By Nick Tindall, AEM Senior Director of Regulatory Affairs and Ag Policy

Regulatory AdvocacyAt the 2016 Spring AEM Board meetings, we pledged to step up for our milking machine manufacturing members after learning no one in our nation’s capital was addressing a core issue affecting their sector. Namely, the Food and Drug Administration (FDA) didn’t have the right regulations in place to govern modern realities of robotic milking, i.e. Automated Milking Installations (AMI).   

The limited number of companies involved meant national attention was unlikely. If AEM couldn’t fill this void, than who could?

Our response was simple and swift: We could help. 

And we did.

AEM’s Ag Services, Tech and Safety and Advocacy departments came together and executed a multi-pronged strategy. This included establishment of the Dairy Equipment Leadership Group and Dairy Equipment Engineering Committee to provide necessary member buy-in and guidance while we interacted with the FDA for the first time.

Word got out about AEM’s commitment to help AMI manufacturers, attracting two long-term membership targets to join the joint industry campaign.

Make no mistake about it, there was a learning curve. Our first crack at making changes to the Pasteurized Milk Ordinance (PMO), which provides the regulatory framework for milking equipment, at the biennial April 2017 National Conference on Interstate Milk Shipments (NCIMS), was unsuccessful. However, we learned from the experience and applied that knowledge moving forward.

Member company engagement was ultimately the key factor in our first breakthrough.

In August of 2017, under the AEM umbrella, executives and technical experts from the leading AMI manufacturers traveled to Washington, D.C. for a series of meetings with the U.S. Food and Drug Administration, U.D. Department of Agriculture and the National Milk Producers Federation. These visits were directly responsible for two critical developments:

1.  That October FDA released regulatory guidance to milk inspectors that gave dairy farmers using AMIs relief while we worked together to update the PMO.

2. An AMI subcommittee within the NCIMS was established to bring together manufacturers, FDA, food processors and state regulators to develop consensus amendments to the PMO.

The fruits of this labor were seen in April when the 2019 NCIMS adopted, with FDA’s enthusiastic support, changes to the PMO that will properly oversee AMIs for the first time.  

AEM’s work in this area isn’t finished, but tangible benefits have been achieved for our member companies.

Furthermore, the exercise serves as an excellent example of what AEM can do for its members.

Many issues in Washington, D.C. involve large coalitions. However, AEM can provide additional value to its members by taking the lead in areas ripe for us to leverage our unique expertise.  

We just need you to bring them to our attention.

After all, if AEM can’t do it…who will?

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