OUR INDUSTRY TODAY

Implementing a Quality Assurance Program Using a

Risk Assessment Tool on Dairy Operations
W. M. SISCHO,1 N. E. KIERNAN,2 C. M. BURNS,1
and L. I. BYLER1
The Pennsylvania State University, University Park 16802

ABSTRACT
Concerns and perceptions about antibiotic residues
in milk prompted the dairy industry to develop a
voluntary program to support rational antibiotic use
on dairy farms. One deficiency of this program is the
inability of producers to identify easily the weaknesses in antibiotic management in order to develop
control plans. To overcome this deficiency, an educational approach was designed. The program centered
on an on-farm risk assessment tool used by the
producer and an industry educator to determine the
current risk for residue violation. The risk assessment
tool was tested by 25 field personnel working with
northeastern milk receivers and 250 producers in
seven states. The participants in the study identified
a lack of adequate treatment records as being the
highest risk factor for antibiotic residues, followed by
deficiencies in understanding how to use antibiotics
and poor relationships between veterinarians and
their clients. When field representatives utilized the
risk assessment tool, for most producers, risk of antibiotic residue decreased by approximately 19%. In
particular, more farms kept written records or more
complete records. Finally, producers with reported
histories of antibiotic residues were less likely to implement management changes to reduce the risk of
antibiotic residue.
( Key words: quality assurance, antibiotic residues,
food safety)
Abbreviation key: HACCP = hazard analysis critical control points, MDBQAP = Milk and Dairy Beef
Quality Assurance Program.
INTRODUCTION
Consumer and governmental concern over the
potential for the introduction of chemical contaminants on the farm into the food supply is an

Received December 5, 1995.

Accepted July 25, 1996.
1Department of Veterinary Science.
2Department of Human Resources.
1997 J Dairy Sci 80:777787

important issue affecting policy for the livestock industry. Farm organizations have responded to this
concern by developing innovative on-farm programs
for management and quality assurance. In particular,
the dairy industry developed the Milk and Dairy Beef
Quality Assurance Program ( MDBQAP) to promote
rational protocols directed at managing and reducing
the use of antibiotics on the farm ( 6 ) .
The MDBQAP was originally designed as a voluntary program for producers, but, in July 1992, the
revised Pasteurized Milk Ordinance ( 1 ) required that
any producer found with a violative antibiotic in
shipped milk would be required to participate in the
MDBQAP. This ordinance changed the nature of the
MDBQAP; the program was no longer voluntary. The
change might explain in part the poor nationwide
participation in the program. According to registration records as of October 1995, including duplicate
and required participation, only 6276 of approximately 145,000 dairy producers in the US had completed the program.
The MDBQAP was conceived as a Hazard Analysis
Critical Control Points ( HACCP) program ( 2 ) .
There are several general components to any HACCP
program. An HACCP program must 1 ) articulate the
hazard, 2 ) identify the critical control points for the
hazard, 3 ) quantify the limits of the hazard (i.e., the
allowed product variability), 4 ) identify the risk for
the hazard on the premises, 5 ) implement procedures
to control risks that are specific to the premises, 6 )
assess the success of the procedures to control risk
(i.e., implement a monitoring program), and 7 ) establish a system to verify and document the implementation of the HACCP program ( 4 ) .
Evaluation of early implementations of the
MDBQAP by representatives of milk receivers and
veterinarians identified deficiencies in the MDBQAP
program as an HACCP program. Although the
MDBQAP clearly articulated the hazard (antibiotic
residues) and provided critical control points to prevent the hazard [the 10 points in the booklet (3)], the
MDBQAP failed to motivate producers to examine
their own practices carefully. The MDBQAP did not
provide adequate tools for the producers to develop
plans to manage and monitor changes that were

777

778

SISCHO ET AL.

