Industry-Led Dairy Welfare Programs: How Legitimate Are They?

In Canada and the U.S., dairy cows aren’t protected by strong farmed animal welfare legislation. Instead, the dairy industries in both countries have created their own animal welfare programs. These programs set standards for how cows should be housed, handled, and cared for, and they use audits to check whether farms are following the rules. This study aimed to analyze their legitimacy using a framework focused on three key areas:

1. Input legitimacy: Who sets the standards?
2. Throughput legitimacy: How accountable, transparent, and inclusive is the process?
3. Output legitimacy: How well do the standards work in practice?

How The Programs Work

In both countries, the dairy welfare program includes national standards and a system for implementing and assessing them on farm. In Canada, these are accomplished by separate organizations. The National Farm Animal Care Council coordinates and publishes the Code of Practice for the Care and Handling of Dairy Cattle (the “Dairy Code”), while the proAction program, which translates the Dairy Code’s requirements into auditable farm-level criteria, is run by Dairy Farmers of Canada, an industry group.

In the U.S., the Farmers Assuring Responsible Management (FARM) program develops and enforces national standards, and is run by two trade associations, the National Milk Producers Federation and Dairy Management Inc.

Methods

Instead of collecting data on farms, the researchers analyzed publicly available documents from each program between 2023 and 2024. They searched the National Farm Animal Care Council, Dairy Farmers of Canada, and FARM program websites. From these searches, the researchers collected items like annual reports, standards manuals, committee lists, public comment summaries, and videos explaining the programs. They then coded these materials for themes according to their legitimacy framework, such as who sits on committees, how public input is handled, how audits work, and what information is shared with the public.

Who Sets The Standards?

Both systems are weighted toward dairy farmers and industry representatives in decision-making. In Canada, the Dairy Code committee includes farmers, processors, veterinarians, scientists, government officials, industry representatives, program implementation experts, and a representative from an animal welfare organization. However, dairy farmers still hold a large share of seats, and the final proAction program is approved solely by the Dairy Farmers of Canada Board of Directors.

In the U.S., the FARM program’s committees and board are similarly dominated by farmers and dairy co-operatives. Non-farmer members are usually veterinarians, animal scientists, or processors, who usually have close ties to the dairy industry.

This strong farmer presence can help ensure that standards are practical for farms. However, it also raises concerns that other viewpoints, such as animal welfare groups, small-scale or marginalized farmers, and the general public, may be underrepresented.

Who Gets To Participate?

Both systems allow some public participation through surveys and comment periods. The pre-development survey for the most recent Dairy Code, which gathered input before the standards were drafted, received comments from a wide range of stakeholders, including the general public (44%), consumers (39%), animal welfare advocates 37%), and dairy producers (21%). This suggests that the Canadian system has been relatively successful at inviting broader participation. In contrast, the FARM program’s most recent pre-development survey was dominated by industry voices: most responses came from farmers (63%), processors (16%), and veterinarians (12%). Very few respondents — just 1.5% — were consumers or members of the public.

Public comment periods, which allow people to comment on a draft of the standards before they’re finalized and published, also appear to be more accessible in Canada. The most recent public comment period on the Dairy Code received 45,470 comments compared to just 308 for the FARM program, despite the fact that the U.S. population is 10 times bigger than Canada’s. However, neither system makes individual comments publicly available — they’re only reported in summary form.

How Transparent and Accountable Are The Programs?

The researchers found that both systems share some information with the public, such as who sits on their committees and how the programs are structured. The FARM program publishes regular annual reports, and proAction has shared at least some general audit results in the past.

However, transparency is limited when it comes to outcomes. For proAction, there’s been little public reporting of audit results since 2017. The FARM program reports more outcome data, such as how many farms had to correct problems, but still doesn’t provide detailed farm-level information.

Both programs use on-farm audits and can, in theory, penalize farmers who fail to meet the standards, including removing their licence (in Canada) or blocking them from selling milk (in the U.S.). But because so little information is public, it’s difficult to know how often serious problems are found, how quickly they are fixed, and whether penalties are consistently enforced.

Another concern is auditor independence. Many auditors are closely tied to the industry — for example, dairy co-operative staff or organizations that already work with farms. Truly independent third-party audits are absent in the Canadian system and rare in the U.S. system, conducted on just a sample of farms. This can weaken trust in the results.

Do The Standards Actually Protect Cows?

To illustrate how well industry standards line up with the latest animal welfare science, the researchers focused on three important requirements for dairy calves.

• Housing calves together is better for their welfare. The Dairy Code is phasing in this requirement for calves housed indoors, while the FARM program has no such requirement.
• Restricted milk feeding leaves calves hungry and limits their growth. The Dairy Code specifies a volume that must be fed to calves. The FARM program requires feeding to maintain calf “health, growth, and vigor” but doesn’t indicate a volume.
• Dehorning calves is painful. The Dairy Code requires the use of both a local anesthetic and an analgesic, while the FARM program only recommends this.

So, overall, the Canadian system appears to cover these issues more thoroughly than the U.S. system.

Both systems use a mix of animal-based measures (e.g., body condition or lameness scores), resource-based measures (e.g., bedding or space requirements), and management-based measures (e.g., pain control protocols). However, relying on written protocols to evaluate compliance may be problematic, as research suggests that some farmers create these documents mainly to satisfy program rules, not necessarily to guide daily practice. This makes it difficult to know whether industry standards are truly improving cows’ lives.

What This Means For Advocates

The researchers conclude that industry-led dairy welfare programs in Canada and the U.S. have both strengths and weaknesses. On the positive side, they have very high participation from farmers (around 98% in the U.S. and 100% in Canada), some scientific grounding, and at least basic systems for audits and penalties.

However, serious concerns about legitimacy remain, including:

• Farmer and industry dominance in decision-making
• Limited transparency about audit results and enforcement
• Unclear levels of real-world improvement of animal welfare
• Low public trust, especially when compared to government laws or independent third-party certification

For animal advocates, this study suggests that industry standards alone aren’t enough to ensure adequate welfare on dairy farms. Advocates may want to push for more diverse representation on committees, stronger independent auditing, detailed public reporting of outcomes — and in the long term, stronger legal protections that don’t depend on the dairy industry policing itself.