Public Health Risk Management

Introduction

Public Health and the Dairy IndustryWhilst most of the key public health outcomes relevant to the dairy industry are achieved through food safety regulation and related programs, it is important to consider the dairy industry’s contribution to zoonotic disease management and the dairy contribution to nutritional public health benefits. This risk management framework focuses on these issues.

Dairy products are an important component of a healthy diet and the dairy industry is proud to contribute to public health from the nutritional perspective. The industry has a strategic priority i to “proactively promote and protect dairy’s value and integrity” which incorporates programs to enhance the acceptance and uptake of dairy foods by consumers, as well as to manage the risks to public health that are inherent along the dairy supply chain (Dairy Australia). Much of the public health debate in the dairy industry centres on the consumption of unpasteurised milk (refer to the section below regarding “Dairy Product Related Food Borne Illness”).

Australia has a comprehensive range of public health risk management arrangements to protect the health of the general public. These are augmented by specific statutory requirements and targeted programs to address particular risks within industries. Each State has some form of dairy regulatory legislation or scheme that supplements the Australia New Zealand Food Standards Code (Food Standards Code). These regulatory arrangements, along with the Food Standards Code and guidelines and manuals, help to assure a safe supply of milk and milk products in Australia. Additionally, the Export Control Orders help to assure the safe supply of food to the international markets.

The risks posed to public health from dairy cattle zoonoses are small and are generally confined to people working in the industry in close contact with cattle on farms. For example, on average, 5% of dairy workers in Queensland’s Atherton Tablelands are diagnosed with leptospirosis every year (Source: Queensland Health Leptospirosis Guidelines). Dairy farmers have a responsibility to ensure that workers know about zoonoses such as leptospirosis, and how to reduce the risk of contracting such diseases. “Leptospirosis is a disease caused by the spirochaete, Leptospira spp, and is characterised by fever and myalgia in humans. Transmission can occur through urine contaminated water and hay being ingested, inhaled or absorbed through the skin and eyes. People at risk from leptospirosis include abattoir workers, dairy farmers, cattle farmers, veterinarians, piggery workers, cane farmers, and banana growers. Nationally, 176 notifications of leptospirosis were received during 2004 where at least 6% of cases are known to have occurred in dairy industry workers”. (Source: “National Farm Injury Data Centre 2006. Occupational Health & Safety Risk in the Australian Dairy Industry. The Facts, 2006. Australian Centre for Agricultural Health and Safety”: Moree).

It is estimated that the Australian dairy industry involves around 100,000 people through farming (9,266 farms employing about 50,000 people), services to farming (an estimated10,000 people), manufacturing (estimated at up to 30,000 people), transport and research activities. Over half (52%) of Australia’s dairy farm businesses rely solely on family labour (Dairy Australia, 2005).

Australia has a very safe supply of milk and dairy products based upon existing standards in the Australia New Zealand Food Standards Code and Australia’s ‘paddock to plate’ approach to food safety regulationii. The Australia New Zealand Food Standards Code requires that all milk for human consumption in Australia must be either pasteurised or treated by an equivalent heat treatment system to ensure public health and safety. As a result, the risk to the general public from milk-borne zoonotic agents is effectively eliminated. The focus of attention is on protecting the health of the people who work and live on the estimated 7,500 dairy farms around the country.

The Food Standards Code specifies controls to manage potential microbiological hazards in dairy products, which include food-borne zoonotic disease agents. The National Dairy Standard 4.2.4 specifically requires that the processing of milk and dairy products includes pasteurisation or an equivalent process to eliminate any pathogenic micro-organisms that may have been present in the incoming milk. Specifically, Standard 4.2.4 requires milk to be heat treated to the equivalent of 72°C

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for 15 seconds or more if the milk solids content is greater than normal milk. Milk must be cooled after the heat treatment to minimise the growth of pathogenic micro-organisms. Cheese can be made from milk with a lower heat treatment but must be held for 90 days or more. Regulators and industry have prepared guidelines for the validation and verification of heat treatment equipment and processes.

The risk management systems in place to address the risks to public health posed by diseases that can be passed from animals to humans (zoonoses) are covered in this document. The risk management systems for other risks to public health, including food safety, occupational health and safety, animal health, and biosecurity are the focus of separate related documents within the Risk Visualisation Tool.

The Dairy Risk ProfileAs part of the Food Standards Australia New Zealand (FSANZ) standard development framework for Proposal P296, the National Dairy Primary Production and Processing Standard (later to be gazetted as Standard 4.2.4 of the Food Standards Code), a scientific assessment “ A Risk Profile of Dairy Products in Australia”(the Dairy Risk Profile), was undertaken within the context of the national food safety regulatory framework (refer to Dairy Food Safety Risk Management Systems document for details of the national regulatory system). The Risk Profile examined both microbiological and chemical risks for the dairy sector.

“With regard to microbiological hazards, the Risk Profile considered the:• Identification and description of microorganisms that may be associated with dairy products including key attributes of each organism and its public health impact;• Examination of epidemiological data (domestic and international) related to the consumption of dairy products;• Examination of prevalence and concentration data on potential hazards from products along the entire dairy food chain; and• Description of the dairy production, processing, distribution and consumption chain and current knowledge of the impact of each of these on public health and safety risks.

The examination of chemical hazards considered:• Agricultural and veterinary chemicals used in primary production;• Environmental contaminants, including heavy metals, organic contaminants and micronutrients;• Natural chemicals found in plants, fungi or bacteria associated with plants;• Food processing by-products;• Food additives, processing aids and those chemicals that may migrate from packaging.”

Dairy Risk Profile Key FindingsThe FSANZ Risk Profile determined that “the current management practices in place within the Australian dairy industry support the production of dairy products with a high standard of public health and safety. The key findings include:• Consumption of dairy products is rarely linked to food-borne illness in Australia.• A wide range of microbiological hazards may be associated with raw milk and dairy products, but these do not represent a problem under current management practices which:

- control animal health;- ensure adherence to good milking practices;- require effective heat treatment e.g. pasteurisation; and- have controls to prevent post-pasteurisation contamination in the dairy processing environment.

• There are minimal public health and safety concerns regarding the use or presence of chemicals in dairy products due to the extensive regulatory and non-regulatory measures in place along the dairy industry primary production chain.• Extensive monitoring of chemical residues in milk over many years has demonstrated a high level of compliance with the regulations.”

The outcomes of the Risk Profile demonstrate that the existing regulatory arrangements and industry initiatives that have been implemented are effective in protecting the public health and safety of consumers. The FSANZ Risk Profile concluded that “the factors along the Australian dairy supply chain that have the most significant impact on the safety of processed dairy products are:

the quality of raw materials;

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correct formulation; effective processing (pasteurisation in particular); the prevention of recontamination of a product; and Maintenance of temperature control during distribution, retail sale and storage of the product

in the home.”

Dairy Product Related Food Borne IllnessesFood borne illnesses related to food-handlers is discussed in more detail in the Retail / Markets risk management section. The following is an extract from the Draft Assessment Report for Proposal P296, Primary Production and Processing Standards for Dairy, conducted by Food Standards Australia New Zealand in 2006:

“In Australia, illness from dairy products is generally rare. For example, between 1995 and 2004, there were only eleven reported outbreaks directly attributed to dairy products, eight of which were associated with consumption of unpasteurised milk. In other Australian outbreaks, dairy products were an ingredient of the responsible food vehicle identified as the source of infection. However, dairy products are a component of many foods and it is often difficult to attribute the cause of an outbreak to a particular food ingredient. Microbiological survey data for pasteurised dairy products in Australia show a very low incidence of hazards of public health significance in these products. While commercial dairy products have rarely been identified as sources of food-borne illness in Australia, there have been a number of reports of outbreaks associated with consumption of dairy products internationally. Unpasteurised dairy products are the most common cause of these dairy-associated outbreaks of illness.”

What is Public Health?In 1920 CEA Winslow classically defined public health as "the science and art of preventing disease, prolonging life and promoting health through the organized efforts and informed choices of society, organizations, public and private, communities and individuals"iii. Public health is concerned with threats to the physical and mental health of populations, which arise from many different aspects of living. The term “public health” is often used synonymously with the term “population health”, but public health does not focus on the public health care system alone. Public Health comprises many fields of endeavour.

Under the Australian Constitution (Section 51) States and Territories are responsible for public health, including food safety and standards. The Commonwealth, States and Territories of Australia, together with New Zealand, have come together to create a structure to regulate the food supply. This partnership continues to provide an overarching framework and legal obligations for food businesses to produce food that is safe and suitable for human consumption.

Australia’s health system is world class, supporting universal and affordable access to high quality medical, pharmaceutical and hospital services, while helping people to stay healthy through health promotion and disease prevention activities. The Australian Government has a vision to achieve “better health and active ageing for all Australians”iv and maintaining and improving public health is a high priority for Federal, State and Territory and Local Governments, as well as the community at large. The Australian Government has limited involvement in public health issues, with the States taking a major responsibility for the management of public health and communicable diseases.

Public Health LegislationIn October 1996, Australian Health Ministers agreed to the implementation of the National Public Health Partnership (NPHP) as a working arrangement to plan and co-ordinate public health activities, to provide a more strategic approach to public health activities and implement new national initiatives. One of the key priorities of the NPHP is the review of the public health legislative and regulatory framework. Public health law comprises many issues, including the “core” public health legislation relating to food, drugs, poisons, therapeutics, tobacco and radiation. There are many other pieces of legislation that have a significant impact on public health, such as the Commonwealth Trade Practices Act which includes provisions relating to product safety, liability for defective products, and occupational health and safety. Commonwealth public health legislation does provide the basis for determinants of health and disease.

The aim of public health legislation is to protect and promote the health of the public. State Public Health legislation provides the basic safeguards necessary to protect public health through

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cooperation between Governments, local governments, health care providers, industries and the community. This is achieved by:

preventing, controlling and reducing risks to public health providing for the identification of, and response to, notifiable conditions defining obligations on persons and particular health care facilities involved in the provision of

declared health services to minimise infection risks providing for the notification by doctors and registered nurses of child abuse and neglect, and

protecting children who have been harmed or are at risk of harm when they present at health service facilities

collecting and managing particular health information, and establishing mechanisms for health information held by Government to be accessed for appropriate research

inquiring into serious public health matters responding to public health emergencies providing for compliance with public health legislation to be monitored and enforced.

Risk Management in the Dairy IndustryBased upon risk management and supported by science, the Australian dairy industry has developed quality management systems that underpin the regulatory requirements. The Australian dairy industry works collaboratively with government regulatory agencies and service suppliers to ensure a preventative approach to manage risks across the integrated supply chain. The industry approach is outcome focused, science based, non-prescriptive and proportionate to risk.

