have forced farmers to sell milk for less than their costs of production. The projected median income for a dairy farmer this year is -$1,316. Amending 2 VAC 5-490 will only add to the financial costs of milking process.
The VSDA argues in favor of this amendment claiming the marketability of Virginia milk will increase resulting in more overseas exports, expansion of local processers, and a prideful notion to declare Virginia as the highest standard east of the Mississippi. However, these claims are unsubstantial because each of them are merely speculative and indeterminate. It is clear that the most important of these goals is to tout this “pride statement”, which is absurd considering it will come at the expense of Virginia farmers.
Lowering the bacteria counts and somatic cell accounts to the proposed levels will not require processors to pay a significantly higher price when they purchase it from the farm because the vast majority of consumers choose the cheapest option on the self. With the current status of dairy farming nationwide, regulations that put more pressure on farmers with minimal return on investment need to be avoided.
Regards,
Daniel Deal
I am located in Southwest Virginia and have seen in recent years many of our local small to medium sized dairy farms go under due to large coorporations pricing them out of their market. Large farms/coorporations which have a larger market and therefore increased resources at their disposal will likely be able to adapt to the proposed changes. Small and medium dairy farms will not be able to withstand increased cost due to new regulations as well as fight to keep their milk prices affordable to in the market. They are essentially in the middle of a fight they cannot win. I will be important to not pass these new regulations and help preserve the small and medium sized dairy farms.
Thank you for your consideration,
Parker Mabe
As a consumer, I’d like to understand the exact problem this resolution is trying to solve. I know of no known relationship between pasteurized milk with SCC 750,000 cells/ml and human health issues. The proposed reduction provides a safer product to what extent? If there is a real health concern, this would make sense. It would be a greater benefit to human health combating disease, infection, etc. However, I see no correlation. Are there improved health benefits to lower SCC counts, there is. But, there are also improved health benefits to drinking less, eating less, and exercising more. There doesn’t necessarily need to be a required regulation for consumers to take advantage of those benefits. Also, I understand the rationale behind expanding markets for products produced in Virginia. Again, availability of new markets to what extent? If there is research suggesting this will lead to new markets, I would be more inclined to agree. However this seems to be an unknown.
Approving this amendment would have unintended consequences on small to medium sized dairy farms. I realize smaller farms are a low percentage, but approving this amendment would take away further liberties of those struggling due to regulations and larger production farming being able to afford adjusting.
As the owners/operators of a small grade-A dairy farm in Va, we oppose this amendment. At this time, many or most dairy farms, large & small, are having trouble staying in business due to the lower prices paid for raw milk. Additional regulations will only add to the stress and problems for these farms.
Current regulations have served Va dairymen and consumers well in the past. We ask that the Board of Agriculture & Consumer Services do NOT try to fix something that is not broke. Thank you.