specific to their own farms. Because the MDBQAP

appeared to be a regulatory program, producers were
not convinced that practices used to avoid residues
were integral to successful dairy production and did
not constitute government interference in their enterprise.
Overall, the MDBQAP did not readily allow
producers to characterize their own risk for antibiotic
residue, did not result in a plan to overcome risk, and,
ultimately, did not allow producers to evaluate their
own progress in lowering the risk of violation. To
overcome these deficiencies, researchers at The Pennsylvania State University designed an alternative
educational program to aid in the implementation of
the MDBQAP. The program was built on the strength
of the MDBQAP, which articulated the hazards of
antibiotic residues and provided a general set of control points. However, the new program extended the
MDBQAP to focus producer awareness of on-farm
practices to avoid antibiotic residues. The core of this
educational program was a tool for risk assessment to
be used by the producer and an industry educator on
the farm to determine the current risk of residue
violation. This study evaluated the success of the
educational program in influencing management as
reflected by changes in on-farm practices to avoid
antibiotic residues.
MATERIALS AND METHODS
Development of the Risk Assessment Tool
The risk assessment tool was designed to complement the MDBQAP workbook, Milk and Dairy Beef
Residue Prevention Protocol ( 3 ) . The risk assessment
tool was to be used to quantify and rank the risks
associated with antibiotic residue in the bulk tank
according to the HACCP outlined in the MDBQAP
workbook. The tool would then identify on-farm
strengths and weaknesses for residue prevention,
facilitate risk communication, and provide a means to
assess on-farm progress in risk abatement.
The risk assessment tool was based on three
sources of information that helped to quantify and
rank on-farm management practices. The first was
the MDBQAP workbook, which served as the basic
structure to rank risk and clearly outlined HACCP to
prevent on-farm antibiotic residues. The second
source was a refereed journal article by McEwen et al.
(10). Those researchers ( 1 0 ) used observational
study methodology to contrast the management style
and knowledge of antibiotics among producers who
had violative levels of antibiotics in their milk against
those who did not. The study of McEwen et al. ( 1 0 )
Journal of Dairy Science Vol. 80, No. 4, 1997

was the most important source for quantifying risk

because violators were contrasted against a control
group, and the strength of association between risk
and management practices could be determined. The
final source of information to rank risk came from
studies (7, 12) that used known cases of residue
violations to identify causes for the violations. Those
studies (7, 12) were of less value because they lacked
control farms for comparison, and, therefore no
strength of association could be determined for the
risk factors.
Of the 10 HACCP outlined in the MDBQAP
producer booklet, 8 could be evaluated on the farm by
an objective observer. Consequently, the risk assessment tool was designed to address those 8 points. The
HACCP were: 1 ) herd health, which was evaluated
according to mastitis control and the reproductive and
dry cow management on the farm; 2 ) the relationships between veterinarians and clients; 3 ) identification of treated cows; 4 ) treatment records and communication on the farm; 5 ) drug storage; 6 ) labeling
of antibiotics; 7 ) on-farm screening for antibiotics;
and 8 ) understanding the appropriate use of antibiotics. An additional section was added to assess the
perception of the producers own risk as well as the
risk of neighboring producers for antibiotic residues
in bulk tank milk.
Based on the information sources described previously, each of the 8 management areas or HACCP
were ranked from first to last in importance for avoiding residues. Importance was defined as a deficiency
that could directly result in an antibiotic residue. The
management areas with the highest potential risk
were treatment records, relationships between
veterinarians and clients, understanding the proper
use of antibiotics, and the use of antibiotic screening
tests. The areas with the least risk were programs
involving reproduction, dry cow management, and
mastitis control. The assessment tool was designed so
that deficiencies in the high risk areas would be
weighted to dominate the on-farm risk assessment.
The areas from highest to lowest risk and the range of
risk weights are presented in Table 1.
Program Implementation
The risk assessment tool was designed to be administered by any educator (dairy industry field
representatives, veterinarians, or county extension
agents) who was interested in implementing the
MDBQAP. In this study, field representatives implemented the program. The representatives were
chosen because their primary focus on the farm was
milk safety and quality, and those representatives

779

OUR INDUSTRY TODAY

TABLE 1. The ranking and range of potential risk points for on-farm management or critical control
points associated with the risk of an accidental occurrence of antibiotics in bulk tank milk.
Range of
risk points

Ranking HACCP1
1
2
2
2
5
5
7
7
9

Treatment records and communication

Relationship between veterinarian and
Understanding the use of antibiotics
Proper labeling of antibiotics
Use of on-farm screening tests
Identification of treated cows
Proper storage of antibiotics
Existence of reproductive and dry cow
Existence of an active mastitis control
1Hazard

to and between employees

client

programs
program

035
023
020
019
018
020
017
017
015

Analysis Critical Control Point.

were the only industry contacts that all dairy

producers would have consistently had. The risk assessment tool contained questions directed to the
producer and observations made by the educator; an
example of one section of the tool is shown in Figure
1.
Field supervisors from four participating milk
receivers were designated as field representatives in
the project. In turn, each field representative identified a sample of 10 producers who would cooperate in
the study. The goal was to enroll 250 producers from
at least three states to participate in the program.
Although the sample of both field representatives and
producers was likely biased, the randomization of
producers to treatment and control groups allowed
fair evaluation of the treatment effects within the
study population.