The Australian Dairy industry risk management system is an overarching through-chain framework across the integrated risk management systems, including animal health, animal welfare, biosecurity, food safety, public health, environment and occupational health and safety. The objective is to provide a comprehensive and industry-wide approach to address issues that may affect the reputation and future viability of the Australian dairy industry (Dairy Australia).

The Australian dairy industry works in a co-regulatory partnership approach to identify any emerging issues and hazards that may represent a risk to or adversely affect the dairy industry and dairy product safety. Through strong international linkages, this ensures the Australian industry is aware of potential issues in other countries and actions being taken by various agencies and scientific researchers to investigate measures to correct or manage the issue. Proactive and reactive measures are undertaken to ensure industry risk management plans remain appropriate for the risk.

The Australian Dairy industry works collaboratively with government regulatory agencies and service suppliers to ensure a preventative approach to risk management across the integrated supply chain or value chain. The Dairy industry has introduced systems that manage the risks associated with dairy production, processing and distribution from pre-farm to the consumer. This through-chain approach incorporates all six sectors, including Pre-Farm, On Farm, Transport, Manufacture / Processing, Distribution and Retail.

The Australian dairy industry has developed quality management systems that underpin the regulatory requirements to control and mange identified risks. The various “controls” across the dairy risk management framework have been categorised into the following broad groupings:

Regulatory Systems, National and International Standards, Traceability and Verification Systems, Market Forces, and Industry and Commercial Programs.

The Dairy Supply ChainThe typical dairy supply chain is characterised by milk being produced at the dairy farm then being sold and transported to the manufacturer of milk products. The milk is then distributed as drinking milk or other milk products through distributors and retailers to the end consumers. However, there are many exceptions to this basic process where the dairy farmers process their own milk or manufacturers produce the milk at their own dairy farm. The distribution structure also varies depending on the size and scale of the operation.

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Food Security / BioterrorismFood security and bioterrorism preparedness and planning is co-ordinated at an across government level through the Commonwealth Department of Agriculture (DoA), the Department of Health and Ageing, and State and Territory Departments of Premier and Cabinet through the inter-government “Trusted Information Sharing Network” Project.

In addition, some State and Territory governments have enacted specific sub-ordinate legislation pursuant to their Food Act legislation to deal with suspected intentional or deliberate contamination of food. This legislation has been used in recent times to deal with criminal extortion cases involving food contamination.

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Pre-Farm Risk Management Framework

IntroductionProducing milk requires a range of pre-farm inputs, including feed, livestock, fertiliser, chemicals, water, skilled labour and other resources. The industry sees each of these inputs as essential to ensuring public health, food safety and product integrity along the supply chain, so the potential risks are identified and controlled by a range of standards and systems operating well before the inputs reach the dairy farm.

Farm Inputs – Regulatory SystemFood standards are enforced on farm predominately by State Dairy Food Authorities (SDFAs) / State Regulatory Authorities (SRAs) in conjunction with State Health Departments and local government. The Commonwealth Department of Agriculture (DoA) have arrangements in place with SRAs for the enforcement of standards for exported dairy products. DoA may inspect or check test imported foods for compliance with Australian Standards. From farm to product storage, all dairy businesses must be licensed. Individual Food Safety Programs for farms are approved by SRAs before licences are granted and compliance is monitored through regular audits. It is important to note that SDFAs/SRAs utilise a range of regulatory tools designed to encourage compliance with the legislation and do not solely rely upon food safety programs and audits as the sole method of verification and enforcement. An annual verification program is conducted.

State Departments of Primary Industries / Agriculture enforce regulations for use of chemicals on farms, animal welfare, control of animal disease and biosecurity including traceability. The relevant State Veterinary Practitioners Registration Board registers veterinarians for clinical practice. State Environmental Protection Authorities (SEPAs) monitor the environment including water and air quality for conformance with regulatory requirements.

Australian dairy food safety programs are based on the international standards established by Codex alimentarius. While food safety programs are based on risk assessment and management principles, there is also an emphasis on their practical application. Industry quality assurance programs have been recognised as covering both food safety and quality elements. On-farm dairy food quality assurance programs cover the same essential elements. These elements were agreed between the dairy industry and government several years ago. The core food safety elements of the programs are:- The management of physical, chemical and microbiological contaminants,- Standards in dairy milking premises, - Standards of hygienic milking practices,- Water supply and quality, - Cleaning and sanitising procedures,- Traceability and record maintenance, and - The competency of staff who are responsible for milking and the operation of the food safety

program on the farm.

Farm Inputs - StandardsDivision 2 of the national Dairy Standard 4.2.4 specifies the specific on farm primary production requirements, including a mandatory food safety program. A dairy primary production business must control its potential food safety hazards by implementing a documented food safety program. The control measures must manage the hazards arising from

(a) Inputs;(b) The design, construction, maintenance and operation of premises and equipment;(c) Milking animals;(d) Persons involved in milking; and(e) Milking practices.

The control measures must also –(a) Include support programs that ensure that premises and equipment are clean and sanitary and that pests are controlled; and(b) Ensure that milk is cooled and stored at a temperature that prevents or reduces the growth of microbiological hazards in the milk; and(c) Ensure that milk for human consumption is only sourced from healthy animals.

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As part of the documented food safety program, a dairy primary production business must have a system that enables the tracing of –

(a) Inputs; and(b) Animals to be milked; and(c) The milk produced.

Farm Inputs – Traceability & VerificationTraceability is the cornerstone of modern food safety. The Australian primary production and processing sectors utilise a traceability approach, whereas the food service/food distribution sectors utilise a recall approach. The Australian Dairy industry has chosen to adopt a one up / one back system of traceability that identifies the immediate supplier and immediate recipient of dairy products.

Clause 5 of Division 2 of the national Dairy Standard 4.2.4 specifies that as part of the documented food safety program, a dairy primary production business (i.e. a dairy farm) must have a system that enables the tracing of

(a) Inputs; and(b) Animals to be milked; and(c) The milk produced.

Farm Inputs – Market ForcesAustralian dairy manufacturers work closely with domestic and international customers to ensure safe and consistent quality dairy products are supplied year around. FSANZ is the key authority for development of national food standards and codes for practice for products destined for the domestic market and imported dairy products. State Health Departments implement the standards at state level. DA plays an important role in interpreting and negotiating the market access requirements of importing countries. The regulatory framework for dairy products sold within Australia and overseas is harmonised wherever possible. Federal and state government agencies work closely with industry to provide safe dairy products for both Australian and international customers.

The relationship between Australian dairy companies and their domestic and international markets has been developed over years through close communication with customers and consistent delivery of safe quality dairy products. Retail or ingredient customers within Australia and overseas apply rigorous buying specifications. Typical buying specifications include product specification, transport conditions and the buyers’ expectations of the quality assurance approach. Many customers audit their suppliers on a regular basis. Competent authorities within Federal and State regulatory agencies underpin the national approach to food safety and quality.

Farmer to Manufacturer CommunicationIf farmers have concerns about the quality of milk, they will contact the company to discuss the concerns. The company will arrange for an investigation to take place and for testing to be conducted before the milk is cleared as suitable for collection. The manufacturer provides fast feedback to farmers on quality tests conducted by the manufacturer. If urgent corrective action is required, electronic communication is used or the farmer contacted personally. Company field service officers may work with the farmer to identify suitable corrective action.

Farm Inputs – Industry / Commercial ProgramsA range of programs from government/industry agencies supports the dairy industry food safety regulatory approach. Some of these programs include the National Livestock Identification System (NLIS) and Feedsafe and Foddercare programs operating in the fodder industries. All dairy farmers are accredited under the beef industry food safety program (Livestock Production Assurance – LPA). This program covers the food safety elements of on farm meat production. National and regional extension programs have been developed by the dairy industry to support the farm sector. Some areas covered by these programs include:

• Mastitis prevention and treatment - Countdown Downunder• Animal fertility - Incalf• Use of grains as supplementary feed - Grains2Milk• increasing efficiency of milk harvesting - Cowtime• handling of animals to minimise stress and injury• Australian Breeding Values (ABV) genetic selection of bulls for ease of calving, fertility, mastitis resistance and survivability,

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• Design of milking sheds, laneways and stockyards• Environmental issues – DairySAT, DairyGains

The dairy industry directly supports the various State Governments’ dairy extension activities, which focus mainly on business productivity and environmental aspects of dairy farming. Dairy Australia has established the National Centre for Dairy Education Australia (NCDEA) to develop and deliver vocational education and training for all sectors of the dairy industry. In conjunction with Dairy Food Safety Victoria, food safety programs have also been developed for the manufacturing sector. There are many supporting programs underpinning dairy food safety. The programs listed above provide examples of programs but this is not an exhaustive list.

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On Farm Risk Management Framework

IntroductionDairy farms in Australia are primarily pasture-based with conserved fodders, grains and prepared stock-foods used as supplementary feed. The Australian dairy industry is based on the production from two million dairy cattle located across six Australian States, with approximately 8,000 farms producing about 9.4 billion litres of milk (as at 2008/09). Australia is among the world’s four largest exporters of dairy products.

The greatest dairy industry risks to public health are arguably found at the farm level. Although the Australian dairy herd is largely managed extensively, people working and living around dairy farms will be exposed to a range of public health hazards. Dairy farms are generally set up and managed to reduce these risks. However specific zoonoses still require attention and physical hazards to farm workers are also of concern. The management of these risks is undertaken by individuals within a comprehensive framework of statutory controls and industry supports. The risk management systems that address zoonoses are described below whilst the systems managing occupational health and safety (OH&S) and food safety are described in related documents within the Risk Visualisation Tool.

Zoonotic Disease ControlsAustralian cattle are free of many of the agents that cause serious zoonoses (such as bovine brucellosis and bovine tuberculosis) in other parts of the world (refer to the Animal Health risk management document). However there are still organisms found on most dairy farms that have the potential to cause disease in humans in some circumstances. Zoonotic diseases associated with Australian dairy cattle can be contracted from contact with: animal wastes; the improper handling of infected animal products; the handling of infected animals; contact with their blood, saliva, milk and urine; and the inhalation of airborne dust. People in close contact with dairy cattle are at risk but fortunately illnesses are fairly rare.

The major zoonotic agents associated with dairy cattle in Australia include: certain bacteria (e.g. Leptospira spp, Listeria spp, Salmonella spp, Campylobacter spp, and

E. coli); viral diseases (e.g.Rotavirus, Coronavirus); parasites (e.g. Cryptosporidia spp and trematodes); and Rickettsial diseases, such as Q fever.

