The Grade "A" Pasteurized Milk Ordinance

The Grade "A" Pasteurized Milk Ordinance (PMO) is recognized as the national standard for milk sanitation.
The Grade "A" Pasteurized Milk Ordinance - Articles


The Grade "A" Pasteurized Milk Ordinance (PMO) is recognized by the Public Health Agencies, the milk industry, and many others as the national standard for milk sanitation. The PMO provides uniform regulations for the dairy industry that are created by the dairy industry, government, and academic representatives.

The Grade "A" Pasteurized Milk Ordinance (PMO) is considered the gold standard of regulations and is an invaluable resource for all aspects of dairy production and processing. Some sections of the PMO apply to all dairy processors, such as farm and milk plant inspections and drug residue testing, while other sections apply to those producing pasteurized, Grade "A" products. Other key features of the PMO are the standards for milk and milk products, pasteurization conditions, equipment and testing specifications, dairy farm and milk plant facility specifications, and the HACCP program.

Obtaining a Copy of the PMO

The PMO is easy to find electronically, and often in short supply in printed format. To find an electronic copy, it is usually easiest to do a browser search for "Pasteurized Milk Ordinance" and the year, which will identify several links to download the over 400 page. pdf document for free. Check with your local PDA or FDA sanitarian to see if printed copies are available.

PMO Table of Contents

The scope and importance of this document warrants including the Table of Contents here for reference, particularly for those who are unfamiliar with this resource.

  • Definitions
  • Adulterated or misbranded milk and/or milk products
  • Permits
  • Labeling
  • Inspection of dairy farms and milk plants
  • The examination of milk and/or milk products
  • Standards for Grade "A" Raw Milk for Pasteurization, Ultra-pasteurization, Aseptic Processing and Packaging or Retort Processed After Packaging
  • Standards for Grade "A" Pasteurized, Ultra-pasteurized, Aseptic Processed and Packaged Low-acid Milk and/or Milk Products, and Retort Processed After Packaged Low-acid Milk and/or Milk Products
  • Appendix A. Animal Disease Control
  • Appendix B. Milk Sampling, Hauling and Transportation
  • Appendix C. Dairy Farm Construction Standards and Milk Production
  • Appendix D. Standards for Water Sources
  • Appendix E. Examples of 3-Out-Of-5 Compliance Enforcement Procedures
  • Appendix F. Cleaning and Sanitization
  • Appendix G. Chemical and Bacteriological Tests
  • Appendix H. Pasteurization Equipment and Procedures and Other Equipment
  • Appendix I. Pasteurization Equipment and Controls - Tests
  • Appendix J. Standards for the Fabrication of Single-service Containers and/or Closures for Milk and/or Milk Products
  • Appendix K. HACCP Program
  • Appendix L. Applicable Regulations, Standards of Identity for Milk and Milk Products, The Federal Food, Drug, and Cosmetic Act, and the Federal Insecticide, Fungicide and Rodenticide Act
  • Appendix M. Reports and Records
  • Appendix N. Drug Residue Testing and Farm Surveillance
  • Appendix O. Vitamin Fortification of Fluid Milk Products
  • Appendix P. Performance-based Dairy Farm Inspection System
  • Appendix Q. Operation of Automatic Milking Installations for the Production of Grade "A" Raw Milk for Pasteurization, Ultra-pasteurization, Aseptic Processing and Packaging or Retort Processed After Packaging
  • Appendix R. Determination of Time/Temperature Control for Safety Milk and/or Milk Products
  • Appendix S. Aseptic Processing and Packaging Program and Retort Processed After Packaging Program


Dairy products have long known to be associated with pathogens and the industry has long participated in a voluntary food safety system to control these hazards and produce safe dairy products. This system follows principles of a Hazard Analysis and Critical Control Point (HACCP) system, including required prerequisite programs. The requirements of a dairy HACCP system, prerequisite programs, records, training, and implementation are listed in Appendix K of the PMO.

FSMA requires all facilities to have a food safety plan that is broader in scope than a traditional HACCP plan. The FSMA Hazard Analysis and Risk-based Preventive Controls (HARPC) food safety plan contains more preventive controls (process, sanitation, allergen) to manage hazards than would be defined as critical control points (CCPs) under a HACCP system. Additionally, FSMA requires supply-chain control programs and recall plans.

The FDA recognizes the effectiveness of the voluntary dairy HACCP program with regard to FSMA. However, there are gaps between the current Appendix K and the requirements of FSMA, such as a mandatory allergen control program, supply-chain program, and recall plan. It is the intention of the FDA to bring the PMO Appendix K into compliance with the FSMA regulations. Consequently, the FDA has made a provision for dairies following Appendix K of the PMO to have until September 17, 2018 to comply with FSMA regulations in order to allow for the changes to be made to the PMO.

PMO Revisions

The PMO is revised every 2 years, in odd-numbered years, by the U.S. Department of Health and Human Services, Public Health Service, Food and Drug Administration. Changes to the PMO are based on the outcome of proposals, discussions, and votes by representatives of the dairy industry, government, and academia from all 50 states and U.S. territories, that occur at the biannual meeting of the National Conference of Interstate Milk Shipments.

The process of updating the PMO after each conference takes time before the new PMO is released in electronic and paper format to FDA personnel, local inspectors, and other dairy professionals. The 2015 version was released spring 2016.