On control farms, the field representatives used the

risk assessment tool to identify on-farm risk but did
not explicitly review the assessment results with the
producer and only provided the MDBQAP booklet ( 3 )
for the producer to review at his or her discretion. The
treatment and control implementations were compared for the resulting changes in farm practices that
might avoid antibiotic residue in bulk tank milk.
Three to 5 mo after the initial implementation, all
farms were revisited by the field representatives, and
the risk assessment tool was used to reevaluate the
management practices on the farm. Because the
project was over, the results of this final evaluation
were shared with each producer, regardless of group,
at this visit. All completed risk assessment tools were
returned to the project coordinators for data entry
and summary.

Research Design

Field Representative Training

The project was designed as a clinical trial with

treatment and control farms. On treatment farms,
field representatives and the producer jointly used
the risk assessment tool to identify specific risks and
then to develop a plan to avoid risks that were
specific to that farm. The field representative and
producer surveyed the farm using the risk assessment
tool, discussed the results of the survey and the risks
associated with certain practices (emphasizing high
risk areas identified by the assessment), and formulated a risk abatement plan that was specific to that
herd. The important aspects of the treatment implementation were the joint agreement by the
producer and the field representative on the results of
the survey and the development of a plan that addressed one or two of the identified deficiencies. The
development of a herd plan was facilitated using a
summary form filled out jointly by the field representative and the producer (Figure 2).

All participating field representatives were involved in 2-d training sessions on the purpose of the
project, the need for consistency and neutrality in the
implementation, and the nature of risk. The training
sessions were a combination of lectures on project
protocol, discussion groups, trial use and peer critique
of the risk assessment tool, on-farm visits to use the
tool, and clarification and standardization of the use
of the tool.
Program Evaluation and
Data Analysis
The program was evaluated in five stages: 1 ) input
of field representatives on the risk assessment tool
and the training program, which was obtained after
the training session using a focus group format; 2 )
farm implementation, which was evaluated and summarized in writing by the field representative; 3 )
Journal of Dairy Science Vol. 80, No. 4, 1997

780

SISCHO ET AL.

quantitative program effectiveness, which was evaluated by comparing changes in on-farm risk between
the first and second visits; 4 ) focus group discussions
of producers for subjective evaluation of the value of
the program, which was conducted following the final
farm visit; and 5 ) focus group discussions of the field
representatives to reflect on their role in the program,
which was also conducted following the final farm
visit.
Design and implementation of focus groups were
based on the methods described by Merton et al. ( 1 1 )
and Kruger ( 9 ) . The focus group meetings were held
in two different locations, and all field representatives
were invited. Nonparticipants were invited to complete a mail questionnaire that was designed and
implemented using the methods described by Dillman

( 5 ) . This report presents only the results from evaluations 3 and 5, which are those related to program
effectiveness and the use of the risk assessment tool.
For quantitative analysis, the outcome of interest
was the change in practices on the farm to avoid
antibiotic residues as surveyed between the first and
second visits. This change was measured as both the
absolute and relative difference in risk points between the two visits. A statistical model described the
relative change in risk as a function of treatment
group, field representative, and milk receiver and was
developed using analysis of covariance ( 8 ) .
For the analysis of qualitative data, the outcomes
of interest were effect on treatment and control farms,
the use of the risk assessment tool to discuss dairy
quality, and the perceived reaction of the producer to

Figure 1. Example of the format used for the risk assessment tool. Answers within squares receive Risk Points.
Journal of Dairy Science Vol. 80, No. 4, 1997