Very occasionally other zoonotic diseases associated with cattle are diagnosed in humans including tapeworms (Taenia saginata), Toxoplasma spp., and cutaneous anthrax. Most dairy farms have systems in place to minimise the risks from these diseases. Common risk management activities include:

identifying, treating and/or removing infected animals from the herd; vaccinating cattle for leptospirosis to eliminate carriers; managing effluent and waste; establishing splash guards in the dairy; providing protective clothing; controlling pests such as flies and rodents; providing washing up facilities and disinfectant to clean up after handling cattle; providing separate areas for eating and drinking; and managing feed sources (e.g. to manage sources of Aflatoxin contamination)...

Employers are required by State and Territory lawv to take reasonable steps to protect the health of their employees, including from zoonoses. Employees also have responsibilities to work safely and maintain a safe working environment. These laws are strictly enforced by State and Territory regulators, with farms being a particular focus for compliance activities. Guidance material specific to dairy farm risks is also available from these agencies.

Dairy Australia provides farmers with information about how they can comply with the law through the The People in Dairy program. The industry also engages in industry awareness activities and supports formal training for farm workers through the National Centre for Dairy Education Australia.

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Cattle can also suffer illness from zoonotic agents. Australia has a comprehensive risk management system to manage the health of Australian dairy cattle. Identifying, treating and/or removing infected stock helps reduce the risks to humans. This is particularly relevant to diseases that are spread by contaminating the environment, such as Salmonella. Animal health risk management systems are described in a separate document.

Controls over communicable diseases can also be applied through State and Territory law. However, because they are generally isolated incidents, Government health officers rarely become involved in controlling zoonotic disease issues associated with the dairy industry. Surveillance statistics on some of the more important zoonoses in Australia are collected from doctors and laboratories and then collated by the Australian Government Department of Health and Ageing in a database – the National Notifiable Disease Surveillance System (NNDSS ). Particular zoonoses are also reported in the Animal Health Disease Surveillance Quarterly Reports on the Animal Health Australia website.

Dairy Farm Food Safety ProgramsUnder the FSANZ Food Standards Code (FSC) Standard 4.2.4 all dairy farms are legally are required to develop and implement a documented Food Safety Program (FSP). Core elements of the FSP include:

• Control of contaminants – physical, chemical and microbiological• Dairy milking premises• Hygienic milking• Water supply and quality• Cleaning and sanitising• Traceability and records• Personnel competency

State Dairy Food Authorities / SRAs approve the FSP before a dairy farm licence or accreditation is granted. Approved auditors conduct regular audits of the farm FSP. Other forms of verification are also used including SRA monitoring farm test and performance data.

All animals are individually identified from birth to death. Farmers actively monitor the health and welfare of animals with the assistance of registered veterinarians. Vendor declarations are required for animals and stockfeed purchased from external sources. Risks from agricultural and veterinary chemicals are minimised by ensuring that only chemicals registered by the Australian Pesticide and Veterinary Medicines Authority are used on the farm. Label instructions for use and withholding periods for milk and meat are followed. Records document the frequency and duration of use. Trained operators use clean and sanitised equipment to milk cows. The milk is cooled promptly and stored until collection, at temperatures to minimise the growth of microbial hazards. These food safety programs are validated by SRAs before dairy farm licences are issued. Approved auditors conduct regular audits. Approval of auditors follows the National Food Safety Audit Policy requirements.

Risks from agricultural chemicals in feed and water are minimised by the use of chemicals registered by the APVMA with farmers following directions for use and required withholding periods for milk and meat. The farmer records the frequency and duration of use of chemicals. Vendor declarations are required for feed sourced from external sources. The health and welfare of the animals is paramount to ensure optimal production. Although most dairy cattle are bred on the farm, all livestock must be individually identified from birth to death to ensure lifetime traceability. In consultation with registered veterinarians, farmers actively monitor and treat diseases as required. Treated animals must be clearly identified to ensure segregation of unsuitable milk. Vendor declarations are required when animals are sold off farm or purchased from external sources.

All antibiotics and most other veterinary chemicals are only available by prescription through registered veterinarians. Farmers must use veterinary medicines in accordance with label directions, observe recommended withholding periods for milk and meat and keep records of all treatments. Government controls diseases of regional significance through a range of legislated programmes under the Livestock Disease Control legislation. Welfare standards for animals are legislated by each State. To support farmers with the management of mastitis, reproduction and animal welfare, the Australian dairy industry has developed and conducts numerous extension programs that address animal health and welfare e.g. Countdown DownUnder , Incalf and CowTime .

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A range of industry and regulatory agencies monitor the safety and quality of milk and dairy products through the supply chain. These include dairy companies, regulatory groups such as the Australian Milk Residue Analysis Survey, federal and state regulatory agencies, SRAs, SDPIs and EPAs. The Australian Milk Residue Analysis (AMRA) Survey is an important measure in monitoring the safety of milk. State Departments of Health monitor the safety of food at retail level and during the distribution of product following manufacture.

Verification of food safety programs is critical to the integrity of the Australian co-regulatory system. It is undertaken to ensure that control measures are working. Increasingly, verification is achieved through regular auditing by companies, regulatory authorities or other third parties such as suppliers and customers. Companies conduct audits at a frequency determined in the documented business plan. Company staff usually performs these through monitoring and record keeping in an internal verification process.

Regulatory authorities conduct audits to verify that establishments are operating food safety programs satisfactorily. This ensures that:

- Monitoring records are up to date and correct- Corrective actions are taken in a timely manner and resolved- Calibration criteria are met- Testing results are available and within specification- Changes to systems, procedures, and processes are actioned appropriately.

Auditing is conducted by qualified, competent and accredited auditors directly employed by government or increasingly by auditors approved by the regulatory authority who operate under contract. Where this latter system is operating, regulatory authorities randomly check the contract audit system. The audit system is again supported by a regulatory system operating in all Australian States and Territories. It is supported by legislative powers designed to protect public health. The scope of the audits is extensive with a focus on the food safety system, including audit standards and auditor competencies and skills rather than traditional inspection.

Monitoring and Surveillance ProgramsThe Australian Milk Residue Analysis (AMRA) Survey plays an important role in the Australian dairy industry by gathering and compiling information on the chemical residue status of Australian milk. This helps to verify that the quality assurance measures in place are managing potential food safety risks. The purpose of the AMRA Survey is to provide a credible, independent, national monitoring system for potential agricultural and veterinary chemical residues, and environmental contaminants in Australian bovine milk. The program provides an assurance that the dairy product export requirements of DoA are being met. Dairy Food Safety Victoria (DFSV), in co-operation with Dairy Australia and the Department of Agriculture (DoA), currently coordinates the Survey.

The AMRA Survey is risk-based in its design and reflective of agricultural practices in the Australian dairy industry. Sampling is predominantly random selection. However, historical patterns of agricultural chemical and veterinary drug usage, as well as other relevant factors, are taken into consideration. In addition to random sampling, targeted sampling is conducted when new residue risks are identified, or to collect data on potential emerging residue risks. The European Union (EU) residue monitoring directives are used to provide a framework for the Survey. Samples for the Survey are taken from bulk milk farm pick-up tankers. State dairy authorities/SRAs are responsible for investigating any samples with a positive antimicrobial or aflatoxin test result, or pesticide and anthelmintic residues detected at 50% or greater than the Maximum Residue Limits (MRLs). Similarly, residues of environmental contaminants are investigated when detected at 50% or greater than the maximum allowable level. All results are reported against the limits or levels established by FSANZ which are published in the Food Standards Code.

The AMRA Program routinely includes the testing of milk for the presence of aflatoxin M1 residues. Agricultural and veterinary chemicals, and extraneous environmental contaminants included for analysis in the AMRA survey have established upper limits (Maximum Residue Limits or Extraneous Residue Limits) in the FSANZ Food Standards Code (Standard 1.4.2), and it is these limits that provide the trigger points upon which various regulatory actions may be taken if residues are identified. Aflatoxin M1 on the other hand, is regulated via Standard 1.4.1 – Contaminants and Natural Toxicants. In this standard, FSANZ has only established maximum limits (MLs) for those

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contaminant / commodity combinations where it serves an effective risk management function, and only for those foods which provide a significant contribution to the total dietary exposure. Foods not listed may contain low levels of contaminants or natural toxicants. No ML is established for aflatoxin M1 in milk as it presents a low public health risk. Regardless of whether or not a ML exists, the levels of contaminants and natural toxicants in all foods should be kept ‘As Low As Reasonably Achievable’ (the ALARA principle). MLs are set at levels that are consistent with public health and safety and that are reasonably achievable from sound production and natural resource management practices. Australia’s and New Zealand’s international trade obligations are also taken into consideration.

Animal HealthRefer to the related Animal Health document for a detailed discussion of the animal health risk management framework. The Commonwealth Department of Agriculture (DoA) is responsible for biosecurity of livestock imported into Australia. The Animal Health Committee (AHC) develops national approaches to the prevention and control of disease in the livestock industry. The national approaches are implemented by State Departments of Primary Industries/Agriculture (SDPI) in conjunction with Animal Health Australia. On farms, the health of animals is monitored closely. Sick animals are segregated from the main herd. Registered veterinarians diagnose and advise on appropriate treatment. The veterinarian is required to advise the SDPIs if a notifiable disease is diagnosed.

Control of Pathogens - Farm levelFood Safety Programs (FSPs) include measures to ensure the health of milking animals. Sick animals are separated from the herd during treatment. Cows with mastitis are clearly identified when treated and the milk is withheld from the farm bulk milk. Water supplies are monitored to ensure they are clean and will not spread disease. Milking equipment is cleaned and sanitised after each milking.

Milking Practices, Harvesting, Storage / Cleaning – Regulatory SystemSkilled staff on farm use modern machine milking techniques and practices to ensure that cows are milked hygienically with minimal stress. The cows are usually milked twice a day. Colostrum is segregated from the main milk supply. Milking equipment is cleaned and sanitised ready for the next milking using detergents and sanitisers registered by the APVMA. The quality of water used in the dairy is monitored to ensure it does not have the potential to contaminate milk. Trained technicians supply and maintain milking equipment. The milking shed and holding yards are designed and constructed to minimise animal stress and injury and for the ease of cleaning. Effluent is disposed carefully to minimise pollution of the environment, the farm and surrounding water supplies.

Food standards are enforced on farm predominately by State Dairy Food Authorities / SRAs in conjunction with State Health Departments and local government. DoA has arrangements in place with SRAs for the enforcement of standards for exported dairy products. DoA may inspect or check test imported foods for compliance with Australian Standards. From farm to product storage, all dairy businesses must be licensed or accredited. Individual Food Safety Programs for farms are approved by SRAs before licences are granted and compliance is monitored through regular audits. Other forms of verification are also used including SRA monitoring farm test and performance data. An annual verification program is conducted.

