Legacy of Safety Continues
by Lynn Petrak
From HACCP to high-tech equipment, testing to tamper-proofing, dairy processors stretch the safety net on their products and processes.

It’s been more than a century since the first commercial milk pasteurization machines were introduced in 1895 and nearly 100 years since the first compulsory pasteurization laws were passed in 1908. With that kind of history, it is hard to take issue with those who note that dairy producers have demonstrated an early and aggressive commitment food safety.
“We have been more proactive versus other industries,” agrees Marianne Smukowski, dairy safety applications coordinator for the Wisconsin Center for Dairy Research, noting the more modern examples the industry’s voluntary commitment to the Hazard Analysis Critical Control Point (HACCP) programs.
Indeed, in the past century that spawned safety initiatives right along with the growing commercialization of dairy products, there have been scores of tools, pasteurization and HACCP systems among them, in the farm-to-fork fight for food safety. From sterilized milking machines and safe and effective vaccinations on the farm to increasingly rapid testing of milk and products at various stages in the dairy processing plant to the ever-stringent sanitation practice, safety is a part of what every dairy producer and manufacturer does every day for every single animal or product.
Closer to the “fork” side of that safety net, meanwhile, there remains an area of vulnerability. According the U.S. Department of Agriculture (USDA), 97 percent of all foodborne illnesses can be prevented by improving food handling practices at home. In this area, too, dairies continue to improve communication with consumers, through clear labeling and educational messages.
The combined work over the years has paid off for those who produce and consume dairy products. In a recent report, the Centers for Disease Control and Prevention (CDC) in Atlanta, in collaboration with the Food and Drug Administration (FDA) and USDA recounted declines in foodborne infections due to common bacterial pathogens, with incidences of Salmonella dropping eight percent, E. coli O157:H7 skidding 42 percent and Campylobacter decreasing 31 percent. (The news was a bit different for Listeria, with the CDC reporting that the rate of Listeria-related foodborne illness rose in 2005 from 2.7 cases per million to three cases per million).
Even with the arrow going in the right downward direction for many foodborne illnesses, there is obviously more work to be done and more work that is being done by dairy farmers, dairy manufacturers, researchers, laboratories, industry organizations, government agencies, retailers and foodservice operators.  “Foodborne disease is still a significant cause of illness in the United States and further efforts are needed to sustain and extend these important declines and to improve prevention of foodborne illnesses,” remarked Dr. Julie Gerberding, director of the CDC, in a statement last year.
The CDC chief’s assessment is shared by those in the industry who carry the mantle of safety on a daily basis in their respective dairy plants. “It’s ever changing and we have to keep on the edge of change. You have to anticipate what could happen and take care of it beforehand,” says Emil Nashed, vice president of quality control and research and development for Wallington, N.J.-based Farmland Dairies Inc., of his company’s comprehensive safety and quality program.
Michael Neuwirth, spokesman for The Dannon Co., White Plains, N.Y., concurs. “We are vigilant about safety, in terms of taking precautions to protect our employees and to ensure the safety and quality of our products for consumers,” he says.
Roadblocks
To be sure, there are quite a few acronyms tossed about in the lexicon of food safety. Plant employees have to be well versed in the ABCs of safety, and in particular, the GMPs, SSOPs, HACCPs, PMOs and other shorthand terms for important programs geared to preventing contamination in the perishable food chain.
Many point to organized HACCP programs as effective ways to stem food safety problems before they start and cause problems at the finished product level. Although still voluntary for those in the dairy industry, many plants have instituted such programs on a range of levels and several have become HACCP certified by the FDA.
“It’s proven very successful for us, and it’s a good program because we also have SSOPs and SOPs for every step of the operation, from the time milk comes in to the time it goes on the truck. There is protocol that needs to be followed all the time and validated on a regular basis to make sure it’s been done,” Nashed says of Farmland’s HACCP program, which is the largest dairy plant that has received formal certification from the FDA. “It gives a sense of accountability — that I know I can be home at night sleeping well. My philosophy is: My children drink our milk.”
Training on HACCP continues, conducted through industry organizations or independent consultants. The International Dairy Foods Association (IDFA), Washington, D.C., continues to successfully sponsor HACCP workshops, including an upcoming program in late October in Las Vegas.
“We are getting a lot more interest from the dairy industry and are partnering with universities to sponsor additional HACCP workshops. We went through a period when they [operators] would say, ‘I know what HACCP is, but I’m am not sure we understand how it can contribute to our bottom line and make it work for us.’ Now, there is a better industry understanding of HACCP’s value, and the response is more ‘How can I better understand it to make it work effectively for me?’” says Allen Sayler, IDFA’s senior director of regulatory affairs. “It takes comprehensive training and implementation to realize the full value of HACCP to the dairy industry.”
