200 C Street, S.W.
Washington, D.C. 20204
April 2, 1990
TO: All Regional Food and Drug Directors
Attn: Regional Milk Specialists
FROM: Milk Safety Branch (HFF-346)
SUBJECT: Sampling for Animal Drug Residues and Other Contaminants in Milk,
Interpretation of Section 6 of the PMO
This memorandum is being issued at the request and in cooperation with the Executive Board of NCIMS.
In accordance with the recently established guidelines for issuance of interpretations this interpretation is being issued and distributed to all state milk regulatory and rating officials. Any comment that the states have should be sent to the Executive Secretary of NCIMS within 30 days of the date of this letter. If no comments are received this memorandum shall be effective 60 days from the date of this letter. (June 2, 1990)
Section 6 of the Pasteurized Milk Ordinance states in Part:
"Examinations and tests to detect adulterants, including pesticides, shall be conducted as the regulatory agency requires".
The interpretation of this portion of Section 6, requires that regulatory agencies adopt the following policy in regard to determining when additional sampling is necessary:
When the Commissioner of the Food and Drug Administration (FDA) determines that a potential problem exists with animal drug residues or other contaminants in the milk supply, samples shall be analyzed for the contaminant by a method(s) determined by FDA to be effective in determining compliance with actionable levels or established tolerances. This testing will continue until such time that the Commissioner of the Food and Drug Administration is reasonably assured that the problem has been corrected.
The determination of a problem is to be based upon:
Sample survey results, USDA tissue residue data from cull and veal dairy animals, Animal drug disappearances and sales data, State feed back and Other relevant information
Copies of this memorandum are enclosed for your distribution to District Milk Specialists, state milk regulatory agencies and state milk rating officers in your region.
Johnnie G. Nichols
Chief, Milk Safety Branch