Understanding Milk Classification Labels Back »

Within today’s society there is a lot of confusion about the food we consume. We as consumers need to truly take the time to understand “what” the label is telling us and the “why” behind the way a product is processed and given a particular label before it is presented to us as consumers for consumption. So my challenge to you, as end users is to take a few minutes to become informed before assuming something you have heard is a fact and look to credible sources for accurate information.

Defining Milk

In the last month, I have had several conversations regarding the milk we drink and differences in the various types of milk presented for sale for human consumption. We first need to understand that all milk produced from hooved mammals' is the normal lacteal secretion, practically free of colostrum, obtained by the complete milking of one (1) or more healthy hooved mammals and is produced for the sale of Grade “A” milk and milk products that fall under the Grade “A” Pasteurized Milk Ordinance (Grade “A” PMO)¹ The Grade “A” PMO provisions govern the processing, packaging and sale of these Grade “A” milk and milk products as the basic standard used in the voluntary cooperative state – USPHS/FDA Program for the Certification of Interstate Milk Shippers. All 50 states, the District of Columbia and U.S. Trust Territories participate in this program. To learn more about the Grade “A” PMO standards which are enforced by the SD Department of Agriculture under the Ag Services division and that all dairy producers and dairy processors must follow, visit the South Dakota Department of Agriculture website.

Within South Dakota state statute (§ 39-6-1) "Milk," is defined as the lacteal secretion, practically free from colostrum, obtained by milking one or more healthy cows, that contains not less than eight and one-fourth percent solids-not-fat and not less than three and one-fourth percent milk fat. "Grade A milk," is milk produced in accordance with the standards set forth in regulations promulgated pursuant to the authority granted in § 39-6-9 and that is not subject to the requirements for manufacturing grade milk or raw milk for human consumption. Whereas, "Manufacturing grade milk," (often referred to as Grade “B” milk) is any milk or milk product that is produced for processing and manufacturing into products for human consumption in accordance with the standards set by rules promulgated pursuant to the authority granted in §§ 39-6-9 and 40-32-18 and that is not subject to the requirements for Grade A milk or raw milk for human consumption. Grade A milk is the only milk that can be used for the fluid milk we drink whereas, Grade A milk and Manufacturing grade milk (Grade B) milk can be used for the manufacturing of dairy products such as cheese. Typically, Manufacturing grade is only allowed for cheese manufacture unless specific permission has been granted otherwise for use in other products. Determination of the type of dairy farm grade is done by state statute (following standards set in the Grade “A” PMO) and each Grade “A” farm is inspected bi-annually, whereas Grade “B” farms are inspected annually. According to a January 2016 SD Department of Agriculture report we have 217 Grade “A” dairy farms and 32 Grade “B” dairy farms in South Dakota. A majority of the milk produced from SD dairy farms goes for the production of cheese.

So what is the difference between conventional, organic and raw milk? In South Dakota there are regulations which are set by state law and standards established in the Grade “A” PMO which govern the sale of these three milk products.

Conventional & Organic Milk

Let’s start with conventional and organic milk. Milk can only be labeled organic, according to the U.S. Department of Agriculture (USDA) if it is from cows exclusively fed organically grown feeds, kept in pens of certain size dimension, allowed periodic access to outdoors and sunlight, and cows that are not treated with hormones or antibiotics.² The thing to remember is that NO milk produced in either a conventional or organic production system can be utilized for human food consumption if it contains any antibiotics. Both organic and conventional milk are tested for the presence of antibiotics, bacteria, and for proper storage temperature by the milk hauler/milk processor before it leaves the farm. If any antibiotics are detected in a load of milk from a dairy producer the milk is then discarded and NOT used for human consumption and the dairy producer must pay for the load of milk. Both conventional and organic milk must follow strict standards established by the Grade “A” PMO, including pasteurization to ensure that all milk is pure, safe, and nutritious. Once the milk has been tested for antibiotics, bacteria and proper temperature it then enters the processing plant for pasteurization, standardization and processing into various dairy products; organic and conventional milk are not comingled. Pasteurization is the process of heating raw milk to a minimum of 145° F for 30 minutes or ≥161° F for more than 15 seconds, followed by rapid cooling. Pasteurization kills harmful bacteria that can occur in raw milk, even while the strictest quality production standards are followed. A wide variety of germs sometimes found in raw milk, can make people sick, and include: bacteria (e.g., Brucella, Campylobacter, Listeria, Mycobacterium bovis (a cause of tuberculosis), Salmonella, shigatoxin producing E. coli O157, Shigella, Yersinia ), parasites (e.g. Giardia) and viruses (e.g. norovirus)³. So let’s compare conventional farm practices to organic practices to see what is and is NOT allowed under each production system.