The Wisconsin Center for Dairy Research is also continuing its training programs on HACCP, according to Smukowski, sponsoring regular short courses on the topic. She, too, underscores the effectiveness of the system: “The industry has done it for several years, and that’s why we have a good handle on addressing issues with dairy and safety.”
Food safety programs comprise a variety of elements that may be part of HACCP programs. One of the foundations is FDA’s regulations for current good manufacturing Practices (GMPs). As plant operations comply with GMPs and train employees about what those practices are and how to follow them, industry organizations are also working on behalf of dairies on the regulatory front.
IDFA helped represent the dairy industry’s position, as part of an industry-wide coalition, to the FDA as that agency continued its process of determining updates for GMPs for foods. “IDFA members felt strongly that there were specific dairy issues that needed to be voiced — that sometimes we had unique views that differ slightly from other food sectors,” Sayler says, adding that IDFA submitted comments to the FDA, which had asked for public comments on a white paper published last year.
“We recommended that GMPs shouldn’t contain specific time/temperature requirements for holding foods but instead more general performance criteria. For example, we felt it was appropriate that industry have training on GMPs for employees, but we felt FDA shouldn’t be dictating content, frequency and other details, but just determine that such training was in place.”
IDFA took a similar position on other FDA white paper issues such as written sanitation programs for processing equipment, Listeria environmental monitoring and an allergen management program, which IDFA noted should be addressed by the industry but specific records related to these programs should not be accessed or driven by the government.
As processors look to set up interventions along the way, either as part of formal HACCP programs or another type of commitment to safety, they are increasingly boosting their efforts in sanitation, taking advantage of the latest in sanitizers and cleaners for personnel, work surfaces and machinery, and clean-in-place (CIP) features for equipment. “We are always upgrading our equipment and switching chemicals and looking for the latest in sanitation,” Nashed says, citing recent upgrades like the plant’s refrigeration system.
Changes and Improvements
As dairies upgrade food safety programs and equipment and systems designed to prevent contamination or spoilage during processing and transport, there have also been efforts to re-evaluate regulatory requirements that are required for Grade A dairy products.
IDFA, for its part, is working to ensure safety while helping dairy processors run their plants efficiently. In the last year, Sayler has managed, on behalf of Grade A processors, the gathering of information through literature searches, scientific reports and challenge studies, to convince FDA of the safety of filling of cultured and acidified products like sour cream, yogurt, buttermilk and cottage cheese at a temperature above 45 degrees. “Each of these products has slightly different characteristics and different challenges when you are trying to cool them,” Sayler says. “FDA said they’d be willing to work with us and not object to current industry filling and storage practices as long as we were working in good faith to supply scientific evidence to support a change to the regulations.”
As a result of the collaborative efforts, Sayler reports that sour cream, buttermilk and yogurt can now be filled above 45 degrees. “It’s a huge thing for processors, because it provides the scientific underpinning for industry practices we always knew was safe,” Sayler says, noting the alternative would have translated into real challenges for processors. “If we weren’t successful with this, a processor would have had to install additional processing equipment or stop production of these products. For example, with a product like cottage cheese, you need that higher temperature for the cream dressing to be absorb into the curd to get the desired texture and mouth feel the consumer expects.”
Similarly, IDFA focused on quality and safety in production in working with the government on changes to the federal Food Codes dictating how products like cheeses must be held for safety, including storage temperatures.
“The Food Code dictates specific temperatures that food must be held at retail and food service establishments, whether it is the time and temperatures that hot food must be held hot or cold food held cold. There were concerns that certain cheeses may be safe if held out of the required 41 degree F temperatures,” recalls Cary Frye, IDFA’s vice president of regulatory affairs, recounting that IDFA collaborated with researchers and the Wisconsin Department of Agriculture Trade & Consumer Protection (WDATCP) to submit a proposal to the Conference of Food Protection recommending that the Food Code be amended to exempt specific cheese from the current 41-degree storage and display requirements. “We’ve moved it forward in that NCI [National Cheese Institute] was directed to work further with FDA on this matter. This is the beginning of a project designed to apply current science to cheese safety.”
Smukowski is also heavily involved with the cheese storage issue. “We’ve been getting a ton of questions on that,” she says, noting that she and colleague Rusty Bishop wrote a paper on the topic, relating the Center’s research on cheeses and storage temperatures that will be published in an upcoming publication of Journal of Food Production Trends.
Valide and Verify
Just because a product goes through the process stage doesn’t mean it’s automatically deemed safe. Testing is an integral tool used by all types of dairy manufacturers to validate the quality and safety of the product at various stages in production.
