The National Conference on Interstate Milk Shipments (NCIMS) incorporated the requirements laid out in the Food Safety Moderation Act (FSMA) Preventive Control for Human Food (PCHF) rule into the Pasteurized Milk Ordinance (PMO), Appendix T during the 2017 NCIMS conference, with a compliance date of September 2018. Since the 2018 compliance date, FDA has been conducting food safety audits during check ratings to determine compliance.
During these inspections, if FDA determines the site does not comply with the PCHF rule, the agency has the ability to stop the check rating and issue a 2359i form with details of noncompliance to the PCHF Rule. The Grade A site has 60 days to work with the state rating officer (SRO) to achieve compliance. At the end of the 60 days, the SRO conducts a PCHF audit and an Interstate Milk Shippers (IMS) rating. A successful state rating allows the plant to continue its IMS Listing.