FARM 3.0 was instituted Jan. 1, 2017. The most notable requirement is the tail docking ban. All farms selling to plants that require FARM compliance should have been inspected by a qualified FARM inspector by now. For most farms, this is someone from the dairy co-op or processor. A small number of farms have been evaluated by a third-party inspector. The list of documents required by FARM 3.0 is extensive, but the list of things that can trigger enforcement at this time is fairly small. Some of those documents require annual signatures. Now would be a great time to get your FARM 3.0 documents updated.
    Here is the list of documents you need to have available for inspection on your dairy:
    - A signed Veterinary Client Patient Relationship (VCPR) dated within the last 12 months.
    - Dairy cattle ethics agreement for all employees with animal care responsibilities dated within the last 12 months.
    - Dairy cattle training agreements and log for all employees with the specific responsibilities of stockmanship, calf care, non-ambulatory animals and euthanasia.
    - A posted emergency contact sheet.
    - Drug treatment records.
    - Herd health plan signed by the veterinarian or record in the last 12 months.
    - Mortality records.
    - A third-party verification signature page if a third-party audit has been completed.
    Notice that you must have signatures updated annually for the VCPR, dairy cattle ethics agreements and the herd health plan. Your veterinarian will need to sign the VCPR and herd health plan. You should sign the VCPR and herd health plan, as well. Your employees need to sign or resign and date the dairy cattle ethics agreement. Signatures do not need to be updated for the dairy cattle training agreements, but there needs to be one on file for every affected employee, including any new people who have not yet signed.
    When the National Milk Producers Federation developed the FARM program they proposed a phased enforcement strategy to give producers time to comply. As a result, there are only three requirements that if not met, will trigger a mandatory corrective action plan. These are phase one priority areas: a signed VCPR; signed dairy cattle ethics agreements, and no tail docking.
    You could perhaps squeak by just having these. However, there are also four phase two priority areas that if not met, will trigger a continuous improvement plan, which is somewhat of a lower bar of enforcement. These are: a herd health plan to include, at a minimum, protocols for newborn and milk fed calf management, pain management, non-ambulatory animals and euthanasia. Ninety-five percent of the cow herd must score two or less on the FARM locomotion scorecard. Ninety-five percent of the cow herd must score two or less on the FARM hock and knee scorecard. Ninety-nine percent of all classes of animals must score two or more on the body condition score scorecard.
    Locomotion, hock and knee, and body condition scoring is done at the time of inspection, so all you need available to avoid enforcement action is the herd health plan. If you do not have a written and signed herd health plan, now would be a time to develop one. When doing this the best practice would be to complete all the parts of the required herd health plan, not just the four parts subject to enforcement at this time. The plan for enforcement is to enforce more of the requirements over time.     Here is the list of the remaining required herd health plan protocols: milking routine and procedures; common disease treatments and monitoring; vaccinations, specifying age, class, product and administration route; daily observation of cattle for disease or injury; diseased or injured cattle management, including treatment for pain; disease treatments; parasite, pest and fly control; air quality; lameness prevention and management; dystocia, and culling and transport to slaughter.
    There are 14 required protocols in the herd health plan if we consider pain management and diseased cattle management the same. If you do not have them and want to get started, there are some examples on the FARM website. Your co-op or processor field representative may have others. Your veterinarian can help, too. Most dairy veterinarians have written dozens of protocols and will be able to provide examples of most of the required documents. Understand that this is not a veterinarian-directed program; nor is it a government program. FARM is NMPF’s program that has been adopted by just about every co-op or processor in the United States, so ultimately enforcement questions should be directed to whomever is purchasing your milk.
    Our veterinary practice developed generic versions of all the required protocols and documents before January 2017 to share with our producers if requested so they could modify and update them as needed. We also created a binder for all required documents that is used to file everything related to FARM in one place. We are starting the process to help everyone get the required updates. Other practices may have done similar efforts, so if you have not yet put everything together, your veterinarian might be the first person to ask. If you have everything in place, be sure to get the documents updated at least every 12 months.
    Jim Bennett is a dairy veterinarian at Northern Valley Dairy Production Medicine Center in Plainview, Minn. He and his wife, Pam, have four children. Jim can be reached at with comments or questions.