The National Milk Producers Federation (NMPF) has submitted comments to the U.S. Food and Drug Administration asking that dairy farms be exempted from the intentional adulteration rule of the Food Safety Modernization Act (FSMA). The rule was the sixth proposed FSMA rule and will require domestic and foreign food facilities to address hazards that may be intentionally introduced by acts of terrorism. “In considering whether activities that occur on dairy farms represent a high risk for intentional adulteration, FDA concluded fluid milk storage and loading in a dairy farm operation pose a significant vulnerability,” wrote Beth Briczinski, NMPF’s vice president of Dairy Foods and Nutrition, in the organization’s comments submitted Monday. “However, for a number of reasons, we disagree with the premise that on‐farm milk destined for pasteurization is a high‐risk food and, therefore, we maintain that activities on dairy farms should not be addressed through this rule.” The group argues that because raw milk destined for pasteurization moves through various regions of the country and processing demands, it would be a poor choice for intentional adulteration. Because dairy products are used as ingredients in other food, they can go through multiple heating steps and be distributed across a large array of other products, and NMPF believes this decreases the impact for potential adulteration. NMPF also stated that dairy farms are already employing many elements of food defense for biosecurity measures that help prevent the introduction of infectious and contagious diseases among cattle, and, in turn, help prevent the spread of harmful problems in the milk from those cows. “We would encourage FDA to adopt an approach whereby dairy farms would have a food defense plan (a suite of risk-based CGMPs) that is implemented only when a credible threat of intentional adulteration against the milk supply is identified,” Briczinski wrote. Raw milk that is produced for direct human consumption and not destined for pasteurization should not be exempted, NMPF noted. “Because they will not be pasteurized prior to human consumption, raw milk and raw milk products have an expanded list of potential contaminants, including those that are heat-sensitive,” Briczinski wrote. NMPF also jointly submitted comments with the International Dairy Foods Association (IDFA) regarding intentional adulteration in dairy processing plants. These comments expressed concerns with the proposed rule and asked FDA to “fundamentally reconsider its proposed approach.” The groups argue that food defense and food safety should be regulated differently, that the rule should encourage thoughtful analysis of threats, and that FDA shouldn’t distinguish between broad and focused mitigation strategies. NMPF and IDFA want the agency to require only basic food defense plans that will allow plants to “identify reserved focused mitigation strategies that can be utilized in periods of heightened concern should they materialize in the future.” The groups have also asked for FDA to offer a re-proposal version of the intentional adulteration rule. The deadline for issuing the final rule is May 31, 2016.