FARM program Version 2028 open for comments by Oct. 2, webinar slated Aug. 7

ARLINGTON, Va. — The National Dairy Farmers Assuring Responsible Management (FARM) Program is asking dairy producers and other industry stakeholders to weigh in on proposed changes to the Animal Care and Workforce Development programs before Version 2028 standards are finalized.

The public comment period opened July 8 and continues through Oct. 2, with a live informational webinar scheduled for Friday, Aug. 7, at 1 p.m. ET to review the proposed revisions and explain how comments will be considered.

The proposed Animal Care revisions include updates to fitness-to-transport guidelines, the evaluation process for injured tails, calf nutrition, animal observations, documentation requirements and continuing education standards.

Proposed Workforce Development changes include wording revisions intended to improve clarity and farm-level relevance, restructuring some evaluation questions to be less prescriptive, providing greater flexibility in areas such as safety self-inspection timing, and exploring additional workforce topics.

After the comment period closes, farmer-led task forces and advisory councils will review the feedback before forwarding recommendations to the National Milk Producers Federation Board of Directors. If approved, Version 2028 would become effective Jan. 1, 2028.

The online survey walks participants through each proposed change. New or revised language is identified, along with the rationale behind the recommendation.

Respondents indicate whether they support the proposal as written, support it with suggested changes, or do not support it. Those selecting either of the latter two options are invited to explain their reasoning before moving to the next proposal.

The survey also includes opportunities at the end to provide additional feedback as well as final comments to FARM staff.

Some revisions under Animal Care are substantive and others remove informational questions that are not required standards while adding or modifying others in an effort to streamline evaluations. A separate section covers Workforce Development proposals. One notable clarification specifies that payroll records must be accessible and auditable by the appropriate governing authority but are not subject to review by the FARM evaluator.

Webinar to explain proposed changes

The Aug. 7 webinar will review the FARM governance structure, the Version 2028 development timeline, proposed Animal Care and Workforce Development revisions, and the public comment process.

Presenters include Dr. Steven Roche, founder and CEO of ACER Consulting, and Nicole Ayache, who oversees the FARM Program’s Environmental Stewardship and Workforce Development pillars for the National Milk Producers Federation.

Previous survey: support and frustration

The current review follows a national stakeholder survey conducted in 2025 to help launch development of FARM Version 2028. More than 800 responses were received, with 557 meeting the criteria for inclusion in the final analysis, representing producers, veterinarians, cooperatives, processors and other dairy stakeholders from across the country.

According to the ACER Consulting report from that survey, respondents generally agreed the FARM Program supports consumer confidence, market access, industry self-regulation, and continuous improvement.

At the same time, more than 400 written comments cited growing paperwork, administrative burden and added costs without corresponding economic return.

Others questioned whether FARM effectively builds consumer trust or has become driven more by external expectations than producer realities.

Participants called for greater emphasis on animal-based outcomes rather than prescriptive documentation, along with more producer input, greater transparency, fewer redundant requirements, and more stability between program revisions.

Administrative requirements generated some of the strongest criticism.

Respondents questioned Cow Care Agreements, continuing education records, veterinary-client-patient relationship documentation, treatment records, and herd health plan sign-offs that they viewed as duplicative of existing regulatory or processor requirements.

Smaller family farms, in particular, indicated annual signatures and extensive paperwork often do not reflect how animal care is actually delivered on their operations.

The report also called for greater flexibility to accommodate differences in herd size, housing systems, climate and regional production practices while improving evaluator consistency and clearer application of standards.

Producer concerns go beyond

Although many producer concerns in recent years have centered on the FARM Environmental Stewardship (ES) program, the current Version 2028 review is limited to Animal Care and Workforce Development.

The FARM website does not indicate a prior public comment process for Environmental Stewardship (ES), Versions 2 or 3, which were actively developed through Dairy Management Inc.’s (DMI) Innovation Center for U.S. Dairy between 2017 and 2022. The current FARM ES Version 3 was launched in October 2024.

While FARM ES participation is described as voluntary, implementation has expanded to become required in effect through processor, cooperative and supply-chain commitments under the DMI Innovation Center’s U.S. Dairy Stewardship Commitment. According to the FARM program website, 6000 FARM ES evaluations have been completed since 2017.

As FARM ES evaluations by processors, cooperatives and for them through third-parties have expanded during 2025 and 2026, dairy farmers have increasingly questioned sustainability reporting benchmarks, greenhouse gas calculations, audits, and farm data collection. Many also question how cow methane emissions are calculated, modeled, and benchmarked as scientific understanding increasingly recognizes biogenic methane as part of the natural carbon cycle, distinct from fossil fuel emissions, and cows as essential to that cycle.

Some of these concerns were reflected in a 2026 American Dairy Coalition dairy farmer survey, in which 77% of respondents said farm data requests for sustainability reporting were not truly voluntary in practice, 87% said they had never signed a data-sharing agreement while 13% were unsure if one existed, 92% reported receiving no compensation for the value of their farm data, and 100% agreed farmers should own and control data generated on their farms.

While understanding, filtering, and commenting on these concerns are outside the scope of the current FARM survey, there is an opportunity in this survey to provide a final comment to the FARM program staff.

Perhaps most important, participating in the survey shows dairy farmers are engaged and will provide feedback, when they are given the chance, in order to help shape FARM standards and program implementation in the future.