781

OUR INDUSTRY TODAY

the risk assessment tool. The focus group discussions

were taped, and the tapes were transcribed. The transcripts were abstracted, and the comments were organized to represent the array of positions about each
of the four evaluation topics.
RESULTS
A total of 25 field representatives from four milk
receivers covering seven states (Pennsylvania, New
Jersey, Delaware, Maryland, West Virginia, Ohio,
and New York) participated in the project. These
field representatives each recruited 10 producers for a
total of 250 producers. The training sessions for the
field representatives occurred during the first 2 wk of
January 1993, and the first farm visits commenced by
the end of January.
Final herd visits were completed by mid-April; a
total of 23 field representatives completed both farm
visits and returned a complete set of risk assessments, which resulted in complete information from
219 operations. Three focus groups for producers were
scheduled between April 6 and 16, and two focus
groups for field representatives were scheduled in late
June. Representatives who were unable to attend the

June meetings were mailed a questionnaire in July.

All data used in the analysis was received by October
1993.
Demographics of Participating Producers
Demographics of the participating producers are
presented in Table 2. The vast majority of producers
were herd owners (89%) and were male (96%). Approximately 75% of the producers were <50 yr of age,
74% were high school graduates, and 22% had either
attended or graduated from college. Mean milk
production was 26.1 kg/d per cow; median production
was 27.3 kg/d per cow. Production ranged from 37.3 to
13.2 kg/d per cow. Sixty-two percent of the participating producers reported that they previously either
had had an antibiotic residue violation or had
dumped bulk tank milk because of antibiotics.
On-Farm Practices to Prevent
Antibiotic Residues
First visit. The risk assessment tool was designed
to weight management deficiencies differentially as
greater or lesser risks that might result in accidental

Figure 2. The form used to develop a focused, on-farm risk reduction plan for dairy operators in the treatment groups.
Journal of Dairy Science Vol. 80, No. 4, 1997

782

SISCHO ET AL.

TABLE 2. Descriptive information from 250 dairy producers in

seven states involved in the risk assessment project.1
Producer
Currently participating in DHIA testing
Role on farm
Herdsperson
Herd manager
Owner
Unknown
Gender
Male
Female
Unknown
Age, yr
<20
2034
3549
5064
6584
Educational background
Attended grade school
Attended high school
High school graduate
Technical school
Attended college
College graduate
Unknown
Antibiotic residue in bulk milk
Mean milk production, kg/d per cow
Standard deviation of milk production
1Not

(no.)
169

(%)
68

15
13
220
2

6
5
88
1

239
10
1

96
4
0

1
90
106
51
2

0
36
42
20
1

23
26
128
16
19
36
2
154
26.1
4.3

9
10
51
6
8
14
1
62

all producers answered each question.

antibiotic residues in bulk milk (Table 1). This

process was expected to force the highly weighted
management areas to be considered as the high risk
areas; however, data for the actual observed risks for
the 250 operations at the first visit were not completely parallel to those of the weighting scheme (Table 3). On the first visit, poor treatment records and
communication was by far the most commonly observed and greatest risk factor of on-farm management. Of the 250 farms (treatment and control) involved in the initial evaluation, 133 (53.2%; 95% CI;
46.8 to 59.5%) had deficiencies in this area. Of the
risks observed, 50% of the farms had no written
records, had more than two people milking cows, or
had part-time milkers (Table 4). On 12% of the
farms, not all milkers could recognize a treated cow.
Of the farms that had written records, only 40% of
those records included the name of the drug used,
only 37% included the time that milk was withheld,
and only 17% included the name of an appropriate
milk screening test.
Of the remaining risk areas evaluated on the first
visit, the most common deficiencies were understandJournal of Dairy Science Vol. 80, No. 4, 1997