In addition to tests that take place on the farm for animal health and raw milk, myriad tests are conducted in dairy processing facilities.
Whether performed in a company’s own laboratory, sent to an outside lab or checked in house by a third party, tests today are designed to be more reliable and fast. The expanded use of adenosine triphosphate (ATP) biolumincnece testing is one example, through which potential contaminants are identified by the detection of light emitted from living organisms. Processors use luminometers to check work surfaces and, in some foods like meat carcasses, the product itself.
Farmland, for its part, uses an array of evaluations in its dairy facility, including ATP bioluminescence tools. “That is a good technology, because instead of waiting five days, you wait two days. You can get on-the-spot results and know what we are doing,” Nashed says. “We are looking at anything new to enhance food safety.” Farmland has its own certified lab and also uses outside testing services.
Silliker Inc., Homewood, Ill., handles a steady stream of dairy samples through its microbiological testing services, according to Kathy Alamo, operations manager, dairy program for the company’s Modesto, Calif.-based Northern California Laboratory. “Most food processors use third-party testing for the obvious reason of keeping pathogens out of their plants,” she says. “We are seeing an increase in popularity of third-party auditing among dairy companies for internal benchmarking and to meet customer vendor requirements.”
Cleveland-based Pierre’s Ice Cream, which has a robust HACCP program that has been recognized by the state of Ohio, also takes advantage of third party audits and conducts extensive testing of its facilities and products. Among other tools, the company conducts Listeria testing on all of its finished products, which is not mandatory and, for that matter, not common in the industry. “Nothing is released from the production building over to the distribution building until it clears all the batteries of tests,” reports plant manager John Gaughan. “Each product is evaluated daily by the operator, by the flavor man, by our quality manager.”
Safety With Security
In the farm-to-fork chain, production, processing and testing are usually followed by packaging. In that area, many of food safety measures are targeted toward ensuring the integrity of the package, through its material and closures, to prevent any leakage or deliberate or accidental access.
In the wake of biosecurity concerns and subsequent steps taken by food manufacturers in the wake of bioterrorism concerns and government-led protective measures, tamper evidence has become one of the priorities of those that bottle or package dairy products. Suppliers have helped button up packaging, so to speak, with tamper-resistant and tamper-evident caps and closures, with features ranging from pull tabs with rings to foil or plastic overwraps on tub products to seals and bands around ice cream carton lids.
As processors experiment and apply innovations in package features driven by the need for biosecurity, the industry itself also must keep an eye on regulatory issues affecting package design. In the past year, IDFA worked with several of its members to provide input to the FDA on a protocol concerning the agency’s testing for tamper detectability of plastic milk container closures.
In mid-August, FDA released its final protocol. “There were points in the protocol that would be helpful to processors. It’s not approving one type of closure over another or requiring a foil seal, for example, but it’s based on how containers and closures together function properly,” says Michelle Matto, IDFA assistant director for regulatory affairs.
Emerging Issues  
Preventing foodborne illness and ensuring safety and quality through pathogen control has long been the directive of safety initiatives within and beyond the processing stage.
While Salmonella, Listeria and other microbes have garnered a lot of attention and newer bugs of concern like Mycobacterium paratuberculosis are spurring a closer look within the industry, another emerging safety concern in recent years has been related to allergens. With last year’s passage of the Food Allergen Labeling and Consumer Protection Act, dairies have been ramping up their efforts related in this area. Dairy is listed as one of the eight top allergens, and many dairy plants use other allergens, such as tree nuts and wheat.
At the Wisconsin Center for Dairy Research, Smukowski reports she is fielding more queries about allergens among dairy businesses. “I get a lot of questions on the situation and I think there is some education that can be done in the allergen area and with labeling,” she says. “There is always training that needs to be done and it all ties into the food safety system.”
Silliker’s Alamo agrees. “Allergens are of increasing concern to dairy processors in connection with various ingredients in ice cream and yogurt formulations,” she says, adding that the industry is well suited to getting out in front of the issue before there are major problems. “Historically, the dairy industry has taken the lead in food safety — not only from the regulatory standpoint, but also from the competitive aspects of protecting brands and reinforcing the image of dairy as nature’s most perfect food.”
At the individual dairy company level, meanwhile, manufacturers are heeding the importance of proper labeling and production as those functions relate to allergens.
Dannon, for instance, recently rolled out a new Light & Fit Crave Control product that contains the listed allergen of wheat, and notified the Food Allergy Action Network (FAAN), Neuwirth says. FAAN was informed that the new reduced-sugar nonfat yogurt made with fruit, cereal and ProteinFiberPlus is the only Dannon product to contain wheat.  
Lynn Petrak is a freelance journalist based in the Chicago area.