Dairy operations, for the past several years, have been encouraged to adopt HACCP by their customers who believed that HACCP is an important part of total quality management.

HACCP (hazard analysis and critical control points), as defined by the Food and Drug Administration, “is a management system in which food safety is addressed through the analysis and control of biological, chemical, and physical hazards from raw material production, procurement and handling, to manufacturing, distribution and consumption of the finished product.”

HACCP has since become a globally recognized program for food safety and is now required by Global Food Safety Institute (GFSI) certification programs. A hazard analysis and risk-based preventive controls are now required for all food plants under the jurisdiction of FDA by the Food Safety Modernization Act (FSMA).

Recognizing the increased interest in HACCP, the 1997 National Conference of Interstate Milk Shippers (NCIMS) appointed a committee to address how a voluntary HACCP system should be implemented, evaluated, monitored and enforced as an alternative to the traditional inspection/check-rating system. The rules appeared to be simple:

• Utilize current National Advisory Committee on Microbiological Criteria for Foods (NACMCF) HACCP principles consistent with current FDA HACCP recommendations.
• Continue to assure at least the same level of milk safety provided by the traditional inspection/rating/check-rating system.
• Continue to provide uniformity and reciprocity under the HACCP alternative to the traditional inspection/ rating/check-rating system.

Six years later, after a pilot study at 13 dairy processing facilities in nine states, HACCP was adopted and published as Appendix K of the Pasteurized Milk Ordinance by the delegates of the NCIMS as a voluntary alternative regulatory system in NCIMS and PMO for grade A dairies.

Yet today, only 11 dairies in seven states are listed on the Interstate Milk Shippers list as participating in the NCIMS HACCP program. Why are so few participating in a program that seems to be a natural for meeting the requirements of customers, GFSI, and now FSMA?

Is the lack of participation the result of not having enough trained regulatory personnel available to monitor the program? At present, only seven states have trained regulators. Or are the dairy industry and regulatory agencies simply content with the check-rating system that has historically served the dairy industry?

As presently defined, the NCIMS HACCP program requires the standard elements of Codex and the current edition of the NACMCF HACCP principles and application guidelines with some very specific additions in the form of required prerequisite programs. The elements include the seven principles of HACCP, management commitment, product descriptions and a flow diagram.

All milk used to produce dairy products under the NCIMS HACCP program must come from an acceptable IMS-listed source with a sanitation compliance rating of 90% or higher.  In addition, NCIMS HACCP requires criteria such as drug residue testing, trace back to be in place and meeting all PMO labeling requirements.

Appendix K also requires specific prerequisite programs. Those programs that must be in place with a brief written description and checklist must address:

• The safety of the water that comes into contact with milk or milk products or product-contact surfaces, including steam and ice.
• The condition and cleanliness of equipment product-contact surfaces.
• The prevention of cross-contamination from unsanitary objects and or practices to milk or milk products or product-contact surfaces, packaging material and other food-contact surfaces, including utensils, gloves, outer garments, etc., and from raw product to processed product.
• The maintenance of hand washing, hand sanitizing and toilet facilities.
• The protection of milk or milk product, packaging material and product-contact surfaces from adulteration with lubricants, fuel, pesticides, cleaning compounds, sanitizing agents, condensate and other chemical, physical and biological contaminants.
• The proper labeling, storage and use of toxic compounds.
• The control of employee health conditions that could result in the microbiological contamination of milk or milk products, packaging materials and product-contact surfaces.
• Pest exclusion from the dairy plant.

It would appear that the dairy industry has a well written and thorough program available to them that, with a few modifications, will meet all of the requirements of customers and FSMA. The question is: Will FSMA require dairies to adopt the current NCIMS HACCP program or will they continue to operate with parallel programs, a voluntary NCIMS HACCP plan and the current check-rating system?