Plant Records To Include Grade Label Butterfat Testing
Published Date: 1/16/2025
Rule
Summary
Starting February 18, 2025, dairy plants in the USDA’s voluntary grading program must keep records of butterfat tests done either in-house or by approved labs. These records have to be ready for USDA inspectors to check, making the process smoother and matching how the industry already works. This change helps plants stay efficient without adding extra costs.
Analyzed Economic Effects
3 provisions identified: 1 benefits, 2 costs, 0 mixed.
Use in-house/third-party tests; records review saves plants
Beginning February 18, 2025, plants in the voluntary AMS Dairy Grading program may use in-plant or approved third-party butterfat tests and have AMS perform an annual records review as an alternative to a USDA inspector doing duplicate butterfat testing. AMS estimates this alternative yields annual net savings to participating plants of $4,560 to $31,560; AMS estimates the records review cost charged to a plant is about $440 per year (4 hours at $110/hour).
Noncompliance can remove USDA butter grade shield
If an AMS records review shows a plant's butterfat results do not meet the 80 percent butterfat requirement, AMS will review more frequently and require corrective actions; if a plant fails to take corrective action over three consecutive reviews, or releases product not meeting the 80 percent requirement on three occasions, USDA may notify the plant to discontinue use of the USDA Grade Label (butter shield).
Keep butterfat test records 12 months
If you operate a butter plant participating in the USDA Grade Label program, you must retain butterfat test records on-site for 12 months starting February 18, 2025. AMS estimates recordkeeping burden averages 2.5 hours per recordkeeper per year (17 recordkeepers total = 42.5 hours). Records will be available for on-site review by USDA inspectors and do not need to be submitted to the agency.
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