Recently there has been an attempt to modify the Grade A PMO by removing the need for sanitizing teats prior to milking. While the NCIMS approved such a change, the FDA did not so the need for sanitizing remains essentially unchanged. The FDA did provide for an alternative. Basically item 13r of the PMO is as follows:

This item is deemed to be satisfied when:

1. Milking is done in a milking barn, stable or parlor.

2. Brushing is completed prior to milking.

3. Flanks, bellies, tails and udders are clipped as often as necessary to facilitate cleaning of these areas and are free from dirt. The hair on the udders shall be of such length that it is not incorporated with the teat in the inflation during milking.

4. Udders and teats of all milking cows are clean and dry before milking. Teats shall be cleaned, treated with a sanitizing solution and dry just prior to milking...

The FDA added the following to #4 ...except that additional alternative udder preparation methods may also be used once they have been evaluated by FDA and found acceptable.

Since the time of this addition to item 13r of the PMO, one alternative method has been approved:

Sanitizing of the teats shall not be required if the udder is dry and the teats have been thoroughly cleaned (not dry wiped) and dried (manually wiped dry) prior to milking. The determination of what constitutes a dry udder and dried teats shall be made by the regulatory agency.

The FDA will evaluate other alternative methods for udder and teat preparation as such methods are presented to them. So as of this time, teat sanitization is still required prior to milking.