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4. What unique information must a milk supplier provide on each Certificate of Conformance (COC)?
The milk supplier shall have records of individual farms available to link and confirm that raw milk meeting the EU requirements for SCC and SPC is received at the facility manufacturing dairy products for shipment to the EU.
5. What are the responsibilities of the milk supplier when the farm’s rolling mean exceeds the maximum EU requirement?
A milk supplier must notify AMS if a farm’s rolling mean exceeds the EU requirement and the milk is used for products that are certified for export to the EU. If the farm comes back into compliance no further notification is needed. If the farm exceeds the requirement for three consecutive months after notification then the plant must ask for derogation or exclude the milk from entering products shipped to the EU.
6. Provide an example of the timeline before a farm would be considered out of compliance. This would be the time when the milk supplier must make decisions about the use of milk from that farm. See Table Below:
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Determining Compliance Eligibility for European Union Export Certification
Effective January 1, 2012
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Month
| Monthly data for rolling three-month mean for SCC
| If result of rolling three-month mean for SCC
| Actions
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April 2012
| Jan, Feb, Mar
| > 400,000
| Milk ok for export in April. Notify AMS.
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May
| Feb, Mar, Apr
| > 400,000
| Milk ok for export in May. (1st month)
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June
| Mar, Apr, May
| > 400,000
| Milk ok for export in June. (2nd month)
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July
| Apr, May, Jun
| > 400,000
| Milk ok for export in July. (3rd month)
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August
| May, Jun, Jul
| > 400,000
| Milk NOT ok for export in August. Milk supplier must suspend, segregate, discontinue certification or request derogation from AMS to be eligible.
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AMS requires the milk supplier to request a derogation or exclude the milk from EU certification when they receive the July numbers in early August. AMS will accept derogations and apply them retroactively if the plant makes the request in a reasonable time frame.
7. Will the COC for farm milk collected in a given month be used to determine compliance in following month?
Yes, a COC covering raw milk delivered in April would be based on March’s compliant three-month rolling mean. This avoids a milk supplier having to trace product that may have moved significantly through the supply chain before the monthly sample is analyzed and reported.
8. What unique information must a milk processor or applicant provide on each Certificate of Conformance (COC)?
The processor shall have records for dairy ingredients or composite food that require an EU Health Certificate. There must be enough information to trace back at least one step toward the raw milk production for milk or dairy products covered by the COC for verification during the AMS Dairy Programs review of records. This can include production lot identification codes, production dates, bills of lading or any other documentation that provides this information. It will not detail individual farms.
9. Is it possible for a farm to be out of compliance for either the SPC or the SCC requirements or for both requirements?
Yes, derogations are specific to the parameter(s) (SCC or SPC) that is out of compliance. A farm could conceivably have two derogations at once. The requirements are mutually exclusive.
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