ing antibiotic use, relationships between veterinarians and clients, use of cowside screening tests, and
identification of treated cows. Overall, mean values
for initial total risk were similar for treatment (54.2)
and control (57.7) groups, and both groups had similar risk profiles (Table 3).
Changes between first and second visits. The
same risk areas that appeared to be important during
the first visits were also important during the second
visits, but fewer farms (44.7%; 95% CI, 38.0 to
51.6%) reported treatment records and communication as the most important risk. There was also some
change in the order of identified risks on the farms
(Table 5). Twenty fewer treatment farms and 15
fewer control farms reported that treatment records
and communication was the greatest risk factor. The
biggest change occurred in the number of farms that
kept written records. During the first visit, 50% of the
farms had no written record of treatments. By the
second visit, <34% of the farms had no written
records. The improvement was slightly better for
treatment farms than for control farms. The quality of
the records also improved between the first and second visits. More records included the name of the
antibiotic used and its labeled withholding time (Table 4).
The mean risk during the second visit was 43.4
points for treatment farms compared with 46.2 points
for the control farms. On average, the treatment and
control farms decreased the risk between the two
visits by approximately 11 points, which represented
a 19% decrease in risk for both groups. The treatment
farms decreased fairly evenly ( 9 to 11%) in four
areas: 1 ) treatment records and communication, 2 )
understanding antibiotic use, 3 ) antibiotic residue
tests, and 4 ) identification of treated cows. The control farms decreased the risk of understanding antibiotic use by 19% and also decreased the risk of poor
veterinary and client relationships (13%) and identification of treated cows (12%) (Table 6).
Influences on changing risk. Least squares
analysis of covariance of the relative change in risk
for the occurrence of an antibiotic residue is shown in
Table 7. Seven variables were assessed in the model:
1 ) the risk assessment treatment, 2 ) age of the
producer, 3 ) previous history of antibiotic residues in
the bulk tank, 4 ) educational background of the
producer, 5 ) milk receiver field representative working with the producer, 6 ) importance of antibiotic
residues, and 7 ) producer assessment of his or her
likelihood of violation because of antibiotic residues.
Interactions between field representatives and group
were also assessed in the model.

783

OUR INDUSTRY TODAY

TABLE 3. Results of a risk assessment survey from 250 farms located in seven states taken during the initial visit showing the five most
commonly reported risk areas on all participating farms.
Median
observed
risk points

Dairy farm
Total farms
assessed

Risk area
Treatment records and communication
Understanding how to use antibiotics
Relationships between
veterinarians and clients
Use of cowside screening tests
on the farm
Identification of treated cows

95% CI1

Trt2

Control

Maximum
observed
risk points

Minimum
observed
risk points

Trt

Control

Trt

Control

Trt

Control

(no.)

(%)3

133

53.2

46.859.5

68

65

12

12

29

30

45

18.0

13.423.4

21

24

19

20

39

15.6

11.320.7

16

23

16

20

36
29

14.4
11.6

10.319.4
7.916.2

20
14

16
15

8
5

7
5

17
20

17
20

2
0

1
0

(no.)

195%

exact binomial confidence interval for the percentage.

farms.
3Total percentage is >100% because some farms identified more than one risk area as the greatest.
2Treatment

The relative change in risk was influenced by two

variables, field representative and antibiotic residue.
Success of field representatives in influencing change
varied widely. The least squares means for relative
difference in risk for the 23 field representatives
ranged from 0.37 to 0.12. Least squares mean was
<0 for 19 of the 23 representatives, suggesting that

the majority of the representatives influenced

producers to decrease their risk. Box and whisker
plots that demonstrate the variation of representative
influence on the outcome are shown in Figure 3.
The second most important variable affecting risk
outcome was antibiotic residues. Participants who
had no history of antibiotic residues demonstrated a

TABLE 4. Results of a risk assessment survey from 250 farms located in seven states taken during the
initial visit showing the five most commonly reported risk areas on these farms.
First visit
Trt1

Risk area

Control

Second visit
Trt

Control

(no.)
Treatment records and communication
No written treatment records
All milkers would recognize a treated cow
More than two people milking
Part-time milkers on the farm
Records include name of drug used
Records include milk withholding time
Understanding how to use antibiotics
Agree that increasing the dose will increase
the withholding time
Belief that labeled dose is only a guideline
Only one person treats cows
Use of cowside screening tests on the farm
Have screened milk from a cow for antibiotics
in previous 12 mo
Milk cows that have been treated last
Use separate milking equipment for treated cows
Identification of treated cows
Had treated a cow with antibiotics in previous 90 d
Treated cows were visibly marked
1Treatment

65
110
64
66
49
44

62
112
59
61
49
49

33
105
51
46
70
71

41
107
49
46
56
66

110
49
69

105
64
67

107
47
76

106
47
69

93
65
40

91
67
34

90
58
52

88
62
40

119
95

112
87

100
89

100
90

farms.
Journal of Dairy Science Vol. 80, No. 4, 1997

784

SISCHO ET AL.