State Departments of Primary Industries / Agriculture enforce regulations for use of chemicals on farms, animal welfare, control of animal disease and biosecurity including traceability. The relevant State Veterinary Practitioners Registration Board registers veterinarians for clinical practice. State Environmental Protection Authorities monitor the environment including water and air supplies for conformance with regulatory requirements.

Food safety programs are based on the international standards established by Codex alimentarius. While food safety programs are based on sound risk assessment and management principles, there is also an emphasis on their practical application. Industry quality assurance programs have been recognised as covering both food safety and quality elements. On-farm dairy food quality assurance programs cover the same essential elements. These elements were agreed between the dairy industry and government several years ago. The core food safety elements of the programs are:- The management of physical, chemical and microbiological contaminants,- Standards in dairy milking premises, - Standards of hygienic milking practices,

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- Water supply and quality, - Cleaning and sanitising procedures,- Traceability and record maintenance, and - The competency of staff who are responsible for milking and the operation of the food safety

program on the farm.

Milking Practices, Harvesting, Storage / Cleaning - StandardsDivision 2 of the national Dairy Standard 4.2.4 specifies the specific on farm primary production requirements, including a mandatory food safety program. A dairy primary production business must control its potential food safety hazards by implementing a documented food safety program. The control measures must manage the hazards arising from

(a) Inputs;(b) The design, construction, maintenance and operation of premises and equipment;(c) Milking animals;(d) Persons involved in milking; and(e) Milking practices.

The control measures must also –(a) Include support programs that ensure that premises and equipment are clean and sanitary and that pests are controlled; and(b) Ensure that milk is cooled and stored at a temperature that prevents or reduces the growth of microbiological hazards in the milk; and(c) Ensure that milk for human consumption is only sourced from healthy animals.

As part of the documented food safety program, a dairy primary production business must have a system that enables the tracing of –

(a) Inputs; and(b) Animals to be milked; and(c) The milk produced.

Milking Practices, Harvesting, Storage / Cleaning – Traceability & VerificationTraceability is the cornerstone of modern food safety. The Australian primary production and processing sectors utilise a traceability approach, whereas the food service/food distribution sectors utilise a recall approach. The Australian Dairy industry has chosen to adopt a one up / one back system of traceability that identifies the immediate supplier and immediate recipient of dairy products.

Clause 5 of Division 2 of the national Dairy Standard 4.2.4 specifies that as part of the documented food safety program, a dairy primary production business (i.e. a dairy farm) must have a system that enables the tracing of –

(a) Inputs; and(b) Animals to be milked; and(c) The milk produced.

Milking Practices, Harvesting, Storage / Cleaning – Market ForcesAustralian dairy manufacturers work closely with domestic and international customers to ensure safe and consistent quality dairy products are supplied year around. FSANZ is the key authority for development of national food standards and codes for practice for products destined for the domestic market and imported dairy products. State Health Departments implement the Standards at state level. DA plays an important role in interpreting and negotiating the market access requirements of importing countries. The regulatory framework for dairy products sold within Australia and overseas is harmonised wherever possible. Federal and state government agencies work closely with industry to provide safe dairy products for both Australian and international customers.

The relationship between Australian dairy companies and their domestic and international markets has been developed over years through close communication with customers and consistent delivery of safe quality dairy products. Retail or ingredient customers within Australia and overseas apply rigorous buying specifications. Typical buying specifications include product specification, transport conditions and the buyers’ expectations of the quality assurance approach. Many customers audit their suppliers on a regular basis. Competent authorities within Federal and State regulatory agencies underpin the national approach to food safety and quality.

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Farmer to Manufacturer CommunicationIf farmers have concerns about the quality of milk, they will contact the company to discuss the concerns. The company will arrange for an investigation to take place and for testing to be conducted before the milk is cleared as suitable for collection. The manufacturer provides fast feedback to farmers on quality tests conducted by the manufacturer. If urgent corrective action is required, electronic communication is used or the farmer contacted personally. Company field service officers may work with the farmer to identify suitable corrective action.

Milking Practices, Harvesting, Storage / Cleaning – Industry / Commercial ProgramsA range of programs from government / industry agencies supports the dairy industry food safety regulatory approach. Some of these programs include the National Livestock Identification System (NLIS) and Feedsafe and Foddercare programs operating in the fodder industries. All dairy farmers are accredited under the beef industry food safety program (Livestock Production Assurance – LPA). This program covers the food safety elements of on farm meat production. National and regional extension programs have been developed by the dairy industry to support the farm sector. Some areas covered by these programs include:

• Mastitis prevention and treatment - Countdown Downunder• Animal fertility - Incalf• Use of grains as supplementary feed - Grains2Milk• Increasing efficiency of milk harvesting - Cowtime• Handling of animals to minimise stress and injury• Australian Breeding Values (ABV) genetic selection of bulls for ease of calving, fertility, mastitis resistance and survivability,• Design of milking sheds, laneways and stockyards• Environmental issues – DairySAT, DairyGains

The dairy industry directly supports the various State Governments’ dairy extension activities, which focus mainly on business productivity and environmental aspects of dairy farming. Dairy Australia has established the National Centre for Dairy Education Australia (NCDEA) to develop and deliver vocational education and training for all sectors of the dairy industry. In conjunction with Dairy Food Safety Victoria, food safety programs have also been developed for the manufacturing sector. There are many supporting programs underpinning dairy food safety. The programs listed above provide examples of programs but this is not an exhaustive list.

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Transport Risk Management Framework

IntroductionManaging the bulk milk collection and transport from Australia’s 8,000 dairy farms is critical to ensure a high quality safe and hygienic product. All milk transport operators must have an approved Food Safety Program and/or be licensed / inspected by the State Dairy Food Authority (SDFA) / State Regulatory Authority (SRA), or have their program integrated as a part of the dairy manufacturer’s approved FSP. In some States this process is managed through the Dairy processors and these records are audited when the Dairy processor is audited to verify compliance with legislative requirements.

Milk transport operators must have an approved Food Safety Program. The temperature and time of transport is managed to minimise potential food safety risks. Core elements of the bulk milk transport FSP include:

Control of food safety hazards during collection and transport from equipment, vehicles, containers and personnel

Product traceability Time and temperature controls Personnel skills and knowledge

In peak season, collection usually occurs daily. When production declines, milk collections may reduce to an SDFA / SRA approved frequency. Prior to milk collection at the farm, tanker drivers sample milk for testing by the company. Typical tests include fat, protein, somatic cell count, microbiological quality and antibiotic residues. The results of the tests are provided to the farmer and used as a basis for payment. If an abnormal result is detected, such as positive antibiotic residue detection or high somatic cell count, the farmer is promptly notified of the result and appropriate action is taken. Prior to unloading at the factory, the manufacturer may check the milk for quality.

Typical tests include antibiotic residues and temperature. If a positive residue result is detected, trace-back testing is performed on individual milk samples from each farm supplier so corrective action can be taken. The temperature of milk or product and time of transport is controlled to minimise potential hazards.

Tankers are cleaned using Cleaning-in-Place (CIP) systems with approved chemicals and potable water. Visual inspections of the internal tanker surfaces and swabbing of food contact surfaces may be used to check the effectiveness of cleaning programmes. Information on the origin of and destination of milk supplies is recorded to ensure traceability from farm to manufacturer and from manufacturer to farm if required.

Traceability is the cornerstone of modern food safety. The Australian primary production and processing sectors utilise a traceability approach, whereas the food service/food distribution sectors utilise a recall approach. The Australian Dairy industry has chosen to adopt a one up / one back system of traceability that identifies the immediate supplier and immediate recipient of dairy products.

Division 2 of the national Dairy Standard 4.2.4 specifies that as part of the documented food safety program, a dairy primary production business must have a system that enables the tracing of –

(a) Inputs; and(b) Animals to be milked; and(c) The milk produced.

Clause 9 of the National Primary Production and Processing Standard 4.2.4 provides that a dairy transport business must have a system to identify the immediate supplier and immediate recipient of the dairy product. Food standards are enforced in dairy collection and transport predominately by SDFAs / SRAs in conjunction with State Health Departments and local government. DoA has arrangements in place with SRAs for the enforcement of standards for exported dairy products. DoA may inspect or check test imported foods for compliance with Australian standards. From farm to product storage, all dairy businesses must be licensed. or have their program integrated as a part of the dairy manufacturers approved FSP Individual Food Safety Programs for farms are approved by SRAs before licences are granted and compliance is monitored through regular audits. Other forms of

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verification are also used including SRA monitoring farm test and performance data. An annual verification program is conducted.

State Departments of Primary Industries / Agriculture enforce regulations for use of chemicals on farms, animal welfare, control of animal disease and biosecurity including traceability. The relevant State Veterinary Practitioners Registration Board registers veterinarians for clinical practice. State Environmental Protection Authorities monitor the environment including water and air supplies for conformance with regulatory requirements.

A range of industry and regulatory agencies monitor the safety and quality of milk and dairy products through the supply chain. These include dairy companies, regulatory groups such as the Australian Milk Residue Analysis Survey, federal and state regulatory agencies, SRAs, SDPIs and EPAs. The Australian Milk Residue Analysis (AMRA) Survey is an important measure in monitoring the safety of milk. State Departments of Health monitor the safety of food at retail level and during the distribution of product following manufacture.

Product Tracing – Regulatory SystemMilk transport operators must have an approved Food Safety Program (FSP) and be licensed / inspected by the relevant SDFA / SRA, or have their program integrated as a part of the dairy manufacturers approved FSP. The temperature and time of transport is managed to minimise potential food safety risks. Core elements of the FSP include:

Control of food safety hazards during collection and transport from equipment, vehicles, containers and personnel

Product traceability Time and temperature controls Personnel skills and knowledge

Food standards are enforced in dairy collection and transport predominately by SDFAs / SRAs in conjunction with State Health Departments and local government. DoA has arrangements in place with SRAs for the enforcement of standards for exported dairy products. DoA may inspect or check test imported foods for compliance with Australian Standards. From farm to product storage, all dairy businesses must be licensed or have their program integrated as a part of the dairy manufacturers approved FSP. Individual Food Safety Programs for farms are approved by SRAs before licences are granted and compliance is monitored through regular audits. Other forms of verification are also used including SRA monitoring farm test and performance data. An annual verification program is conducted.

