Safety Locks

September 1, 2005
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Safety Locks
by Lynn Petrak
Foodborne illness rates drop as dairy processors continue to implement safety and security measures.
Dairy products are rather unique in the food and beverage marketplace because they are animal-based products regarded as both perishable and, for the most part, safe.
It was the advent of pasteurization, of course, that has long set the dairy industry apart from other industries, like those that process meat, poultry, seafood or other fresh products with a short shelf life. “We take ‘bad bugs’ right out of the picture. Many other foods don’t have that luxury,” says Allen Sayler, senior director, regulatory affairs and international standards for the Washington, D.C.-based International Dairy Foods Association (IDFA).
Statistics bear out the notion that dairy products are among the safest in the food chain. There have been no major or national dairy product recalls over the past year, according to the United States Food and Drug Administration (FDA). Even more importantly, illnesses and deaths tied to foodborne pathogens, including dairy products, are low and dropping, as tracked by the Centers for Disease Control and Prevention (CDC).
That is not to say, however, that the dairy industry is complacent about safety, whether the concern is pathogens, allergens or biosecurity. Industry-funded organizations and dairy companies continue to spearhead and fund broad-scale strategic efforts, while on a daily, safety and quality professionals regularly monitor the safety of products that enter and leave dairy plants.
Sometimes, advancements in safety are spurred by improvements in technology, for the processing, distribution or testing of dairy and dairy-based products. At other times, safety-driven initiatives are propelled by evolving issues, such as the emergence of new bacteria, animal diseases and bioterrorism threats. Regulatory issues have a significant impact as well.
“The dairy industry has been highly regulated at both the government and state levels for many years at both Grade A and non-Grade A facilities,” Sayler says. “As a result, it has driven us to go to the next level of safety in practices.”
Animal Instincts
Tracing food safety from farm to fork is not a new concept. In recent history, though, the farm has been a prominent front in the larger food safety battle. “One key area has been animal health, which is getting much work,” observes J. Russell “Rusty” Bishop, Ph.D., director of the Wisconsin Center for Dairy Research and a professor of food science at the University of Wisconsin-Madison.
That assessment is shared by Rob Byrne, vice president of scientific and regulatory affairs for the National Milk Producers Federation (NMPF), Arlington, Va. “Certainly, on the animal disease side, there is a continued effort on disease prevention and to stop any spread of diseases,” he says, adding that although there are no significant emerging animal diseases at this point, bovine tuberculosis has resurfaced in some areas around the country and is being responded to in kind.
For a range of diseases, milk producers continue to take steps to reduce animal health problems that can impact product safety at a later point. Byrne cites a few of those efforts: “It is keeping people out of sensitive areas like calfing areas, it is good cleaning equipment, it is knowing where animals are produced and it is quarantining animals if necessary, among other things.”
In addition to here-and-now issues, dairy producers keep tabs on animal diseases with a potential impact on their industry. Foot-and-mouth disease is one example, because of the stir a few years ago caused by outbreaks in Europe. Meanwhile, although bovine spongiform encepholopathy (BSE) has not been shown to affect dairy products, that disease has spurred a ruminant feed ban that impacts the farming of dairy cows that are later used for ground beef.
Measures of Success
Beyond the farm, dairy processors are working with more structured food safety programs in their plants, some voluntary and some mandated. “Much of the dairy checkoff money is for training for the industry,” Bishop says. “It’s keeping them up on things like good management practices, HACCP, sanitation and other things as we learn them.”
Good management practices (GMPs), which encompass safety-related training, audits, documentation validation and evaluation have been in place in some form or another in dairy processing facilities for years but have been in the spotlight lately. That trend stems in part from a call by the FDA nearly two years ago for a more thorough evaluation of foodborne illnesses. “They wanted to categorize what the driving force was behind foodborne illness problems and realized that a lot of reasons had to do with GMPs,” Sayler recalls.
As a result, FDA fast-tracked a review of GMPs within various industries, including the dairy sector. As that review progressed, IDFA and other dairy leaders have provided comprehensive industry insight and feedback. “There is an industry coalition working with FDA to make GMPs applicable, practical and relevant, in areas like the training of employees, allergen controls, recordkeeping and environmental monitoring,” Sayler says.
The FDA is expected to issue a white paper on GMPs in the coming weeks. “That would give a sense of where changes need to be made,” Sayler says, adding that a comment period following the publication will allow the industry to again voice its concerns and suggestions.
Even with pending action from the FDA, many dairy plants already have GMPs in place at their facilities. Safety training programs are common in large, mid-size and small facilities alike, as are improved allergen control programs and site and product evaluations, by both in-house safety experts and third-party auditors.
Although proposed government revisions to GMPs can be a catalyst for changes or additions to current practices, another driving force is good old-fashioned competition. “As dairies consolidate, they make more products and sell to bigger entities. Those buyers — the Wal-Marts of the world — are requiring GMPs, documentation and HACCP,” Bishop notes. “So dairies can’t afford not to do it because their buyers are demanding it.”
