It’s curious why FDA in their writing and publication of the “Current Good Manufacturing Practice, Hazard Analysis, and Risk-Based Preventive Controls for Human Food; Final Rule,” address equipment sanitation in Subpart A, Definitions, Subpart B on GMPs (117.35, 117.40, 117.80) and Subpart C on Preventive Controls (117.135). 

The Food and Drug Administra-tion’s time-clock for enforcing the most important FSMA regulation, the “Preventive Controls for Human Foods (PCHF)” started in mid-September 2016. As I write this in early December, it appears that FDA will be training its field investigators and regional milk specialists well past the end of 2016.

It is easy to include “avoid a recall of a dairy product “in your company vision statement or plant’s goals. It is relatively easy to write a recall program that you hope will never be used.

The experience acquired through years of hands-on processing is at risk of being lost as plants adopt automation. While IT knows computers, production personnel’s hands-on knowledge of how equipment works contributes to food safety. The upshot? Balance the two.

There is value in milk’s components. Filtration technologies can help you unlock proteins, whey derivatives, sugar and fat. You can use these to manufacture foods and beverages or sell as ingredients.

The high temperature/short time pasteurization process has been a reliable workhorse in dairies for years. But there are alternative technologies that treat raw milk without heat. Some are in use in other countries.

There is no school for dairy plant production workers. It is up to you to teach food safety and plant safety. Then you have to observe that the teaching has been understood.

"Are we there yet?” Many senior plant and dairy corporate leaders are wondering when the journey will end regarding full implementation of the Food and Drug Administration’s Food Safety Modernization Act.

I love a parade except when it’s a never-ending march through my plant by inspectors from federal or state agencies or auditors sent by customers or third-parties.