TABLE 5. Results of a risk assessment survey from 219 farms in seven states taken during the second visit showing the five most
commonly reported risk areas on all participating farms.

Risk area
Treatment records and
communication
Understanding how to use
antibiotics
Relationships between
veterinarians and clients
Use of cowside screening
tests on the farm
Identification of treated cows

Total farms
assessed

Median
observed
risk points

Dairy farms
95%

CI1

Trt2

Control

Maximum
observed
risk points

Minimum
observed
risk points

Trt

Control

Trt

Control

Trt

Control

(no.)

(%)3

98

45

38.051.6

48

50

28

25

45

21

15.426.5

25

20

19

19

36

16

11.822.0

21

15

18

20

49
18

22
8

17.028.5
4.912.7

24
9

25
11

6
5

6
5

16
20

15
20

0
0

0
0

(no.)

1The

95% exact binomial confidence interval for the percentage.

farms.
3Total percentage is >100% because some farms identified more than one risk area as the greatest.
2Treatment

greater mean decrease in risk (0.135) between the

two visits than did producers who had a history of
antibiotic residues (0.077).
Qualitative Evaluation
of the Risk Assessment Process
Ten of the 23 field representatives attended one of
the focus group evaluations. Most field representatives thought that the implementation of the risk
assessment program did result in altered practices,
particularly in the identified high risk areas. The
field representatives generally thought that the program, as presented to the producers in the control
group, did not result in much change, although some
of the control producers did initiate programs to develop records and to mark treated cows. As a communication device, the risk assessment tool was seen as

a valuable means to discuss antibiotic residues and to

develop a dialogue between the field representatives
and producers in a nonregulatory setting. Negative
comments regarding the participation in the project
were few and mostly revolved around the extra work
load and the need to engage veterinarians in the
process. Several of the representatives thought that
veterinarians needed to be more responsible for
residue programs.
DISCUSSION
The risk assessment tool was designed to complement the MDBQAP by helping producers to identify
specific risk practices and to focus educational and
management efforts. The weighting scale of the
categories was based on objective and subjective deficiencies on the farm. Under this scheme, the category

TABLE 6. Mean absolute change (MAC) and mean relative change (MRC) in risk between first and second visits for risk assessment.1
Herd
All

Treatment

Control

Risk area

MAC

MRC

MAC

MRC

MAC

MRC

Overall change in risk

Treatment records and communication
Understanding how to use antibiotics
Relationships between veterinarians and clients
Use of cowside screening tests on the farm
Identification of treated cows

(points)
11.19
3.27
1.69
1.44
1.24
1.54

(%)
19
7
14
5
8
12

(points)
10.9
3.98
1.53
0.96
1.24
1.59

(%)
19
9
9
2
9
11

(points)
11.48
2.55
1.85
1.91
1.25
1.5

(%)
18
4
19
13
8
12

1Data are shown for 219 herds and are reported as MAC and MRC for the treatment group ( n = 110), the controls ( n = 109), and for
both groups combined.

Journal of Dairy Science Vol. 80, No. 4, 1997

OUR INDUSTRY TODAY

785

Figure 3. Box and whisker plots of the influence of field representatives on relative on-farm antibiotic risk reduction on treatment and
control farms between first and second visits.

with the most substantial risk for antibiotic residue

was poor treatment records and communication, followed by relationships among the veterinarian, client,
and patient; understanding the use of antibiotics; and
identification of treated cows.
By far the most common risk assessed on all farms
during the first visit was keeping treatment records.
More than 50% of all farms at the start of the project
did not keep a written record of treatments. Drug
labeling was a primary on-farm risk on <1% of the
farms, which was not surprising because the regulatory penalty for a producer and a veterinarian for
improper labeling of antibiotics is high. Both the
veterinarian and, in particular, the milk receiver
representative have a great deal of expertise and
knowledge in labeling regulation. In addition, the
dairy industry has put great emphasis on ensuring
proper labeling of antibiotics on the farm.
Overall, the treatment and control groups had
similar risk profiles and practices at the beginning of
the project, indicating that the allocation process used
to assign farms to treatment and control groups was
successful. The exception was in the area of understanding drug use. More control farms (64 of 125)
than treatment farms (49 of 125) thought that labels
on antibiotics were only a guideline for use of the
drugs (Table 4).

