Harmful bacterial toxins can occur in dairy products if a processing facility takes a misstep at any number of critical junctures in the leadup to selling its goods to consumers.

Accordingly, quality control procedures have to be exceptional when processing milk and manufacturing various dairy products.

With the appropriate measures in place, and persistent commitment to following them, companies can avoid the potential food safety hazards along the dairy supply chain.

Best practices

Bob Salter, vice president of regulatory affairs and business development for Charm Sciences, Inc., Lawrence, Mass., said dairy processing facilities must address quality control and toxicology for their products on a number of fronts.

“The most important best practices are to establish a food safety plan, including product analysis, work flow and a risk assessment with preventative controls,” Salter explained. “The preventative controls should be designed to reduce or eliminate any perceived microbiological, chemical and physical hazards.”

Furthermore, dealing with plans and controls can’t be limited to specific areas or teams within a plant.

“This should be a top-down effort involving all employees, so they are trained and knowledgeable about preventative controls, their purpose and how the controls were established,” Salter advised.

A principal scientist for chemical regulation and food safety at Atlanta-based Exponent, Craig Llewellyn, Ph.D., also emphasized the need for “strong,” “strictly followed” and documented food safety plans. For dairy processors, Llewellyn pointed out, the long-established Hazard Analysis Critical Control Point (HACCP) food safety management system has to be at the foundation of what they do.

“However, possibly the most important part of food safety and quality efforts are prerequisite programs anchored by strong, science-based ingredient specifications,” Llewellyn said.

Prerequisite programs inside a facility can account for potential issues such as allergen controls, employee hygiene, ingredient traceability and other similar factors.

“[Facilities need] a risk-based program to verify that ingredients and other components of a supply chain comply with designated food safety and quality requirements and meet or exceed regulations,” Llewellyn said.

He said possessing an in-depth understanding of the food safety and quality aspects of every dairy ingredient that passes through a facility is also crucial. Plus, expertise in that area should assist in preventing food safety and quality issues within the supply chain, such as economically motivated adulteration – intentionally leaving out, taking out or substituting a valuable ingredient or part of a food, or adding a substance to make a food appear better or of greater value.

A dairy specialist for the Michigan State University Product Center, East Lansing, Mich., Farida Adam said some of the most important practices at dairy processing facilities include the use of an allergen program for storing and processing raw ingredients. Adam also pointed out that various inclusions for products may contain allergens from different sources.

Additionally, Adam recommended a “robust” sanitation program, noting that “microbial hazards or significant amounts of chemical residues may end up in product from improper cleaning procedures.”

Other key elements, Adam said, include personnel training, environmental testing and swabbing, separating raw ingredients from finished products, linear processing to limit cross-contamination, and making use of a one-way process flow to help limit cross-contamination before and during processing.


People problems

Challenges are to be expected when dealing with quality control and toxicology at a dairy processing facility. And oftentimes those obstacles are directly related to the people who help make the operation function.

“Employee turnover and retirements of legacy employees are some of the biggest challenges,” Salter warned. “It is important to pass on the plant operation and product knowledge through training and mentorship.”

Along those lines, Llewellyn identified human factors and errors as a common problem when striving for perfection.

“A company can have the most appropriate food safety and quality programs in place, but if each worker does not follow them every time, the programs fail,” he said. “If one link fails, the entire chain fails.”

When issues do pop up, Adam said it’s not uncommon for personnel matters to have played a part. Sometimes simple miscommunication is to blame.

The viability of a facility’s plans and procedures also depends on the experts who work there.

Said Salter: “Another challenge is performing a continual review of the food safety plan and updating it with new arising risks that might not have been considered up until now.”

More recent food processing risks, Salter noted, include PFAS contamination from water or packaging materials, and cronobacter microbiological concerns in raw materials.

Similarly, Adam said the specificity of certain toxins may present challenges when adhering to safety protocols.


High standards

Properly managing the products can be tricky, too. Llewellyn said the fragility of the food safety and quality aspects can be accompanied by specific challenges.

“Dairy-based ingredients can come from raw materials sourced from all over the country, or world, and generally are not necessarily limited by environmental restrictions such as those that only allow certain crops to be grown in certain environmental conditions,” Llewellyn explained. “These different conditions can present specific challenges not faced by other supply chains.”

Even if a stop along the supply chain is near a processing facility, maintaining the safety of ingredients requires diligence. And that’s because raw milk is the primary ingredient in any product coming out of a facility.

“Because of its biological nature, specific steps are required to keep [raw milk] safe,” Adam said. “For example, milk must be cooled immediately after cows are milked to reduce microbial proliferation. Milk must also be pasteurized before being used in manufacturing.”

Those inherent characteristics of dairy products, though, have made the dairy industry a “high quality model” for the food industry overall, Salter said.

Dairy processors must maintain the voluntary standards that were agreed upon with the US Food and Drug Administration (FDA) as part of the Pasteurized Milk Ordinance, which calls for dairy facilities and personnel to be audited more frequently than other food manufacturers.

“They have required training dates in order to perform functions in the plant,” Salter added. “The controls in place are generally more strict than the rest of the food industry. Sometimes controls are very prescriptive – for example, requiring antibiotic screening of all incoming milk tanks as they enter dairies and requiring a negative before they can be unloaded.”

When Salter thinks about facilities with effective quality control and toxicology programs in place, he said they exemplify being clean “top to bottom” and well maintained.

“They have long shelf lives to the products produced, and their products meet those shelf life dates,” Salter added. “They have employees that understand the details of the processes and the quality and toxicology controls in place.”

Likewise, Adam said successful facilities utilize regulated temperature control, good sanitation measures, effective detection and monitoring procedures, and expertise in dealing with both common and unfamiliar issues.

As one would expect, strong and strictly implemented food safety and quality programs are vital for a first-class operation. Llewellyn said that requires investing in internal and/or external resources. He also identified other necessities, such as a “deep understanding” of food science, food safety and quality hazards and risks, as well as key aspects of ingredients procurement, and risk-based supply chain verification programs.

“As food safety information should not be seen as competitive, having an external presence in trade associations and professional groups helps to keep organizations at the cutting edge of effective food safety and quality programs,” Llewellyn said.


Extra scrutiny

Critical observation is expected in dairy production, particularly in terms of monitoring quality control and toxicology. Still, some products are associated with especially shrewd examination.

“Any products that are fed to newborns and infants or to [older adults] and immune compromised require the highest scrutiny,” Salter said. “Formula, powdered milk and ice cream are just a few.”

Adam suggested yogurts and cheeses require vigilant monitoring, as well.

“Cultured products may need special attention because of the risks of toxin production if the products are not stored under optimum aging or ripening conditions,” Adam said. “The presence of phage may also cause fermentation failures that may allow the growth of pathogenic microbes.”

Furthermore, Llewellyn advised, because each step along the supply chain is important for dairy products – including food contact and packaging components – a high level of risk-based scrutiny is required for every variety of product.

“Because dairy products can contain ingredients that may be sourced from all over the country and world, no one dairy product should be viewed as requiring more scrutiny than another,” Llewellyn said. “Food safety and quality programs should be viewed as equal for all dairy products.”