Product Tracing – StandardsDivision 3 of the National Dairy Primary Production and Processing Standard 4.2.4 specifies requirements for dairy collection and transport businesses. The definition of ‘dairy transport business’ establishes the scope of the businesses that must comply with these requirements. Dairy transport businesses include businesses that collect and haul bulk milk from dairy farms to processing facilities or depots, and businesses that transport bulk milk or dairy products such as milk powders or concentrates between processing facilities. The term ‘bulk’ clarifies that the product is not packaged or intended for direct sale (retail or wholesale) and is intended for further processing.

Division 3 of the Standard provides for the following provisions for Dairy collection and transportation:Clause 7 Controlling food safety hazardsClause 8 Specific requirementsClause 9 Product tracingClause 10 Time and temperature controlsClause 11 Skills and knowledge

For Clause 7, the control measures must manage hazards arising from transport vehicles, equipment and containers used in the collection and transport of the milk or dairy product; and persons engaged in the dairy transport business; and must include a support program that ensures that the food contact surfaces of transport vehicles, and equipment and containers used in collecting and transporting of the dairy products are clean and sanitary.

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As part of the documented food safety program, a dairy transport business must have a system to identify the immediate supplier and immediate recipient of the dairy product.

Product Tracing – Traceability & VerificationTraceability is the cornerstone of modern food safety. The Australian primary production and processing sectors utilise a traceability approach, whereas the food service/food distribution sectors utilise a recall approach. The Australian Dairy industry has chosen to adopt a one up / one back system of traceability that identifies the immediate supplier and immediate recipient of dairy products.

Division 2 of the national Dairy Standard 4.2.4 specifies that as part of the documented food safety program, a dairy primary production business must have a system that enables the tracing of –

(a) Inputs; and(b) Animals to be milked; and(c) The milk produced.

Clause 9 of the National Primary Production and Processing Standard 4.2.4 provides that a dairy transport business must have a system to identify the immediate supplier and immediate recipient of the dairy product.

Product Tracing – Market ForcesAustralian dairy manufacturers work closely with domestic and international customers to ensure safe and consistent quality dairy products are supplied year around. FSANZ is the key authority for development of national food standards and codes for practice for products destined for the domestic market and imported dairy products. State Health Departments implement the standards at state level. DA plays an important role in interpreting and negotiating the market access requirements of importing countries. The regulatory framework for dairy products sold within Australia and overseas is harmonised wherever possible. Federal and state government agencies work closely with industry to provide safe dairy products for both Australian and international customers.

The relationship between Australian dairy companies and their domestic and international markets has been developed over years through close communication with customers and consistent delivery of safe quality dairy products. Retail or ingredient customers within Australia and overseas apply rigorous buying specifications. Typical buying specifications include product specification, transport conditions and the buyers’ expectations of the quality assurance approach. Many customers audit their suppliers on a regular basis. Competent authorities within Federal and State regulatory agencies underpin the national approach to food safety and quality.

Product Tracing – Industry & Commercial ProgramsA range of programs from government/industry agencies supports the dairy industry food safety regulatory approach. Some of these programs include the National Livestock Identification System (NLIS) and Feedsafe and Foddercare programs operating in the fodder industries. All dairy farmers are accredited under the beef industry food safety program (Livestock Production Assurance – LPA). This program covers the food safety elements of on farm meat production. National and regional extension programs have been developed by the dairy industry to support the farm sector. Some areas covered by these programs include:

• Mastitis prevention and treatment - Countdown Downunder• Animal fertility - Incalf• Use of grains as supplementary feed - Grains2Milk• Increasing efficiency of milk harvesting - Cowtime• Handling of animals to minimise stress and injury• Australian Breeding Values (ABV) genetic selection of bulls for ease of calving, fertility, mastitis resistance and survivability,• Design of milking sheds, laneways and stockyards• Environmental issues – DairySAT, DairyGains

The dairy industry directly supports the various State Governments’ dairy extension activities, which focus mainly on business productivity and environmental aspects of dairy farming. Dairy Australia has established the National Centre for Dairy Education Australia (NCDEA) to develop and deliver vocational education and training for all sectors of the dairy industry. In conjunction with Dairy Food Safety Victoria, food safety programs have also been developed for the manufacturing sector. There

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are many supporting programs underpinning dairy food safety. The programs listed above provide examples of programs but this is not an exhaustive list.

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Manufacture / Processing Risk Management Framework

IntroductionThe Australia New Zealand Food Standards Code requires that all milk for human consumption in Australia must be either pasteurised or treated by an equivalent heat treatment system to ensure public health and safety. Once delivered to the manufacturer, milk is processed in modern automated factories using responsible food safety, OH&S and environmental practices. The relevant State Dairy Food Authority (SDFA) / State Regulatory Authority (SRA) licenses, inspects and audits all dairy processors.

The relevant SDFA / SRA licenses or accredits all dairy processing factories while factories manufacturing product for export also require Commonwealth Department of Agriculture (DoA) registration. Documented HACCP based food safety plans and quality assurance programs are developed to ensure that consumer needs and specifications, including food safety, are constantly met. The FSP must be approved by SDFAs / SRAs prior to the granting of a licence / accreditation. The core elements of the FSP for manufacturing establishments must include:

pathogen reduction technologies, including pasteurisation temperature controls processing standards cleaning and sanitising storage conditions product traceability forwards and backwards through the supply chain from farm to customer post-pasteurisation hazard management raw material and ingredient management records, and skills and knowledge / personnel competency.

Product specifications reflect compliance with regulatory requirements within the Food Standards Code (FSC) and in the case of exports, the requirements of DoA and the importing country. The dairy collection and transportation section of FSC Standard 4.2.4 also covers food safety requirements for milk and bulk dairy products transferred to other factories for further processing.

All suppliers of ingredients, services and packaging work with dairy companies to ensure their materials and services meet specific requirements, especially with regard to the traceability of materials. Potable quality water is used in processing of milk and dairy products and for cleaning of surfaces in direct contact with product. Rigorous standards exist for the design and construction of factories in order to minimise cross-contamination of the final product from raw materials and the external environment. Storage and processing equipment is constructed to meet manufacturing requirements and to ensure food contact surfaces are clean and hygienic. Approved chemicals are used in cleaning and sanitising processing equipment.

Standard operating procedures are used to train staff and to provide ongoing guidance for the safe manufacture of products. Verification techniques used by dairy companies include:

testing of milk and ingredients measurement of temperature, time and chemical composition calibration of measuring and testing equipment monitoring of the factory environment for contaminants final product testing internal auditing of procedures

Information such as product name, date of production, production plant and packing equipment is used to identify different product batches. Additional information including nutritional and use by information is required for labels of goods sold within Australia and in overseas markets. Under the FSC, all manufacturers are required to have a Product Recall system in place detailing the measures to be taken in the unlikely event of a product recall. The system should comply with the FSANZ Food Industry Recall Protocol. Manufacturers regularly check their ability to trace the movement of product and raw materials forward through the production process and backwards through the supply chain. Training and development of staff in all areas of food safety, quality, environment and occupational

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health and safety is imperative for companies seeking to improve their performance while maintaining compliance.

External auditors approved by regulatory agencies including DoA conduct external audits of the food safety and quality systems of factories. Follow-up audits are conducted if non-compliance is noted. Australian and international customers may also audit all or part of a company’s food safety and quality assurance program. An annual verification program to confirm the implementation of the FSC Standard 4.2.4 across the dairy industry has been implemented by SRAs and DA. In addition, SRAs and other regulatory agencies monitor the quality of milk and dairy products.

The Australian Milk Residue Analysis (AMRA) Survey is an important part of regulatory agency and industry verification processes. Industry guidelines for food safety post-farmgate have been developed through collaboration of SRAs and DA under the Australian Milk Residue Analysis Survey and industry working groups. Examples include Guidelines for Food Safety Validation and Verification of Heat Treatment and Processing Equipment. Dairy manufacturers actively work with State Environmental Protection agencies to reduce the impact of dairy processing on the environment.

Meat ProductionIt is estimated that the Dairy Industry provides approximately 20% of the animals supplied to the meat industry (this consists of bobby calves and culled mature cows), and these animals must comply with the required food standards, including Australian Standard AS4696 (the Australian Standard for the Hygienic Production of Red Meat) and the residue and other standards within the Australia New Zealand Food Standards Code. The National Meat Standard – Standard 4.2.3 of the Food Standards Code – requires a food safety program to be implemented for premises producing ready-to-eat meat. All establishments processing meat for the domestic market must be licensed through the State meat safety regulatory authority and must operate in accordance with the approved food safety program.

Animals leaving the dairy farm are usually transported to an abattoir for slaughter and subsequent processing into meat products. The meat processing industry is very tightly regulated. Traceability of cattle is maintained through individual National Livestock Identification System (NLIS) tags and the NVD/Waybill documentation delivered with the consignment by the transporter. Animal health is monitored during lairage and an assessment of every animal’s suitability for human consumption is made both prior to and after slaughter.

Establishments processing meat for export also require licensing through the Commonwealth Department of Agriculture (DoA) to ensure they comply with the importing country’s requirements. A multi-tiered compliance and verification system is in operation in Australia with compliance to the agreed national Meat Standard AS4696 as Tier 1 of this system. Animal health requirements, including ante-mortem and post-mortem health checks are specified in AS4696. It is a condition of licence that every establishment manages the risks to food safety by implementing a documented food safety program, based on the internationally accepted HACCP approach, an approved Australian Standard or approved Code of Practice. The Food Safety Program must be approved by the State or Territory food safety regulator and is audited based on agreed national minimum frequencies to ensure compliance with appropriate Standards. Inspecting the animals prior to slaughter (ante-mortem inspection) is a requirement under the current Australian Standard.

The meat safety inspector is responsible for ante-mortem inspections and follows procedures set out in the site’s approved food safety plan, if an animal is sick or injured. This includes reporting to State or Territory Animal Health Authorities should a notifiable disease be suspected or identified. Trace back and other investigations can be instigated using the traceability systems provided by the NLIS and NVD/Waybill documentation should it be warranted. Every carcase is also inspected by a meat safety inspector according to a set procedure following slaughter (post-mortem inspection). Carcases exhibiting signs of disease are identified and trace back and other disease control procedures can be instigated should they be warranted.

In addition there are a number of national and State based residue monitoring programs in place conducted by Government and industry which take random samples at specified abattoirs for heavy metals, agricultural and veterinary chemicals and antibiotics. Any residue detection above the level specified in the Australia and New Zealand Food Standards Code (including Generally Expected

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Levels and Maximum Limits) is mandatorily reported to the State Food Authority / licensing authority for investigation and reporting.

