On December 6, 2024, the U.S. Department of Agriculture (USDA) ordered nationwide surveillance sampling of raw cow’s milk intended for pasteurization. The order lets the Animal and Plant Health Inspection Service (APHIS) request samples from covered farms and milk-handling businesses; it does not require testing every retail carton or every dairy cow. A positive sample from a processing-plant silo prompts investigation, but does not by itself establish that a herd or state is affected.
What the December 2024 order requires
The order is part of USDA’s National Milk Testing Strategy (NMTS). When APHIS requests it, a person responsible for a covered operation must allow APHIS or its cooperators to collect enough raw milk for highly pathogenic avian influenza (HPAI) testing. The milk must be cow’s milk intended for pasteurization and sent or held by one of these entities:
- Dairy farms
- Bulk milk transporters
- Bulk milk transfer stations
- Dairy processing facilities
The order also requires laboratories and state veterinarians to report positive influenza A nucleic acid detection results from livestock diagnostic samples, including raw milk. Owners of herds associated with positive milk tests must provide basic epidemiological information, including animal movement information. See the USDA Federal Order for the order’s requirements.
What is being tested—and what is not
This is surveillance of raw milk moving through the pasteurization supply chain. It is not a mandate to test every consumer’s milk, every retail carton, or every individual dairy cow. USDA’s National Milk Testing Strategy uses samples from processing-plant silos and other bulk milk sources to monitor for H5 and guide follow-up.
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How the five NMTS stages work
- National silo monitoring: USDA monitors milk silos at processing plants nationwide to locate disease and identify trends.
- State status assessment: USDA works with states on bulk milk programs to identify affected herds or demonstrate that herds are unaffected.
- Response in affected states: The focus is case identification and response, including enhanced biosecurity, movement controls, and contact tracing.
- Demonstrating unaffected status: Sampling continues in states working to demonstrate that they remain unaffected.
- Long-term surveillance: Periodic surveillance is used to demonstrate long-term freedom from H5 in the national dairy herd.
USDA says it will consider ending the strategy when all states reach Stage 5 and demonstrate freedom from H5 in the U.S. dairy herd. The five stages describe the program’s progression; they do not mean that every state is currently at the same stage.
What happens when a raw-milk sample tests positive for H5?
A positive raw-milk sample triggers additional state investigation. Processing-plant silo samples are pooled surveillance samples, so a positive result signals that further investigation is needed; it does not identify a particular infected cow or prove that the state is affected. State and federal officials use additional herd-level testing to determine herd and state status. USDA’s NMTS frequently asked questions explain that a state is not considered affected based only on results from raw milk collected at processing-plant silos.
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How this differs from testing dairy cattle before interstate movement
The December 2024 milk order complements a separate Federal Order issued in April 2024. That earlier order requires testing of lactating dairy cattle before interstate shipment and reporting of positive results; it remains in effect. The programs have different samples, triggers, and purposes.
| Program | What is sampled | When it applies | Purpose and participation |
|---|---|---|---|
| December 2024 National Milk Testing Strategy order | Raw cow’s milk intended for pasteurization | Covered operations must provide a sample when APHIS requests one | Mandatory order obligations support surveillance and investigation |
| April 2024 interstate movement order | Lactating dairy cattle | Before interstate shipment | Requires testing to meet interstate movement requirements |
| Dairy Herd Status Program | Weekly bulk milk samples | Voluntary option for eligible herds monitoring status before interstate movement | Can serve as an alternative to testing each individual animal under the program |
Details of the movement order are available from USDA APHIS’s Federal Order page.
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What dairy producers should know about the voluntary herd-status option
The Dairy Herd Status Program is separate from the mandatory milk-surveillance order. For eligible herds, APHIS says three consecutive weekly negative results from National Animal Health Laboratory Network (NAHLN) laboratories establish Monitored Unaffected status. Continued weekly negative testing maintains that status. Producers can use weekly bulk tank samples through this voluntary program rather than testing each individual animal before interstate movement. See USDA’s Dairy Herd Status Program guidance for eligibility and program details.
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