The revisions are open to public comment until March 31. Producers and industry stakeholders are encouraged to review the proposal at nationaldairyfarm.com and reach out to the FARM team with questions or concerns. Emily Yeiser Stepp, senior director of the program, provides a preview.
Emily Yeiser Stepp
National Dairy FARM (Farmers Assuring Responsible Management)
What are some of the major changes coming in FARM 4.0?
Yeiser Stepp: The majority of the changes are on the administrative side and primarily focus on improving consistency between how co-ops and processors implement the program. Some enhancements to our training are not only for our evaluators but also for those folks prepared as trainers.
While we believe the animal care standards in Version 3.0 are clear, some of the questions involved in evaluating a dairy were a little convoluted. We’re proposing splitting some of those multiple-part questions that seek information on written protocols and actual practices. By separating the two, we’ll get a truer picture of the industry and identify where opportunities for improvement lie.
Currently, FARM has only three minimum requirements under the animal care standard: completion of a signed veterinarian-client-patient relationship (VCPR) form, basic dairy cattle care ethics training and documentation for all employees with animal care responsibilities, and a ban on tail docking.
Under the proposed Version 4.0, evaluation of non-ambulatory animal and euthanasia protocols and practices will become part of animal care requirements. Failure to meet those requirements will trigger mandatory corrective actions. Both our technical writing group and our animal health and well-being committee feel those issues are our highest risk and liability areas.
In Version 4.0, it is also proposed that failure to follow the ban on tail docking at the time of an evaluation will trigger an immediate decertification from the FARM program.
Additionally, under Version 3, folks had up to one year to resolve issues identified for mandatory corrective action plans. Under Version 4.0, it’s proposed that time frame be shortened to nine months. It has been our experience all mandatory corrective action plans were being resolved in six months or less. Shortening the maximum time frame simply conveys the importance that those standards are in place and are being met.
Nothing will change from the aspect of minimum requirements for employee training. What is proposed is the introduction of “continuing education” for family labor as part of the continuous improvement plan. Whether it’s going to an extension meeting or sitting down with their veterinarian to go through their protocol book, there are a variety of things that would be recognized as continuing education under FARM.
We certainly see the advantages for training employees and want to make sure we’re helping dairies with family labor feel like they are professionals in their line of work. I’m hoping it will be seen as a positive way to share the industry’s dedication to continuing education for all involved on the farm.
Are there any additional changes in FARM 4.0 that might cause concern for producers?
Yeiser Stepp: I anticipate the continuing education for family labor will likely get some feedback. Collectively, we’re acknowledging our whole industry is becoming more professional. If there are managers and family employees taking those steps to further their professional development, we want to capture that and share the positive stories throughout the supply chain.
It’s also been proposed if disbudding of calves is done after 8 weeks old, it will also trigger a corrective action plan. Associated with that, the use of pain management during disbudding will still be at the farm veterinarian’s discretion, but we are going to ask whether or not pain management is being used during disbudding and require the disbudding protocols are specifically spelled out and signed off on by the farm’s veterinarian. Pain management continues to be an area of concern from a customer standpoint, and the body of science recommending pain mitigation is extensive.
Pain mitigation associated with disbudding has been a major discussion of our technical writers and committees, recognizing we still don’t have any products labeled for pain management in the U.S., and extra-label drug use must be prescribed by the veterinarian. We’re asking folks to document what they are doing within that protocol and further demonstrate a veterinarian relationship within the herd health plan for those decisions.
What are some evaluation points or questions to see in 4.0?
Yeiser Stepp: New evaluation points or questions are being proposed as part of our global International Organization for Standardization (ISO) dairy welfare certification. The ISO certification process called some of our standards into question. We addressed them, but we didn’t have them specifically laid out in our evaluation itself. For example, one of those concerns is general lighting for animal and human safety.
As we put things out for public comment period, we are also going to provide the rationale for why the standard is in existence and, if it’s a new standard, why we’ve incorporated it.
An additional area relates to daily exercise, weather permitting, for animals. FARM continues to maintain facility neutrality, but we did have a tiestall task force in place to do a full analysis, literature review and evaluation of best management practices to determine whether there were any concerns from an animal welfare standpoint related to tiestall facilities. The task force overwhelmingly came away from the discussion saying a well-managed facility is a well-managed facility.
I think there’s still that question from our customer base regarding an animal’s freedom of movement. There’s no proposed improvement plan associated with this re-introduced standard, which was evaluated in Version 1.0 of the program. However, by gathering information, we will be able to assure the supply chain allowing animals daily exercise is a common practice, regardless of facility.
From an animal observation standpoint, we are re-proposing quantifying the number of animals with broken tails, primarily to encourage farms to evaluate their animal management practices through the lens of stockmanship.
Who/what are the main driving forces behind these changes?
Yeiser Stepp: Largely, those changes are coming about per requests from our co-ops and processors implementing the program. They’re seeking clarity around how to interpret, evaluate and verify on-farm practices to meet specific standards.
By having this robust evaluation, we are able to answer customers’ questions about what we’re doing in a more proactive and accurate way. That doesn’t mean they won’t scrutinize what we’re doing or ask further questions, but at least we have a true representation of on-farm practices.
On the flip side, if there are opportunities for improvement, the FARM program can help guide where research efforts need to be focused.
Long-term, we as a FARM team hope this evaluation – and this is probably a little bit with rose-colored glasses – provides value back to the farm, potentially as a risk assessment evaluation or to prioritize where we can achieve the biggest bang for their buck in tough economic times. I think there is true opportunity to make it something a dairy farmer would want to go through to identify the good and the potential bad as a value add to their operation.
In 2017, we did a producer survey in conjunction with a Colorado State study. Results overwhelmingly documented farmers wanted more input in the program. Out of that, we developed a 20-member farm advisory council. Meeting for the first time in January, they represented a vast diversity of age, geographic location, type of farm and where they marketed milk. The chair and vice chair of that council will not only sit on the technical writing group, but they will also be strategically involved in the other committees in the FARM program. We hope they not only provide feedback and real-world input but will also serve as resource people and peer-to-peer ambassadors for the program.
What are three things every producer should know about FARM 4.0?
Yeiser Stepp: One, there will be more consistency in how the evaluation is being executed.
Additionally, the evaluation has more questions, in an attempt to also capture good on-farm practices in addition to verifying you have the documentation and protocols for backup. Hopefully that will allow us to not only more accurately share the good dairy story but also give credit where credit is due.
Finally, there are different accountability measures, giving separate classifications for mandatory corrective action areas versus continuous improvement action areas. Use these top-priority areas identified by the technical writing group and animal health committee to help you prioritize on-farm management actions.
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