  Conventional Organic
Preventative healthcare for animals Yes Yes
Antibiotics allowed to treat or cure animal illness or disease Yes NO
Milk tested for antibiotics and other drug residues Yes Yes
Recombinant bovine somatotropin (rBST) use allowed Yes No
Source of animal feed Conventional sources Organic sources only
Feed products with ruminant by-products No No
Size of dairy farm Any size Any size
Housing for dairy cows Any type Any type

Source: Midwest Dairy Association: Organic Fact Sheet (2014)

Raw Milk

South Dakota defines “Raw milk for human consumption” (§ 39-6-1) as the lacteal secretion, practically free from colostrum, obtained by the milking of one or more healthy cows, goats, sheep, or other hooved mammals that has NOT been pasteurized or homogenized and is packaged for human consumption. The term also includes raw cream intended for human consumption. In South Dakota, raw milk for human consumption must, at a minimum, be tested monthly for bacteria, coliform bacteria, somatic cell counts, drug residue, and pathogenic bacteria (Salmonella, Listeria monocytogenes, Campylobacter spp., and shigatoxin producing E. coli) at an accredited laboratory approved by the Department of Agriculture. Additionally, raw milk may be tested for pesticides, added water and other adulterants, as deemed necessary by the SD Department of Agriculture, Ag Services division. The tests must be undertaken using the sampling methods in § 12:81:06:01 and must meet the standards in § 12:81:07:02. Any such sample must be collected from the consumer container. (Source: 41 SDR 218, effective June 30, 2015.)

What if pathogenic bacteria is found in raw milk?

So what happens in South Dakota if raw milk is found to be containing pathogenic bacteria upon testing? If official laboratory test results indicate that a sample of raw milk for human consumption contains presumptively pathogenic bacteria, the milk producer must be notified immediately. The milk producer shall immediately notify consumers and the raw milk must be removed from supplies intended for human consumption. The milk producer may only market the raw milk to a licensed milk buyer for further processing, pending the official laboratory results indicating the presence or absence of pathogenic bacteria. An official sample must immediately be collected and tested, at the producer's expense, for the contamination that led to the stop sale and recall of raw milk for human consumption. If the official laboratory results confirm that the raw milk for human consumption contains pathogenic bacteria, the producer's permit to sell raw milk for human consumption is suspended. The department (SD Dept. of Agricultural – Ag Services) shall reinstate the milk producer's permit if the sample meets the standards outlined in §§ 12:81:07:02 and 12:81:07:03 and the milking facility successfully passes an inspection. (Source: 41 SDR 212, effective June 30, 2015.)

Labeling raw milk in South Dakota

So how must raw milk be labeled in South Dakota? All final consumer containers containing raw milk for human consumption must be labeled in accordance with the requirements provided in this section (12:81:07:06). All final consumer bottles, containers, and packages containing raw milk for human consumption must be conspicuously marked with: 1) the identity of the farm where the raw milk is produced and packaged; 2) the words “RAW MILK” OR “RAW CREAM”; 3) the date of bottling. (Source 41 SDR 218, effective June 30, 2015.)

In this day and age it is extremely important to make informed choices about the products we consume and to further investigate what we are consuming and to not assume that everything we hear or read on the internet is true.


  1. U.S. Department of Health and Human Services Public Health Service / Food and Drug Administration. (2013, February 27). 2013 Grade "A" Pasteurized Milk Ordinance. S.D. Department of Agriculture: Agricultural Services: Dairy And Eggs: Dairy Program.
  2. United States Department of Agriculture: Agricultural Marketing Services. (2011, March). National Organic Program Handbook. Retrieved February 27, 2016 from USDA.
  3. Centers for Disease Control and Prevention. (2015, March 10). Food Safety and Raw Milk. Retrieved February 29, 2016 from CDC.
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