The primary goal of the project was to test the

hypothesis that identification of on-farm risk and
follow-up visits to focus educational efforts to reduce
the risk of antibiotic residue would be more effective
than risk assessment with only a generalized approach toward risk reduction as in the MDBQAP
booklet ( 3 ) . The educational effort tested was identification of the primary risk of the farm, focused
discussion between the educator and producer on the
identified risk, and development of a plan to alleviate
that risk. Three to 5 mo after the initial visit, all
farms showed a mean decrease in the risk for antibiotic residue of 19% (Table 6). Proportionately fewer
farms identified treatment records and identification
of treated cows as their primary risks, and the number of producers that identified on-farm screening for
antibiotics as their primary risk increased proportionately.
No difference was detected in the relative overall
change in risk between treatment and control operations. In both groups, the number of farms that identified treatment records as their primary risk
decreased. Producers in the treatment group were
more likely to keep a complete written record of treatment. The producers on the control farms improved
relatively more in regard to understanding the use of
antibiotics, particularly in that labels on antibiotics
are more than just guidelines.
Journal of Dairy Science Vol. 80, No. 4, 1997

786

SISCHO ET AL.
TABLE 7. Least squares analysis of covariance model assessing influences on the relative change in
risk for the occurrence of an antibiotic residue.
Source

df

SS

MS

Model1
Error
Group2
Age3
Antibiotic residue4
Residue issue5
Field representative
Education6
Likelihood of violation7

30
189
1
2
1
1
22
2
1

2.501
8.238
0.000
0.052
0.128
0.001
1.964
0.015
0.006

0.083
0.043
0.000
0.026
0.128
0.001
0.089
0.008
0.006

1.91

0.0050

0.0
0.60
2.94
0.01
2.05
0.18
0.14

0.98
0.55
0.08
0.90
0.005
0.838
0.704

1R2

= 0.232941; relative difference of the mean = 0.187.

assessment treatment groups: field representative developed plan or did not develop a plan.
3Age categories for producers: 35 yr of age, 35 to 50, and >50.
4Producers history of at least one antibiotic residue in bulk tank milk: yes or no.
5Producers belief that antibiotic use is an important issue to the dairy industry: yes or no.
6Producers educational background: grade school, high school, or college background.
7Producers belief that she or he will have an antibiotic residue in the coming year: not likely or
likely.
2Risk

Three important observations emerged from the

multivariate analysis of factors associated with the
relative change between the first and second visits.
First, as observed in the bivariate analysis, mean
decrease in the risk for both groups was similar.
Second, the impact of the field representative on effecting change was very important. Third, a history of
antibiotic residues in the bulk tank made producers
less likely to change.
The first observation suggests that the use of a risk
assessment tool for antibiotic residues in a nonregulatory setting could result in management change. Following the risk assessment, change occurred, regardless of the extra educational efforts associated with
direct involvement of the producer in the development
of risk reduction plans. Regardless of implementation
following the initial risk assessment, producers
decreased the risk for antibiotic residue. The changes
observed, that is, increased use and quality of records,
would probably not have occurred without producer
participation in the project, although that possibility
could not be specifically evaluated. The response that
we observed for the control farms was likely due to
the Hawthorne effect; that is, the process of completing the risk assessment tool to obtain baseline information resulted in change and demonstrated the effectiveness of the risk assessment tool in focusing
producer attention on risk management practices.
Field representatives, as educators, were influential in decreasing risk. More than 80% of the field
representatives in this project influenced on-farm
management, decreasing the risk of residue in the
Journal of Dairy Science Vol. 80, No. 4, 1997

bulk tank milk. This influence was independent of

whether the farm was in the treatment or control
group and was independent of the use of the risk
assessment tool by the field representatives. The
results of the qualitative evaluations of the program
by the field representatives suggested that the risk
assessment tool gave representatives the opportunity
to focus on residue prevention in their interactions
with the producers. In the focus group evaluations,
many of the field representatives stated that the risk
assessment tool changed the perception of the
producers regarding their own practices, causing
them to be open to suggestions.
Although mean change for risk was not different
between treatment and control farms, the representatives did support the concept of developing an action
plan for the treatment farms on the basis of the risk
assessment. Comments emerging from the focus
groups matched quantitative results that indicated an
improvement of the records kept on treatment farms.
The third observation was that producers who
reported a history of antibiotics in their bulk tank did
not decrease their risk as much as those who did not
report such a history, which provides a challenge to
the dairy industry. The data from our study suggest
that the group that might need the most help (i.e.,
producers whose own management system has already been shown to be flawed) might be the most
resistant to adapting measures that would avoid
residue. This group of producers represented >60% of
our sample and suggests that extra efforts are necessary to move the whole industry toward decreased