Bobby CalvesBobby calves have been identified as posing a particular risk to the dairy meat trade and additional work is being undertaken to strengthen the integrity of the supply chain to protect welfare and address residue risks. As a result, in 2009 Dairy Australia conducted a successful Bobby Calf Supply Chain Integrity Trial to ensure that all calves are managed across the calf supply chain in accordance with agreed industry standards and practices and to ensure that all sectors of the calf supply chain understand their responsibilities and put them into practice to ensure market and community requirements are met. The project objective was to ensure that the whole of supply chain responsibility to manage the risks to welfare and of residues in calves sent to slaughter can be demonstrated as being fulfilled. The trial was based on an enhanced traceability system using electronic data capture for vendor bred calves going direct to slaughter that underpins assurances for fitness of purpose regarding residues and welfare. Systems developed during the trial are currently being implemented, providing rapid feedback from abattoirs to transporters and farmer vendors if the calves do not meet the expected standards. Improved accountability along the supply chain is expected to improve compliance and so improve welfare and food safety outcomes.

Food Safety Hazards – Regulatory SystemFood standards are enforced in the dairy processing and manufacture sector predominately by SDFAs / SRAs in conjunction with State Health Departments and local government. DoA has arrangements in place with SRAs for the enforcement of standards for exported dairy products. DoA may inspect or check test imported foods for compliance with Australian Standards. From farm to product storage, all dairy businesses must be licensed / accredited. Individual Food Safety Programs for dairy processors are approved by SDFAs / SRAs before licences / accreditations are granted and compliance is monitored through regular audits. An annual verification program is conducted.

Auditors approved by regulatory agencies including DoA conduct regular audits of food safety programs through the dairy food supply chain. The audit frequency may be based upon past performance. A national verification program has been implemented to provide market assurance and to monitor compliance with FSC Standard 4.2.4.

All dairy processing companies have internal programs for the regular auditing of their quality management systems and the QA programs of suppliers, including farmers. Many companies, including those with ISO certification, use third party auditors for this role. Dairy company QA programs are frequently audited by major customers from Australia and overseas. These audits may include the farm sector as well as manufacturing, storage and distribution. Regulators from several importing countries conduct compliance audits across the Australian dairy supply chain.

Control of Pathogens - Manufacturer levelFSC Standard 4.2.4 requires milk to be heat treated to the equivalent of 72°C for 15 seconds or more if the milk solids content is greater than normal milk. Milk must be cooled after the heat treatment to minimise the growth of pathogenic micro-organisms. Cheese can be made from milk with a lower heat treatment but must be held for 90 days or more. Regulators and industry have prepared guidelines for the validation and verification of heat treatment equipment and processes.

Food Safety Hazards - StandardsDivision 4 of the National Dairy Primary Production and Processing Standard 4.2.4 specifies requirements for dairy processing and manufacture. Division 4 of the Standard provides for the following provisions for dairy processing:

Clause 12 ApplicationClause 13 Controlling food safety hazardsClause 14 Product tracingClause 15 Processing of milk and dairy productsClause 16 Processing of dairy products to make cheese and cheese products

The National Food Safety Standards, Standards 3.2.2 and 3.2.3, also apply to the processing of dairy products. A dairy processing business must control its potential food safety hazards by implementing a documented food safety program. As part of the documented food safety program in clause 13, a

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dairy processing business must have a system to identify the immediate supplier of dairy products and ingredients and the immediate recipient of the dairy products.

Unless an applicable law of a State or Territory otherwise expressly provides, milk must be pasteurised by –

(a) heating to a temperature of no less than 72°C and retaining at such temperature for no less than 15 seconds; or(b) Heating, using any other time and temperature combination of equivalent or greater lethal effect on any pathogenic micro-organisms in the milk; or(c) Using any other process that provides an equivalent or greater lethal effect on any pathogenic micro-organisms.

Milk processed under paragraph 15(1) (a) must be cooled immediately in a way that ensures that the growth of microbiological hazards in the milk is prevented or reduced.

Dairy products, other than cheese and cheese products, must be processed using –(a) A heat treatment that uses a combination of time and temperature of equal or greater lethal effect on any pathogenic micro-organisms in the milk product achieved by paragraphs 15(1) (a) or 15(1) (b); or(b) Any other process that provides an equivalent or greater lethal effect on any pathogenic micro-organisms.

Dairy products processed under paragraph 15(3) (a) must be cooled immediately in a way that ensures that the growth of microbiological hazards in the product is prevented or reduced. Subclause 15(3) does not apply to the processing of dairy products that have been made using milk already processed in accordance with subclause 15(1).

Food Safety Hazards – Traceability & VerificationTraceability is the cornerstone of modern food safety. The Australian primary production and processing sectors utilise a traceability approach, whereas the food service/food distribution sectors utilise a recall approach. The Australian Dairy industry has chosen to adopt a one up / one back system of traceability that identifies the immediate supplier and immediate recipient of dairy products.

Clause 14 of the National Dairy Primary Production and Processing Standard 4.2.4 specifies requirements for dairy product tracing by dairy processing businesses. As part of the documented food safety program under Clause 13 of the Standard, a dairy processing business must have a system to identify the immediate supplier of dairy products and ingredients and the immediate recipient of the dairy products.

Food standards are enforced in the dairy processing and manufacture sector predominately by SDFAs / SRAs in conjunction with State Health Departments and local government. DoA has arrangements in place with SRAs for the enforcement of standards for exported dairy products. DoA may inspect or check test imported foods for compliance with Australian standards. From farm to product storage, all dairy businesses must be licensed or accredited. Individual Food Safety Programs for dairy processors are approved by SDFAs / SRAs before licences are granted and compliance is monitored through regular audits. An annual verification program is conducted.

A range of industry and regulatory agencies monitor the safety and quality of milk and dairy products through the supply chain. These include dairy companies, the Australian Milk Residue Analysis Survey, federal and state regulatory agencies, SRAs, SDPIs and EPAs. The Australian Milk Residue Analysis (AMRA) Survey is an important measure in monitoring the safety of milk. State Departments of Health monitor the safety of food at retail level and during the distribution of product following manufacture.

Verification of food safety programs is critical to the integrity of the Australian co-regulatory system. It is undertaken to ensure that control measures are working. Increasingly, verification is achieved through regular auditing by companies, regulatory authorities or other third parties such as suppliers and customers. Companies conduct internal audits at a frequency determined in the documented business plan. Company staff usually performs these through monitoring and record keeping in an internal verification process.

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Regulatory authorities conduct audits to verify that establishments are operating food safety programs satisfactorily. This ensures that:- Monitoring records are up to date and correct- Corrective actions are taken in a timely manner and resolved- Calibration criteria are met- Testing results are available and within specification- Changes to systems, procedures, and processes are actioned appropriately.

Auditing is conducted by qualified, competent and accredited auditors directly employed by government or increasingly by auditors approved by the regulatory authority who operate under contract. Where this latter system is operating, regulatory authorities randomly check the contract audit system. The audit system is again supported by a regulatory system operating in all Australian States and Territories. It is supported by legislative powers designed to protect public health. The scope of the audits is extensive with a focus on the food safety system, including audit standards and auditor competencies and skills rather than traditional inspection.

Food Safety Hazards – Market ForcesAustralian dairy manufacturers work closely with domestic and international customers to ensure safe and consistent quality dairy products are supplied year around. FSANZ is the key authority for development of national food standards and codes for practice for products destined for the domestic market and imported dairy products. State Health Departments implement the standards at state level. DA plays an important role in interpreting and negotiating the market access requirements of importing countries. The regulatory framework for dairy products sold within Australia and overseas is harmonised wherever possible. Federal and state government agencies work closely with industry to provide safe dairy products for both Australian and international customers.

The relationship between Australian dairy companies and their domestic and international markets has been developed over years through close communication with customers and consistent delivery of safe quality dairy products. Retail or ingredient customers within Australia and overseas apply rigorous buying specifications. Typical buying specifications include product specification, transport conditions and the buyers’ expectations of the quality assurance approach. Many customers audit their suppliers on a regular basis. Competent authorities within Federal and State regulatory agencies underpin the national approach to food safety and quality.

Food Safety Hazards – Industry & Commercial ProgramsA range of programs from government/industry agencies supports the dairy industry food safety regulatory approach. Some of these programs include the National Livestock Identification System (NLIS) and Feedsafe and Foddercare programs operating in the fodder industries. All dairy farmers are accredited under the beef industry food safety program (Livestock Production Assurance – LPA). This program covers the food safety elements of on farm meat production. National and regional extension programs have been developed by the dairy industry to support the farm sector. Some areas covered by these programs include:

• Mastitis prevention and treatment - Countdown Downunder• Animal fertility - Incalf• Use of grains as supplementary feed - Grains2Milk• increasing efficiency of milk harvesting - Cowtime• handling of animals to minimise stress and injury• Australian Breeding Values (ABV) genetic selection of bulls for ease of calving, fertility, mastitis resistance and survivability,• Design of milking sheds, laneways and stockyards• Environmental issues – DairySAT, DairyGains

The dairy industry directly supports the various State Governments’ dairy extension activities, which focus mainly on business productivity and environmental aspects of dairy farming. Dairy Australia has established the National Centre for Dairy Education Australia (NCDEA) to develop and deliver vocational education and training for all sectors of the dairy industry. In conjunction with Dairy Food Safety Victoria, food safety programs have also been developed for the manufacturing sector. There are many supporting programs underpinning dairy food safety.

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Distribution Risk Management Framework

IntroductionPrior to despatch to customers, finished dairy product is stored in warehouses, which are licensed / accredited and inspected / audited by State Dairy Food Authorities (SDFAs) / State Regulatory Authorities (SRAs). For traceability purposes, records are maintained of incoming and outgoing product including damaged goods. All warehouses must have a Product Recall system.

Distribution warehouses are usually licensed / accredited by SDFAs / SRAs for product destined for the domestic market and require registration by DoA for storage of export product. For traceability purposes, records are maintained of incoming and outgoing product including damaged goods. All warehouses have a Product Recall system which must comply with the FSANZ Product Recall Protocol. Prior to despatch to customers, finished product is stored in warehouses operated by the dairy company or by external contractors. The implementation of a Food Safety Program (FSP) is required for all warehouses that are licensed / accredited by SDFAs / SRAs.

Prior to loading of product, warehouse staff must conduct checks of the cleanliness of the interior of transport vehicles and shipping containers. Where required, temperature of the product is checked at loading and monitored throughout the distribution chain. Transporters of bulk product between dairy manufacturing plants intended for further processing are required to have a FSP conforming to the requirements of FSC Standard 4.2.4.

Containers destined for export are sealed and appropriate documentation is completed prior to shipping. Companies use the DoA ExDoc electronic system for certification of dairy exports. Auditors approved by regulatory agencies including DoA conduct audits of the warehouse FSP. Additional follow-up audits are conducted if non-compliance is noted. Australian and international customers also conduct audits on all or part of a warehouse’s quality assurance program.

