Dairy Programs

Did you ever wonder why there are different options for obtaining dairy products in Utah?  And just what are the differences in the programs?  How do they affect you and your beloved family (the consumer) and me (the producer)?  

Well, let us take a look. I was asked not long ago how one knows if their milk is good if they are not a Grade A Raw Dairy.  My Response, "I've worked with health inspectors in three different states.  Held a current Food Handler's Permit in Nevada, Utah and South Dakota.  The inspectors will tell you that they know that as soon as they turn their back on the producer (restaurant, dairy, bakery etc) many producers go back to their old habits of unclean practices.  I worked at a bakery for a short time (no name will be disclosed) who sells wholesale and a lot of retail.  Well known bakery.  A huge reason that I quit is because of some of their practices.  
1) Picking food off the floor and baking it or packaging it for unsuspecting customers 
2) packaging product with bare hands... 

This is a well known commercial bakery and NOT a home bakery.  I know at least one licensed Raw to Retail dairy who chills their milk in the refrigerator, does not temperature test their milk because the state does it for them once a month, does not wash hands between does and also does not sanitize the udders in any way except to brush their bare hand across the udders.  .... 

Also by FDA standards, raw milk dairies are typically NOT Grade A, because many of them are not pipeline and the producer handles the milk.  Utah calls Raw Milk dairies Grade A, but freely admits that technically most raw milk dairies in Utah are actually Raw to Retail Licensed Dairies, NOT Grade A.  The State of Utah does not test unless there is an illness for one of the most dangerous bacteria; camphylobacteria, because its too hard to test for.

Bottom Line then
Calling one's self Grade A Raw Milk Dairy in Utah is just a false sense of security for you. Many licensed and unlicensed dairies do a tremendous job of following health standards.  Others pretend to and hide under the name of Grade A licensing to sell their product. While the inspectors do a wonderful job and we have learned so much from them, they are not catching the real problems in licensed dairies and some of them actually tell the licensed dairies that they are just fine to 'keep doing what they are doing' because the bacteria count is good at present.  In reality, some of these dairies are violating some very serious health standards and dairy code.  So is the milk from a licensed or non-licensed dairy/bakery/etc safe?  It all depends upon if the producer is health-conscious and would follow or reach ABOVE health standards, even if they were not licensed.  It all depends upon the producer.  This is true even with foods that we get in grocery stores."

We at Northern Dawn Dairy strive to uphold strict health standards. We choose to not become licensed at this time, because through the herd share program, we are able to provide more products of a raw nature for you an your family...We love the Herd Share program and know that you do too. That being said, let us take a look at the pros and cons of both programs that Utah Currently has and compare.


Program:   Herd Share

Producer Requirements

  • Create and sign
  • Bill of Sale and Agreement
  • with the consumer
  • Notify Utah Dairy Manager
  • in writing of their intent to sell dairy products through the Herd Share Program
  • Herd and milk records
  • must be available at all times to the consumer for their viewing. Thus that is an added incentive to the producer to maintain strict safety standards

Consumer Requirements

  • Must sign a Bill of Sale and agreement with the producer

What is the Program?

  • Consumer owns a very small limited percentage of the herd
  • Because of this, the producer does not have to be licensed to sell the milk and milk products
  • The consumer does not necessarily
  • get a share of the sale of babies born,
  • nor can
  • he/she tell a producer what to do with the animals

Benefits and Downfalls

Herd Share puts food standards in the hands of the producer to decide what standards they will adhere to.  Thus, if they want to sell their dairy products, they have to make the decision to uphold strict standards. They are not forced into anything. Its the responsibility of the consumer to check out their intended facility to see if it meets the standards they desire to purchase from.


  • Products may be transported to a drop off point or to a consumer's home
  • Allows for
  • cheaper prices
  • of products, due to fewer costs to maintain silly regulations and inconsistent regulations imposed on licensed dairies
  • Allows for a greater diversity of natural raw milk products


  • Products may not be sold at a farmer's market, fair or off-farm store
  • The producer may only sell dairy off of ten goats, ten sheep and two cows.
  • Doesn't give a lot of room for as much milk to be produced

Program:  Licensed Raw to Retail

Producer Requirements

  • Meet the strict and inconsistent facility requirements imposed on the producer
  • The producer is required to have a valid Food Handler's Permit.
  • However, many times the inspectors don't let the producer know that it is a requirement
  • The producer is required by Utah Law to follow the
  • Pasteurized Milk Ordinance
  • (PMO) for safe handling of the udder and milk.
  • However, some licensed dairies are not following this and are told by their inspector that if their bacteria counts are good, that they don't have to follow PMO standards.
  • Goats must be tested for Brucellosis
  • and cows for TB and Brucellosis.
  • Results must be sent to UDAF Dairy Manager.
  • One time test.
  • Log must be kept of the people who purchase milk from them
  • Waiver of liability must be provided to the consumer. Basically this is a mini contract relieving the producer of liability in case of sickness.
  • Milk must be sold in an on-farm storeroom.
  • Can't be sold out of the house etc.
  • However, some inspectors don't force the storeroom.
  • Dairies are forced to comply which is not always the best policy

Consumer Requirements

The consumer must sign the waiver of liability

What is the Program?

The producer has to first meet UDAF facility requirements. Then they have to apply for the license to sell raw milk. If the inspector approves the facility and if the first bacteria counts are good, then the dairy obtains a permit to sell raw milk. UDAF calls it a Grade A dairy.  However, Federal calls it Raw to Retail and not Grade A dairy. State tests the milk monthly for Standard Plate Count, Coliform and somatic cell count. They do not routinely test for camphylobacteria. If at any time the counts are too high the permit to sell milk will temporarily be pulled.  Thus the producer is 'forced to comply', rather than complying to regulations on their own desires. Raw to Retail dairies cannot sell anything except for raw milk, without further licensing.


The producer may milk and sell raw milk from as many animals as he/she wants


  • Often the various inspectors rules that they impose on the producer are not consistent with each other. ie/ One inspector will say that you must have a food handler's permit, another says you don't need one.
  • One inspector will enforce the safe disinfecting of udders, whereas others will say, "if your bacteria counts are great, you don't have to follow the safe disinfecting guidelines
  • Raw milk may only be sold from the on-farm store.
  • It may not be sold in an offsite store, farmer's market or fair.
  • The only exception is if the producer owns at least 51% of the profits of an off-site-store, they may transport and sell the raw milk from that off-site store.
  • This means that most small producers don't have enough money to sell, except from their farm
  • Often, even though the inspectors are great to work with, the facility required is too costly for many wanna-be producers to even get started.
  • Many Licensed dairies and non-licensed strive to produce a safe and wholesome product.
  • However, not all dairies try. Sometimes they let things slip when the inspector turns their back.
  • The reason is that they are forced to do a certain thing, rather than doing them because they strive for excellence on their own desire.
  • Thus, products from licensed dairies may give a false sense of security Inspectors cannot be everywhere at all times. They cannot test milk at required cooling intervals, etc. Thus the security in the licensed facilities is false security.
  • Another false sense of security is that of no routine testing for camphylobacteria.
  • Utah does not routinely test for this because it is so hard to test for Producer signs that the inspector has the right to come on the property at any time and go through the facility and herd. This can be good or bad, depending upon the inspector