Standard 4.2.4 is implemented by State Regulatory Authorities, namely Dairy Food Safety Victoria, New South Wales Food Authority, Safe Food Production Queensland, Dairy Authority South Australia, Tasmanian Dairy Industry Authority, and Department of Health in Western Australia.
“Thus, it’s a national standard implemented through state jurisdictions,” Dornom elaborates. “This comprehensive domestic dairy food safety regulatory framework is the key underpinning element of the dairy food safety risk management system, which also includes industry codes of practice and guidelines.”
Additionally, those dairy businesses wishing to export must comply with the requirements of the Commonwealth Department of Agriculture’s (DoA) Export Control (Milk and Milk Product) Orders 2005.
Every dairy farm supplying a milk manufacturer/processor must be licensed and, under the FSANZ Primary Production and Processing Standard (4.2.4), have a validated and documented food safety plan (FSP) approved by the relevant State Regulatory Authority in place. An audit is conducted every two years in Victoria and annually in other states, to monitor compliance.
“New South Wales and Queensland use monitoring systems against an agreed set of performance indicators as an alternative to audit,” Dornom says. “The auditors undertaking these on-farm compliance audits are approved by the State Regulatory Authorities and must have National Food Safety Auditor Competencies. What’s more, the State Regulatory Authorities also undertake verification audits and system reviews of dairy farms to check that the compliance audits/monitoring systems are being undertaken appropriately and systems are operating effectively.”
National auditor meetings are held approximately every six months (with flexibility in the schedule) to review any issues arising around the states and seek to ensure national consistency with implementing the audits and interpreting the FSP requirements, Dornom adds.
“Any dairy farm that does not comply with its food safety plan is issued with non-conformances and if not resolved, the State Regulatory Authority may revoke the farm license so that it cannot produce milk for sale,” Dornom explains.
On-farm quality assurance programs all contain the same essential food safety elements, she continues. “The core elements that must be addressed in on-farm food safety programs under FSANZ Standard 4.2.4 include agricultural chemicals, veterinary medicines, pest control, stock feed, water quality, hygienic milking, water supply and quality, cleaning and sanitizing, traceability and records, and skills and knowledge,” she points out.
Likewise, under FSANZ Standard 4.2.4, every dairy manufacturing and processing establishment must have validated, documented and approved food safety program in place that must cover the following core elements: pathogen reduction technologies (including pasteurization), temperature controls, processing, cleaning and sanitizing (including chemicals to be used), storage, traceability through distribution, post-pasteurization hazard management, post-pasteurization raw material and ingredient management, traceability, records, and personnel competency.
“The State Regulatory Authorities are responsible for approving the dairy plants’ FSPs and verifying compliance with the plans,” Dornom notes. “Dairy companies are audited against their FSPs by approved auditors as per the National Food Safety Auditor Protocol. Export listed establishments are also audited against their approved arrangements, as well.”
This approach to whole chain food safety reflects international requirements under Codex (Code of Hygienic Practice for Milk and Milk Products), national requirements by FSANZ, and state-based legislation that adopts the FSANZ Requirements.
“In addition to complying with food safety requirements, all dairy farmers must adhere to all legislative requirements, including areas such as animal welfare, chemical contamination, and environmental responsibilities,’ Dornom says. ”Dairy company on-farm QA programs may also contain market specific requirements.”
There are currently no specific issues relating to Australian dairy food safety, Dornom says. “However, we operate in a global market, so when there is an issue questioning dairy food safety in any market, because Australia exports approximately 40 percent of its dairy production, dairy companies are asked to demonstrate why buyers of Australian dairy products need not be concerned about the overseas issue with respect to Australian product,” she relates. “The legislated underpinning of food safety and the company QA programs provide evidence, which is supported by such things as company product testing in accredited laboratories and other monitoring programs like the Australian Milk Residue Analysis survey.”
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