Product Tracing / Product Recall – Regulatory SystemPrior to despatch to customers, finished dairy product is stored in warehouses, which are licensed / accredited and inspected / audited by SDFAs / SRAs. For traceability purposes, records are maintained of incoming and outgoing product including damaged goods. All warehouses must have a Product Recall system that complies with the national Product Recall protocol developed by FSANZ.

Warehouses are usually licensed / accredited by SDFAs / SRAs for product destined for the domestic market and require registration by DoA for storage of export product. For traceability purposes, records are maintained of incoming and outgoing product including damaged goods. All warehouses have a Product Recall system which must comply with the FSANZ Product Recall Protocol. Prior to despatch to customers, finished product is stored in warehouses operated by the dairy company or by external contractors. The implementation of a Food Safety Program (FSP) is required for all warehouses that are licensed by SDFAs / SRAs. Warehouses used for export product need to be registered by DoA.

Product Tracing / Product Recall - StandardsDivision 4 of the National Dairy Primary Production and Processing Standard 4.2.4 specifies requirements for dairy product distribution. The requirements for storage and transportation within the National Food Safety Standards - Standards 3.2.2 and 3.2.3 - apply to the distribution of packaged dairy products. Specifically Clause 6 (Food Storage) and Clause 10 (Food Transport) of Division 3 of Standard 3.2.2 are directly relevant to the distribution of dairy products.

For further information and advice regarding the regulatory requirements and Standards applicable to distribution of food products in Australia refer to “Safe Food Australia” - A guide to the Food Safety Standards . This guide was prepared by Food Standards Australia New Zealand to assist with the interpretation of three of the food safety standards in Chapter 3 of the Australia New Zealand Food Standards Code. These standards apply only in Australia. They are:

3.1.1 Interpretation and Application3.2.2 Food Safety Practices and General Requirements3.2.3 Food Premises and Equipment

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Product Tracing / Product Recall – Traceability & VerificationTraceability is the cornerstone of modern food safety. The Australian primary production and processing sectors utilise a traceability approach, whereas the food service/food distribution sectors utilise a recall approach. The Australian Dairy industry has chosen to adopt a one up / one back system of traceability that identifies the immediate supplier and immediate recipient of dairy products.

Clause 12 of Division 3 of the national Food Safety Standard 3.2.2 specifies that a food business engaged in the wholesale supply, manufacture or importation of food must (a) have in place a system to ensure the recall of unsafe food; (b) set out this system in a written document and make this document available to an authorised officer upon request; and (c) comply with this system when recalling unsafe food.

SDFAs / SRAs require that dairy distribution warehouses should have in place a Product Recall system, which must comply with the FSANZ Product Recall Protocol. The effective implementation of a Food Safety Program (FSP) is required for all warehouses that are licensed / accredited by SDFAs / SRAs. For traceability purposes, records are maintained of incoming and outgoing product including damaged goods. Prior to despatch to customers, finished product is stored in warehouses operated by the dairy company or by external contractors.

A range of industry and regulatory agencies monitor the safety and quality of milk and dairy products through the supply chain. These include dairy companies, the Australian Milk Residue Analysis Survey, federal and state regulatory agencies, SDPIs and SEPAs. The Australian Milk Residue Analysis (AMRA) Survey is an important measure in monitoring the safety of milk. State Departments of Health monitor the safety of food at retail level and during the distribution of product following manufacture.

Product Tracing / Product Recall – Market ForcesAustralian dairy manufacturers work closely with domestic and international customers to ensure safe and consistent quality dairy products are supplied year around. FSANZ is the key authority for development of national food standards and codes for practice for products destined for the domestic market and imported dairy products. State Health Departments implement the standards at state level. DoA plays an important role in interpreting and negotiating the market access requirements of importing countries. The regulatory framework for dairy products sold within Australia and overseas is harmonised wherever possible. Federal and state government agencies work closely with industry to provide safe dairy products for both Australian and international customers.

The relationship between Australian dairy companies and their domestic and international markets has been developed over years through close communication with customers and consistent delivery of safe quality dairy products. Retail or ingredient customers within Australia and overseas apply rigorous buying specifications. Typical buying specifications include product specification, transport conditions and the buyers’ expectations of the quality assurance approach. Many customers audit their suppliers on a regular basis. Competent authorities within Federal and State regulatory agencies underpin the national approach to food safety and quality.

Product Tracing / Product Recall – Industry & Commercial ProgramsAll manufacturers conduct extensive analytical programs to provide evidence to customers that their buying specifications have been achieved. SRAs conduct product monitoring programs and pathogen prevention programs. State Health departments may also include dairy products in their food quality monitoring programs.

The factors along the Australian dairy supply chain that have the most significant impact on the safety of processed dairy products are:

the quality of raw materials; correct formulation; effective processing (pasteurisation in particular); the prevention of recontamination of a product; and maintenance of temperature control during distribution, retail sale and Storage of the product in the home.

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A range of programs from government/industry agencies supports the dairy industry food safety regulatory approach. Some of these programs include the National Livestock Identification System (NLIS) and Feedsafe and Foddercare programs operating in the fodder industries. All dairy farmers are accredited under the beef industry food safety program (Livestock Production Assurance – LPA). This program covers the food safety elements of on farm meat production. National and regional extension programs have been developed by the dairy industry to support the farm sector. Some areas covered by these programs include:

• Mastitis prevention and treatment - Countdown Downunder• Animal fertility - Incalf• Use of grains as supplementary feed - Grains2Milk• increasing efficiency of milk harvesting - Cowtime• handling of animals to minimise stress and injury• Australian Breeding Values (ABV) genetic selection of bulls for ease of calving, fertility, mastitis resistance and survivability,• Design of milking sheds, laneways and stockyards• Environmental issues – DairySAT, DairyGains

The dairy industry directly supports the various State Governments’ dairy extension activities, which focus mainly on business productivity and environmental aspects of dairy farming. Dairy Australia has established the National Centre for Dairy Education Australia (NCDEA) to develop and deliver vocational education and training for all sectors of the dairy industry. In conjunction with Dairy Food Safety Victoria, food safety programs have also been developed for the manufacturing sector. There are many supporting programs underpinning dairy food safety. The programs listed above provide examples of programs but this is not an exhaustive list.

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Retail Risk Management Framework

IntroductionAustralian dairy farmers and dairy manufacturers work closely with domestic and international customers to ensure safe and consistent quality dairy products are supplied year around. For further information and advice regarding the regulatory requirements and Standards applicable to retail sale of food products in Australia refer to “Safe Food Australia” - A guide to the Food Safety Standards . The Safe Food Australia guide was prepared by Food Standards Australia New Zealand to assist with the interpretation of three of the food safety standards in Chapter 3 of the Australia New Zealand Food Standards Code.

Health and Hygiene of Food Handlers and Food BusinessesThe following tables detail some of the pathogens potentially transmitted to food by contaminated food handlers (Source: “Safe Food Australia” - A guide to the Food Safety Standards).

Table 1: Pathogens often transmitted by food contaminated by infected food handlers

Name of pathogen Name of disease Hepatitis A Hepatitis ANorwalk and Norwalk-like viruses Norovirus / Norwalk disease or Norwalk-like diseaseSalmonella typhi Typhoid feverShigella species ShigellosisStaphylococcus aureus Staphylococcal diseaseStreptococcus pyogenes Streptococcal disease

Table 2: Pathogens occasionally transmitted by food contaminated by infected food handlers

Name of pathogen Name of disease Campylobacter jejuni Campylobacter enteritisEntamoeba histolytica AmoebiasisEnterohaemorrhagic Escherichia coli Diarrhoea caused by Escherichia coli (enterohaemorrhagic

strains)Enterotoxigenic Escherichia coli Diarrhoea caused by Escherichia coli (enterotoxigenic

strains)Giardia lamblia GiardiasisNon-typhoidal Salmonella SalmonellosisRotavirus Rotaviral enteritisTaenia solium TaeniasisVibrio cholerae O1 CholeraYersinia enterocolitica Yersiniosis

Food Safety StandardsChapter 3 of the Food Standards Code covers all food retail sale activities, including packaged dairy products. ‘Retail sale’ refers to direct sale to the public and does not include sale to wholesalers, caterers or to businesses that on-sell. For further information and advice regarding the regulatory requirements and Standards applicable to retail sale of food products in Australia refer to “Safe Food Australia” - A guide to the Food Safety Standards. This guide was prepared by Food Standards Australia New Zealand to assist with the interpretation of three of the food safety standards in Chapter 3 of the Australia New Zealand Food Standards Code. These standards apply only in Australia. They are:

3.1.1 Interpretation and Application3.2.2 Food Safety Practices and General Requirements3.2.3 Food Premises and Equipment

The Food Safety Standards are given effect in all States under the relevant State Food Act. In accord with Clause 4(1) of Food Safety Standard 3.2.2 the proprietor of a food business must ensure the food business complies with all the requirements of the Food Safety Standards. The food safety standards regulate the safety and suitability of food. ‘Safe’ and ‘suitable’ are the words used by the Codex

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Alimentarius Commission in its basic texts on food hygiene to describe food that is fit for human consumption. The Codex Alimentarius Commission is responsible for developing international food standards, codes of practice and guidelines on behalf of the Food and Agriculture Organization and the World Health Organization, with the aim of protecting the health of consumers and ensuring fair practices in international food trade.

Food Standards Code Standard 3.2.2 - Food Safety Practices and General Requirements - sets out specific requirements for food businesses and food handlers that, if complied with, will ensure food does not become unsafe or unsuitable. This Standard specifies process control requirements to be satisfied at each step of the food handling process. Some requirements relate to the receipt, storage, processing, display, packaging, distribution disposal and recall of food. Other requirements relate to the skills and knowledge of food handlers and their supervisors, the health and hygiene of food handlers, and the cleaning, sanitising, and maintenance of premises and equipment

Division 4 of Standard 3.2.2 specifies the health and hygiene requirements for both food handlers and food businesses. Subdivision 1 of Division 4 covers the requirements for food handlers, and Subdivision 2 covers the requirements for food businesses. The specific Clauses include:

13 General requirements 14 Health of food handlers 15 Hygiene of food handlers 16 Health of persons who handle food – duties of food businesses 17 Hygiene of food handlers – duties of food businesses 18 General duties of food businesses

Clause 13 places a general obligation on food handlers to take all reasonable measures to ensure that their actions do not compromise the safety and suitability of food. Food handlers are also specifically obliged to comply with the requirements of clauses 14 and 15.A ‘food handler’ is defined to mean a person who directly engages in the handling of food, or who handles surfaces likely to come into contact with food, for a food business.’ Handling’ (of food) is also defined and includes making, manufacturing, producing, collecting, extracting, processing, storing, transporting, delivering, preparing, treating, preserving, packing, cooking, thawing, serving or displaying food. Hence any person who undertakes any of these activities for a food business is considered to be a food handler. Note that the food business is ultimately responsible for the safety and suitability of the food handled by that business and this overall responsibility cannot be devolved to the individual food handler.