Rolled in with GMPs are hazard analysis critical control points (HACCP) systems. Most HACCP programs, after all, include GMPs, along with prerequisites (PPs) and sanitation standard operating procedures (SSOPs)
Whether mandated to implement HACCP because of simultaneous juice production or wanting to demonstrate to customers a commitment to safety, dairies have increasingly worked toward formalizing their HACCP measures. IDFA, for its part, offers a HACCP certification program, a comprehensive training program designed to train juice and dairy professionals to develop, implement and maintain a HACCP system. As part of its training, IDFA sponsors short courses and provides management software programs and written manuals on HACCP for both dairy and juice production.
Other HACCP resources are available to dairy processors as well. The Wisconsin Center for Dairy Research, for instance, offers annual HACCP workshops, while independent consultants can be brought in to conduct training sessions and evaluate or create HACCP programs.
Rules and Regulations
As dairies take concrete steps to ensure safety in their day-to-day operations, they are also mindful of regulatory issues that impact production, facilities, packaging, distribution and marketing, among other aspects of their business.
For example, with the 2006 deadline looming for the Food Allergen Labeling and Consumer Protection Act passed into law by Congress last year, dairy manufacturers have been updating labels with allergen information and, in some case, petitioning the FDA for exemptions. (Milk/dairy is one of the eight top allergens as defined by FDA, along with peanuts, tree nuts, soy, fish, shellfish, wheat and eggs.)
The good news for dairy processors is that much of the work for allergen labeling is under their proverbial belt. “The vast majority in the dairy industry have been meeting the voluntary guidelines put together by the Food Allergy Issues Alliance,” says Michelle Albee Matto, manager, regulatory affairs for IDFA, adding that since the allergen law was put forward, IDFA has relayed dairy industry input to FDA and in turn, worked with its dairy members on compliance.
As they work to label their own milk and dairy products, processors are also keenly aware of cross-contact with other allergens, such as crab used in dairy-based dips or peanuts used for ice cream variegates and inclusions. “We are one of the eight and we use all of the other seven allergens,” Albee Matto notes.
IDFA’s vice president of regulatory affairs, Cary Frye, agrees that the allergen scope is wide for dairy manufacturers. “It is certainly a challenge day in and day out to make sure there isn’t any cross contact,” she says.
Beyond allergens, there are a host of other regulatory issues relevant to dairies. During its conference last spring, for example, the National Conference on Interstate Milk Shipments (NCIMS) proposed changes to food safety regulations for Grade A dairy products. “We really applaud the conference — more and more they are using science and scientific data to make evaluations of current regulations and change them,” Frye says.
The changes NCIMS recommended were tied to more flexible cooling temperatures for cultured and acidified dairy foods. “In order to support the proposed temperature changes, we had respected researchers do a paper on products that we felt were more likely to keep safety characteristics, like sour cream, cottage cheese, yogurt and buttermilk,” Sayler says, noting that report is nearly complete and IDFA is meeting with FDA this month.
As Frye explains, temperature change requests have been determined on a product-by-product basis. “Proposals depend on product characteristics — the profile of cooking a hot product is different than cooling a yogurt down, for example. It also depends on packaging. So we’ve given them very real scenarios,” she says. “This study sees how far we can go and still have a safe product.”
Also as part of its conference last spring, NCIMS made adjustments to employee health regulations and reporting, including workers at the farm and processing plant as well as those who transport milk and other dairy products. “They want to make sure they are updated on foodborne illnesses that may be transmitted,” Frye says, adding that IDFA is working with NCIMS on a study committee on that topic.
Getting the Bugs Out
Under the microscope in a literal way, meanwhile, are the microbes that cause foodborne illness. Although incidents relating to pathogens like E. coli, Salmonella and Listeria have dropped in recent years and pasteurization kills most microbes in finished dairy products, some dairy foods and beverages remain susceptible to microorganism growth.
“We don’t seem to have any hot new pathogens,” says Bishop. “But if I had to pick one, it is still Mycobacterium paratuburculosis (MAP), because there is conflicting data on that.”
To Bishop’s point, a checkoff-funded study two years ago sought to determine if current pasteurization parameters were effective on strains of MAP, which has been linked with Crohn’s disease in humans. The study showed that post-pasteurization eliminates MAP from raw liquid milk. This is supported by studies in New Zealand, Canada, Australia and Ireland, although other evaluations in Europe have been inconclusive.
Another bug that remains on the radar for dairy producers is Listeria monocytogenes. Following an FDA risk assessment for L. monocytogenes in ready-to-eat foods in 2003, the Milk Industry Foundation (MIF) commissioned a study that found that modern advances in milk processing, packaging technology and sanitation practices have contributed to the sharp drop on rates of L. monocytogenes in fluid milk over the past several years. This survey was part of the FDA risk assessment showing that of 5,000 samples of pasteurized milk, only one tested positive for Listeria. “That data is important, because it is contemporary data – about 300 percent lower than the previous data,” says Frye.
