Tail scoring, mortality questions, transport among proposals as comment period ends Oct. 2

ARLINGTON, Va. — Tail injuries would be scored differently. Mortality questions would come back. Fitness-to-transport language would get more specific. But many of the FARM Animal Care standards dairy farmers know today would stay largely intact.

Those are the highlights from the National Dairy FARM Program webinar recently explaining proposed changes and the comment period, asking farmers and others in the industry to weigh in on Version 2028, scheduled to take effect in January 2028.

The public comment period runs through Oct. 2.

“This is meant to be an industry program,” said Steven Roche, founder and CEO of ACER Consulting, who presented the Animal Care recommendations. “We’re looking to make sure that this is representative and inclusive of your thoughts.”

Farmers don’t have to comment on everything. They can respond only to the standards or proposals they care about, along with a general feedback and comments section at the end of the survey.

Tails: Same benchmark, different score

One of the more noticeable changes involves injured tails. Instead of the current injured-or-not approach, FARM proposes a three-point scale distinguishing normal tails from moderate and severe injuries.

The important part for producers is that the existing 5% benchmark would not change. Instead, it would apply specifically to the most severe, score-3 injuries. Farms exceeding 5% of those would receive a Continuous Improvement Plan aimed at reducing the prevalence within three years.

Roche said the approach would give farmers and evaluators more useful information about severity without simply tightening the existing threshold.

Mortality is back; no corrective action

Another notable proposal is the return of mortality questions, which were part of FARM Version 4 but dropped from Version 5. Roche tied their return to FARM’s efforts to maintain ISO certification, which provides outside credibility for the program, including in international markets.

Evaluators would ask whether a farm keeps mortality records and, if so, ask for 12-month mortality rates for several animal groups. Roche stressed that a farm that doesn’t keep mortality records would not receive a corrective action.

“It is not required, but rather it is a good practice,” he said.

More clarity on shipping animals

FARM also proposes spelling out more specifically what should be considered when deciding whether a cow or calf is fit to transport.

The guidance would draw from the American Association of Bovine Practitioners and USDA Food Safety and Inspection Service, particularly conditions that could ultimately result in condemnation at slaughter.

Roche characterized this more as clarification than a major new standard. “We are just spelling them out a little bit more clearly,” he said.

Some debated standards stay put

Not everything discussed resulted in a proposed change. One example is the requirement to offer calves solid feed by day three. The committee considered moving that to day five, seven or even 10, reflecting concerns Roche said producers and others have raised for years.

The recommendation is to keep day three, while clarifying that “starter” does not necessarily mean a starter pellet. Depending on the system, forage, hay or grass can qualify as solid feed.

Likewise, FARM is not proposing to increase the basic 100-animal sampling used for animal observations, although it is still considering whether the cows selected on larger dairies could better represent the herd rather than focusing on the oldest, highest-producing cows.

Other familiar requirements — including veterinarian-client-patient relationships, herd health plans, cow-care agreements, treatment records and annual continuing education — are also proposed to remain essentially unchanged. FARM did, however, eliminate or revise a number of informational questions in an effort to streamline evaluations.

Workforce: Less prescriptive

Proposed changes to FARM Workforce Development follow a somewhat different theme: simplifying questions and making the evaluation less prescriptive.

Nicole Ayache, chief sustainability officer for the National Milk Producers Federation, emphasized that Workforce Development is different from Animal Care. Participating cooperatives and processors do not have to evaluate every farm, and the program does not generate mandatory corrective actions.

Instead, it focuses on HR and safety best practices. About 1500 Workforce Development evaluations were conducted in 2025.

Changes under consideration include simpler employee-handbook and payroll-record questions, less-prescriptive language around safety inspections and clearer recognition that employee training can include everything from formal programs to job shadowing and tailgate talks.

One proposed addition would ask whether farms provide personal protective equipment (PPE) to employees, without dictating particular equipment because needs differ by farm and job.

Some potential Workforce Development additions are being presented as “exploratory” rather than actual recommendations, Ayache stressed. The committees want producer feedback before deciding whether those ideas should advance.

Speak now; final decisions come later

After the Oct. 2 comment period closes, FARM officials said every comment will be read and reviewed before committees revisit the proposals.

The goal is to bring final Version 2028 recommendations to the NMPF Board of Directors in the first quarter of 2027, leaving the remainder of that year for evaluator training, new resources and preparation for the January 2028 rollout.

For farmers, Roche’s message was simple: If there’s a FARM standard you think works — or doesn’t — this is the time to say so.

The complete proposals and public-comment survey are available through the National Dairy FARM Program website at https://nationaldairyfarm.com/

Scroll down to Version 2028 Open Comment Period heading and see tabs for the Animal Care Version 2028 Development and Workforce Version 2028 Development. Click the one you want to comment on and scroll to the Complete the Survey button to enter the survey, which moves through the changes section by section with multiple choice and open-ended questions.

While many dairy farmers have raised questions about FARM Environmental Stewardship (ES), it is not part of the current public-comment survey. That’s despite changes made as recently as May to the greenhouse-gas model powering FARM ES, including how homegrown feeds are incorporated into the whole-farm footprint.

 So we submitted a question during the webinar: When have dairy farmers had — or when will they have — an opportunity to weigh in directly on FARM Environmental Stewardship?

The answer revealed that Environmental Stewardship has followed a very different path for farmer input and program development than Animal Care — including how the metrics, scientific model and farm data are handled.

That answer is the backbone of Part Two.