Today, the USDA announced a National Milk Testing Strategy for HPAI in dairy cattle, including a federal order calling for mandatory testing of silos at milk plants and, as necessary, of farm milk samples. This supplements the existing order requiring testing for interstate movements of dairy cattle, voluntary testing programs and dairy loss indemnity payments implemented at the urging of AFBF.

What does this announcement mean for farmers?

USDA’s Animal & Plant Health Inspection Service (APHIS) five-stage National Milk Testing Strategy for eradicating HPAI in dairy cattle and the federal order at the heart of the strategy will require sharing of raw milk samples from milk plants, haulers, transfer stations and farm bulk tanks, as needed, but starting with milk plant silos. This authority will supplement state authorities and will allow states to implement appropriate state-specific testing programs in cooperation with USDA.

This strategy also encompasses existing efforts, including voluntary testing programs, the requirement that all private and public labs report positive tests to USDA, funding and other support for voluntary animal health interventions on farm, and the addition of milk loss payments to the Emergency Assistance for Livestock, Honeybees, and Farm-raised Fish Program (ELAP).

What is the background on this issue?

Highly Pathogenic Avian Influenza (HPAI) variant H5N1, which has severely impacted U.S. poultry and egg production in recent years, has impacted dairy cows and dairy farmers in 2024, apparently through limited crossover infections followed by undetected spread among dairy herds. It went undetected for some time due to its significant, but limited impact on dairy cow health and productivity, and the dairy industry is working with states and the federal government towards its eradication from the dairy herd.

Through December 6, 2024, USDA has reported confirmed cases of HPAI in 720 dairy herds in 15 states. USDA’s Animal & Plant Health Inspection Service (APHIS) updates these numbers weekly. (See link below.)

USDA announced its five-stage National Milk Testing Strategy for eradicating HPAI in dairy cattle. The federal order at the heart of the strategy will require sharing of raw milk samples from milk plants, haulers, transfer stations and farm bulk tanks, but starting with milk plant silos. This authority will supplement state authorities and will allow states to implement appropriate state-specific testing programs in cooperation with USDA.

States will have substantial flexibility in deciding how to act on positive tests from milk plant silo samples, including decisions about how to obtain bulk tank samples and how to engage with affected producers. Existing milk sampling procedures allow for broad access to plant, load and farm raw milk samples through the plants; this will allow authorities to move from positive silo tests to identification of affected herds relatively quickly. USDA intends to maintain confidentiality with respect to affected herds.

Note that substantial financial and technical support is available to farmers, both for their testing and animal health efforts and for their milk losses. This should support efforts to encourage state regulators to adopt a carrot-before-stick approach to affected herds.

The new USDA strategy encompasses existing efforts, including voluntary testing programs, the requirement that all private and public labs report positive tests to USDA, funding and other support for voluntary animal health interventions on farm, and the addition of milk loss payments to the Emergency Assistance for Livestock, Honey Bees and Farm-raised Fish Program (ELAP). The ELAP payments, which are critical to both supporting affected dairy farmers and to encouraging their engagement in animal health programs, was proposed by AFBF President Zippy Duvall to U.S. Secretary of Agriculture Tom Vilsack in their first conversation about the issue of HPAI in dairy cattle.

The five planned stages of testing and eradication of H5N1 at the state and national level are:

1. Standing Up Mandatory USDA National Plant Silo Monitoring – USDA will immediately begin nationwide testing of milk silos at dairy processing facilities. This national sample will allow USDA to identify where the disease is present, monitor trends and help states identify potentially affected herds.
2. Determining a State’s H5N1 Dairy Cattle Status – Building on the results of silo monitoring, in collaboration with states, USDA will also boost bulk tank sampling programs that will enable us to identify herds in the state that are affected with H5N1.
3. Detecting and Responding to the Virus in Affected States – For states with H5N1 detections, APHIS will work quickly to identify specific cases and implement rapid response measures, including enhanced biosecurity using USDA’s existing incentives programs, movement controls and contact tracing.
4. Demonstrating Ongoing Absence of H5 in Dairy Cattle in Unaffected States – Once all dairy herds in a given state are considered to be unaffected, APHIS will continue regular sampling of farms’ bulk tanks to ensure the disease does not re-emerge. Bulk tank sampling frequency will progressively decline as the state demonstrates continual silo negativity (e.g., weekly, monthly, quarterly if continually negative). If a state becomes affected, USDA will re-engage detection and response activities, and the state will return to Stage 3.
5. Demonstrating Freedom from H5 in U.S. Dairy Cattle – After all states move through Stage Four, APHIS will work with the states to begin periodic sampling and testing to illustrate long-term absence from the national herd.

The program will begin in six states that have already engaged substantially with USDA in voluntary efforts and in the development of this strategy. These are California, Colorado, Michigan, Mississippi, Oregon and Pennsylvania.

Things to keep in mind regarding the safety of the American food supply:

• The Food and Drug Administration (FDA) has confirmed that the country’s milk supply remains safe. Milk pasteurization inactivates pathogens, including avian influenza, and has served public health well for more than 100 years.
• In addition, as a matter of course, sick cows are removed from the milking line. Farmers follow, and are encouraged to follow, strict biosecurity protocols on the farm to protect the health of poultry and livestock.
• In cattle, the virus can cause decreased lactation, low appetite, and other symptoms, but affected cattle have recovered from the virus except when other viruses or health issues are impacting the cattle.