Clause 14 ensures that: a food handler notifies the food business if the food handler suspects he or she may have

contaminated food; and food handlers suffering or suspected to be suffering from food-borne diseases or certain

conditions do not contaminate food.

Emerging Public Health issuesThe Australian dairy industry’s Issues Management Group (IMG) is a network of interested industry and government stakeholders coordinated by Dairy Australia. The objective is to provide a comprehensive and industry-wide approach to address issues that may affect the reputation and future viability of the Australian dairy industry. The Australian dairy industry works in a co-regulatory partnership approach to identify any emerging food safety issues that may affect dairy product safety. This requires strong links with a wide range of Australian and international organisations such as FSANZ, APVMA, CSIRO, Codex Alimentarius Commission, World Animal Health Organisation (OIE) and the International Dairy Federation (IDF). This ensures the Australian industry is aware of potential issues in other countries and actions being taken by various agencies and scientific researchers to investigate measures to correct or manage the issue.

Proactive and reactive measures are undertaken to ensure industry risk management plans remain appropriate for the risk and do provide safe food. Proactive measures may include marketing research and/or commissioning specific research as appropriate to detect any emerging food safety issues and the adequacy of food safety plans against the emerging issues. Reactive measures may include communication strategies to respond to potential food safety issues across the industry and to convey accurate information to customers and importing countries. Regular reviews of potential risks and the measures in place to manage identified risks are conducted.

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Food Retail Premises - Regulatory systemWarehouses and retail food outlets are usually licensed and inspected by Local Governments or State Health Departments under the provisions of State Food Act legislative frameworks for product destined for the domestic market. For traceability purposes, records are maintained of incoming and outgoing product including damaged goods. All warehouses should have in place a Product Recall system, which must comply with the FSANZ Product Recall Protocol. Prior to despatch to customers, finished product is stored in warehouses operated by the dairy company or by external contractors.

Food Retail Premises - Standards (National and International)The National Dairy Primary Production and Processing Standard 4.2.4 specify requirements for dairy primary production, transport, processing and storage. This Standard sets out a number of food safety requirements, including the implementation of documented food safety programs for dairy primary production, collection, transportation and processing. However, this Standard (i.e. Standard 4.2.4) does not apply to retail sale activities. Chapter 3 of the Food Standards Code covers all food retail sale activities, including packaged dairy products. ‘Retail sale’ refers to direct sale to the public and does not include sale to wholesalers, caterers or to businesses that on-sell.

Standard 3.2.2 sets out specific requirements for food businesses and food handlers that, if complied with, will ensure food does not become unsafe or unsuitable. This Standard specifies process control requirements to be satisfied at each step of the food handling process. Some requirements relate to the receipt, storage, processing, display, packaging, distribution disposal and recall of food. Other requirements relate to the skills and knowledge of food handlers and their supervisors, the health and hygiene of food handlers, and the cleaning, sanitising, and maintenance of premises and equipment.

Standard 3.2.3 sets out requirements for food premises and equipment that, if complied with, will facilitate compliance by food businesses with the food safety requirements of Standard 3.2.2 (Food Safety Practices and General Requirements). The objective of this Standard is to ensure that, where possible, the layout of the premises minimises opportunities for food contamination. Food businesses are required to ensure that their food premises, fixtures, fittings, equipment and transport vehicles are designed and constructed to be cleaned and, where necessary, sanitised. Businesses must ensure that the premises are provided with the necessary services of water, waste disposal, light, ventilation, cleaning and personal hygiene facilities, storage space and access to toilets.

For further information and advice regarding the regulatory requirements and Standards applicable to retail sale of food products in Australia refer to “Safe Food Australia” - A guide to the Food Safety Standards. This guide was prepared by Food Standards Australia New Zealand to assist with the interpretation of three of the food safety standards in Chapter 3 of the Australia New Zealand Food Standards Code. These standards apply only in Australia. They are:

3.1.1 Interpretation and Application3.2.2 Food Safety Practices and General Requirements3.2.3 Food Premises and Equipment

The Food Safety Standards are given effect in all States under the relevant State Food Act. In accord with Clause 4(1) of Food Safety Standard 3.2.2 the proprietor of a food business must ensure the food business complies with all the requirements of the Food Safety Standards. The food safety standards regulate the safety and suitability of food. ‘Safe’ and ‘suitable’ are the words used by the Codex Alimentarius Commission in its basic texts on food hygiene to describe food that is fit for human consumption. The Codex Alimentarius Commission is responsible for developing international food standards, codes of practice and guidelines on behalf of the Food and Agriculture Organization and the World Health Organization, with the aim of protecting the health of consumers and ensuring fair practices in international food trade.

Food Retail Premises - Traceability and VerificationTraceability is the cornerstone of modern food safety. The Australian primary production and processing sectors utilise a traceability approach, whereas the food service/food distribution sectors utilise a recall approach. The Australian Dairy industry has chosen to adopt a one up / one back system of traceability that identifies the immediate supplier and immediate recipient of dairy products.

Division 3 of the national Food Safety Standard 3.2.2 specifies that a food business should have in place a system to ensure the recall of unsafe food; set out this system in a written document and

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make this document available to an authorised officer upon request; and comply with this system when recalling unsafe food. The Product Recall system should be based upon the FSANZ Product Recall Protocol. Food standards are enforced on food businesses by State Health Departments and local government utilising an inspection based verification system to verify compliance with the national Food Safety Standards.

Food standards are enforced on food businesses by State Health Departments and local government utilising an inspection based verification system to verify compliance with the national Food Safety Standards. A range of industry and regulatory agencies monitor the safety and quality of milk and dairy products through the supply chain. These include dairy companies, federal and state regulatory agencies, SDPIs and SEPAs. The Australian Milk Residue Analysis (AMRA) Survey is an important measure in monitoring the safety of milk.

Food Retail Premises - Market ForcesAustralian dairy manufacturers work closely with domestic and international customers to ensure safe and consistent quality dairy products are supplied year around. FSANZ is the key authority for development of national food standards and codes for practice for products destined for the domestic market and imported dairy products. State Health Departments implement the standards at state level. DoA plays an important role in interpreting and negotiating the market access requirements of importing countries. The regulatory framework for dairy products sold within Australia and overseas is harmonised wherever possible. Federal and state government agencies work closely with industry to provide safe dairy products for both Australian and international customers.

The relationship between Australian dairy companies and their domestic and international markets has been developed over years through close communication with customers and consistent delivery of safe quality dairy products. Retail or ingredient customers within Australia and overseas apply rigorous buying specifications. Typical buying specifications include product specification, transport conditions and the buyers’ expectations of the quality assurance approach. Many customers audit their suppliers on a regular basis. Competent authorities within Federal and State regulatory agencies underpin the national approach to food safety and quality.

The Australian dairy industry has a rich history of developing and responding to market forces through the development of an extensive range of industry programs and working co-operatively with Government, suppliers and other associated industries. This has resulted in today’s dairy industry which includes farmer’s co-operatives, multi-national organisations, vertically integrated conglomerates and independent operators. Sectors of the industry have taken differing approaches to ensure the outcome of producing safe and quality dairy products, including quality management systems, food safety programs, vendor management systems, and supplier agreements. However, these approaches all have one thing in common which is that the benchmark of compliance with the National Dairy Standard and legislative food safety requirements is built into all of these systems.

Standards and Codes developed by international agencies such as Codex Alimentarius Commission and World Trade Organisation provide guidance to the Australian dairy food regulatory framework. Under the FSC, all manufacturers, wholesalers, distributors and importers of food are required to have in place a written recall plan. The recall plan should be modelled upon the FSANZ Product Recall Protocol. Under Australia’s export legislation and importing country requirements, DoA is the competent authority for export inspection and certification. Export regulations cover many requirements including the importing country’s food safety requirements, product standards, biosecurity, quarantine standards and traceability.

Food Retail Premises - Industry ProgramsA range of programs from government/industry agencies supports the dairy industry food safety regulatory approach. Some of these programs include the National Livestock Identification System (NLIS) and Feedsafe and Foddercare programs operating in the fodder industries. All dairy farmers are accredited under the beef industry food safety program (Livestock Production Assurance – LPA). This program covers the food safety elements of on farm meat production. National and regional extension programs have been developed by the dairy industry to support the farm sector. Some areas covered by these programs include:

• Mastitis prevention and treatment - Countdown Downunder• Animal fertility - Incalf

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• Use of grains as supplementary feed - Grains2Milk• increasing efficiency of milk harvesting - Cowtime• handling of animals to minimise stress and injury• Australian Breeding Values (ABV) genetic selection of bulls for ease of calving, fertility, mastitis resistance and survivability,• Design of milking sheds, laneways and stockyards• Environmental issues – DairySAT, DairyGains

The dairy industry directly supports the various State Governments’ dairy extension activities, which focus mainly on business productivity and environmental aspects of dairy farming. Dairy Australia has established the National Centre for Dairy Education Australia (NCDEA) to develop and deliver vocational education and training for all sectors of the dairy industry. In conjunction with Dairy Food Safety Victoria, food safety programs have also been developed for the manufacturing sector. There are many supporting programs underpinning dairy food safety. The programs listed above provide examples of programs but this is not an exhaustive list.

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ReferencesAustralian Government Department of Health and Ageing, Population Health Divisionhttp://www.immunise.health.gov.au/qfever

The Australian Immunisation Handbook, 8th Edition, 2003http://www.immunise.health.gov.au/handbook.htm

Victorian Department of Human Services, Q Feverhttp://www.health.vic.gov.au/ideas/diseases/qfev.htm

Zoonoseshttp://www.health.vic.gov.au/ideas/diseases/gr_zoo.htm

Victorian Department of Primary Industries, Information Notes - Anthrax in Animalshttp://www.dpi.vic.gov.au

Pfizer Animal Health, Leptospirosishttp://www.pfizeranimalhealth.com.au

WorkSafe Victoria, Q fever Guidance Notehttp://www.workcover.vic.gov.au/

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i Dairy Australia’s Strategic Plan 2012-16, Available at www.dairyaustralia.com.auiiFood safety risk management systems are described in more detail in a related document.iii(1920, C.E.A. Winslow)ivDepartment of Health and Aging, 2011. Available at www.health.gov.au

v