787

OUR INDUSTRY TODAY

antibiotic residues. On the positive side, the

producers who have been successful in avoiding antibiotic residues responded well to the risk assessment approach and implemented management
change aimed at prevention.
CONCLUSIONS
In our study, the producers and field representatives from milk receivers identified a lack of adequate
on-farm treatment records for antibiotic residues as
the highest risk factor, followed by deficiencies in
understanding how to use antibiotics, the relationship
between veterinarian and client, on-farm use of antibiotic residue tests, and identification of treated
cows. When field representatives jointly utilized an
interactive risk assessment tool with their producers,
most producers responded by decreasing risk by approximately 19%. In particular, more farms kept written records or kept more complete records than previously. The field representatives were effective in their
role as educators and as agents of change, promoting
a reduction in the risk for antibiotic residues. The
dairy industry should take advantage of the opportunity to use on-farm representatives to implement
residue reduction programs. Field representatives can
effectively introduce residue programs and build
teams of producers and veterinarians to implement
them. Finally, in our study, producers with reported
histories of antibiotics in the bulk tank were less
likely to implement management changes to reduce
risk of an antibiotic residue. This group of producers
should be targeted to encourage change, which would
likely entail time with the individual producer to
introduce programs, followed by specific on-farm
visits to encourage continued participation.

ACKNOWLEDGMENTS
The authors thank the 25 field representatives who
devoted their time and effort to make this project a
success. This material was based on work supported
in part by the Extension Service, United States
Department of Agriculture, under special project
number 92-EFSQ-1-4064 and material support from
Atlantic Dairy, Hershey Milk, Eastern Milk
Producers, and Milk Marketing Inc.
REFERENCES
1 Anonymous. 1989. Grade A Pasteurized Milk Ordinance. US
Dep. Health Human Serv., Publ. Health Serv., FDA, Washington, DC.
2 Bauman, H. E. 1974. The HACCP concept and microbiological
hazard categories. Food Technol. 28:30.
3 Boeckman, S., and K. R. Carlson. 1992. Milk and Dairy Beef
Residue Prevention Protocol, 1993 Producer Manual. AgriEducation Inc., Stratford, IA.
4 Cullor, J. S. 1995. Implementing the HACCP program on your
clients dairies. Vet. Med. 90:290.
5 Dillman, D. 1978. Mail and Telephone Surveys, the Total Design Method. John Wiley and Sons, New York, NY.
6 Herrick, J. B. 1991. Milk quality assurance and dairy practitioners. JAVMA 199:1268.
7 Kaneene, J. B., and A. S. Ahl. 1987. Drug residues in dairy
cattle industry: epidemiological evaluation of factors influencing their occurrence. J. Dairy Sci. 70:2176.
8 Kleinbaum, D. G., L. L. Kupper, and K. E. Muller. 1988. Applied Regression Analysis and Other Multivariable Methods.
2nd ed. PWS-Kent, Boston, MA.
9 Krueger, R. A. 1988. Focus groups: A Practical Guide for Applied Research. Sage Publ. Inc., Newbury Park, NJ.
10 McEwen, S. A., W. D. Black, and A. H. Meek. 1991. Antibiotic
residue prevention methods, farm management, and occurrence
of antibiotic residues in milk. J. Dairy Sci. 74:2128.
11 Merton, R. K., M. Fisk, and P. L. Kendall. 1956. The Focused
Interview: A Manual of Problem and Procedures. The Free
Press, Glencoe, IL.
12 Van Dresser, W. R., and J. R. Wilcke. 1989. Drug residues in
food animals. JAVMA 194:1700.

Journal of Dairy Science Vol. 80, No. 4, 1997