Even with lower rates of Listeria, there are pockets of concern. One of those areas is the marketing of products made from unpasteurized milk. “We’ve seen a boom in raw-milk cheeses, which can present real problems if they don’t pasteurize them and the cheese has to age 60 days,” Bishop says. “We don’t get many problems with it, but we get one or two, and the fear is that if you get one, all cheese gets lumped in.”
Frye agrees that raw-milk cheeses pose challenges in both safety and the perception of safety. “FDA is putting quite a bit of emphasis on cheeses that are made in small home situations or cheeses that are illegally made,” she says. “At the same time, we continue to see at different state levels a grassroots effort by small farmers to change the regulations to allow for the sale of raw milk at the farm.”
To educate mom-and-pop cheesemakers about the hazards of raw-milk cheese and the effect of outbreaks on the category at large, industry groups have launched various education projects. “It’s thorough training, like how you implement HACCP if your biggest control point of pasteurization isn’t there. In the end, there is no substitution for that, though,” says Bishop, who adds that communicating with consumers is key. “We try to do educational efforts and make sure the consumer knows they are having raw milk products.”
For its part, IDFA has helped define for consumers what “queso fresco” cheese really means and has provided written testimony to states that oppose loosening regulations on products made from unpasteurized milk. An example of efforts to reach out to small cheesemakers is a program called the Grandmother Project geared to Latino cheesemakers in the United States who continue a cultural tradition of making their own cheeses from raw milk. “This project, which originated in Spokane, Washington, teaches people in the Hispanic community how to pasteurize milk, even on the stove, to make cheese,” Frye says.
Another pathogen that dairy processors must keep a constant eye on is Salmonella. Fortunately, as with Listeria and E. coli, incidences linked to Salmonella in dairy products continue to decline. “We had two reports of Salmonella with ice cream — one was a small recall with ice cream and another was related to Salmonella in cake batter used for an ice cream mix, ” Frye says, noting that ice cream producers and other manufacturers of mixed-ingredient products need to be aware of the possible ramifications of all ingredients.
Gauging the presence and level of any type of pathogen, of course, involves microbiological testing. To that end, technological advancements are keeping pace with industry demands for faster, more accurate tests. In addition to the use of in-house testing tools, third-party testing services like Homewood, Ill.-based Silliker Laboratories help dairies check samples for microbes like Listeria and Salmonella, among others.
Product samples aren’t the only things being tested. Kits are also available to detect the presence of bacteria on equipment and other work surfaces within dairy plants. Such high-tech tests are used as both a diagnostic tool for pasteurization problems and as a quality-assurance tool.
Security Guards
Over the past several years, security has been inextricably linked with safety. As with other suppliers in the nation’s vast food chain, dairy processors have taken both large and small measures to enhance their products’ security in light of concerns over bioterrorism or agroterrorism.
According to Clay Detlefsen, vice president of regulatory affairs and counsel for IDFA, security remains a hot-button issue, four years after 9/11. “From the U.S. government’s side, it is high and getting higher. From the industry’s side, it remains at an elevated level,” he reports.
At NMPF, security is on par with traditional safety issues. “Food security has been a big focus over past couple of years and is getting more attention, with awareness among producers and plants,” says Byrne, adding that industry-led efforts to educate individual milk producers and co-op leaders have helped establish and improve a wide range of new security features.
Milk security actually made national headlines earlier this year, when media reports circulated that the nation’s milk supply was vulnerable to a bioattack. “We answered a lot of calls at that time and our general response was that we already have a number of measures in place and that what the publication was talking about wasn’t entirely accurate,” Byrne says.
IDFA also fielded several inquires at that time and responded that the issue was under control due to existing and developing initiatives. “IDFA has worked with the government and industry on that particular issue for years without fanfare, and we’re confident that the majority of concerns about this potential threat are unnecessary because of changes that have been implemented by the dairy industry,” says Detlefsen. “On the media flurry surrounding this paper's publication, IDFA worked closely with other dairy groups to correct misperceptions and reassure the public that the milk supply was safe through media interviews and information.”
In other security news, industry organizations and dairy companies have teamed with government officials on biodefense as part of the Department of Homeland Security (DHS) actions. “IDFA has had a close working relationship with DHS, USDA and FDA and recently, the FBI has joined the other three federal agencies," says Detlefsen, who co-chairs the Food and Ag Sector Coordinating Council and the Processor Manufacturer Subcouncil.
As for specific actions in place to shore up defenses against intentional product tampering, dairies have made several concrete changes, some relating to hiring practices, others tied to access to all parts of farms, plants and storage areas. Even just adding security cameras and outside lighting can make a difference.
On the road, tanker security has been one area targeted for improvement. “Any unauthorized opening of a tanker before its delivery to a processing plant is immediately evident thanks to new security protocols,” Detlefsen says.
Byrne cites similar projects in place around the country. “We have guidelines for tanker security that have been implemented across the board, and we’ve had more awareness on the farm due to some of the measures we’ve recommended for farm security,” he says.
Still, says Byrne, there is an understanding that some vulnerability will remain. “We are doing this while still recognizing that we live in a free society and enjoy those freedoms.”  
Lynn Petrak is a freelance journalist based in the Chicago area.

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