The Nourisher - Editor’s Blog

Upon my request Mark McAffee from Organic Pastures Dairy in California, has offered some suggestions as to what we need to ask FSANZ for in our submission regarding Raw Milk Safety (Project 1):

1. Follow the guidelines for raw milk certifications set out by Raw USA
2. No commingling of raw milk sources… must be from one inspected source.
3. TB free herd testing.
4. Must be tested according to a set standard established by laws and regulations of the authorities of the area where it is sold.
5. Less than 20,000 SPC on one time per month test by certification agency on finished products
6. Zero pathogens including, Listeria M, Ecoli 0157H7, Salmonella, Campylobacter in finished products
7. Pathogen tests performed one time per month by independent testing and certification agency.
8. Worst pathogens ( ecoli 0157H7 ) tested more frequently ( at least once per week by farmer with results sent to farm and the certification agency ).
9. Active Farm Food Safety Plan based on HACCP principles to identify risks and manage them. This plan is tested for compliance.
10. Raw Milk must be labeled as Raw Milk

Mark also says, “Raw milk will be safe if the conditions are safe and natural. Must get rid of high grain diets and antibiotics and wet conditions. They bring on pathogens in manure like crazy.”

Below is a portion of the HACCP plan Mark sent us. This is the plan Organic Pastures Dairy use. Australia’s Doctor Ron Hull (microbiologist and ex-CSIRO scientist) was instrumental in helping Organic Pastures create this plan. I’ve highlighted parts I consider important and additional to the above.

Risk Analysis & Management Program ( HACCP ) for production of Raw Milk products

Organic Pastures Dairy Company was founded in 2000 by the McAfee Brothers when it was discovered that the consumers of California did not have access to pasture grazed living fresh raw milk. The business objectives have always held as their core value the careful listening to consumers needs and desires. As a result, OPDC brought forth a full line of fresh raw milk products. These living food products are now sold in 300 California stores and are consumed weekly by more than 35,000 delighted consumers .

Our food safety plan is driven from this core belief in consumer health and wellness. Our plan is called RAMP and is based on HACCP and the principles of comprehensive RAMP of those potential risks. In cooperation with natural biodiversity and its built in bacterial competition systems, RAMP manages and reduces raw milk risk dramatically and reliably.

OPDC owners, managers and employees hold food safety as the highest priority.

The CA Raw Milk RAMP plan is different from other conventional HACCP plans and contains a continuous persistent active immunity “Kill Step”. Raw milk is a unique living food and differs from all other foods. Raw milk innately contains many different enzyme, and bacteriologic systems (organic acids and others) that actively kill pathogens when and if they are introduced. These immunologic systems, enzymes, specialized proteins and pro-biotic bacteria are not injured or reduced by RAMP but instead they are relied upon as an integral part of our food safety system. The RAMP system protects these living protective immunologic systems from harm. Harsh sterilizers, heat and sanitizers can damage raw milk and injure enzymes and bacteria and increase potential food safety risk.

Most HACCP plans include a processing induced “Kill Step” ( such as pasteurization ) to kill bacteria and potential pathogens. RAMP uses both the innate pathogen killing systems ( active immunity ) in raw milk and the advancements in pathogen detection technology. Through testing the possible entry points of contamination, a dramatic reduction of the possibility of initial introduction of food born illness pathogens or other contaminants can be achieved.

As a result of RAMP, safe raw milk food products are alive with immune system rebuilding components that have positive effects on the humans that consume them. Pasteurized and processed products with an active external “Kill Step” can not impart these living immune system rebuilding values to its consumer. Pasteurized milk and dairy products have lost their innate active immunity and completely different standards and controls must be applied.

Lastly, consumer immunologic improvement is the final invisible, unmeasured component in this food safety plan when viewed in total. Consumer immunity inclusion is part of RAMP and breaks new ground in overall food safety for California raw milk. Previous HACCP plans continuously degrade food biodiversity by adding “Kill Steps”. These sterilized or over-sanitized foods often decrease the immune health benefit to the final consumer, further weakening the consumer and making consumers more susceptible to food born disease. RAMP allows foods with active immunity to become a natural part of California’s consumers diets for those that choose this food.

As part of this approach certain families of bacteria including Coliforms that may appear “not helpful” in other HACCP plans become essential to the vital biodiversity that inhibit pathogens in Raw Milk.

RAMP includes five major areas of management:

1. Environmental Management
2. Herd health husbandry
3. Milking
4. On Farm Creamery
5. Storage and Distribution

The objective of the Organic Pastures, Farm Safety Plan is to create an environment in which:

==> High quality safe raw milk is assured to a high degree of certainty;

==> Elevate the public perception of raw dairy farming as the premier system for milk quality and safety;

==> All food chain and production risks are analysed and managed on a continuing basis;

==> Environmental stewardship and animal welfare are managed as high priorities:

==> Actual standards on the farm are monitored, documented and strengthened.

ENVIRONMENTAL MANAGEMENT

• All pens shall be kept Clean and all pastures shall be kept Green.
• Measures will be taken to assure that cows are healthy and not stressed.
• When pastures have been grazed the cows are moved to new pastures and the consumed pastures are irrigated to regrow, revitalize forage and grass.
• Fencing around paddocks, tracks and yards should be in a good state of repair to secure stock control.
• Pastures should be maintained and grazed in such a way that they provide adequate and safe nutrition to the herd. Where possible noxious weeds should be controlled in the pasture. Pasture should be free from chemical residues.
• Cows should be managed when grazing so that consumption is not deleterious to their health.
• Stock water must be adequate, clean, fresh and of high quality. Free of excessive salts, Algae, Dung, pathogens etc.
• Water must be available in adequate amount to avoid any competition for water during hot periods.
• Adequate shade must be provided during times of heat stress.
• Assess and ensure that your property is free of persistent chemicals.
• Any risk sites should be fenced off from livestock.
• Grazing of dairy stock should only occur where past history of chemical usage is known and all relevant withholding periods have been adhered to.
• Any muddy areas are to be fenced off to exclude animals until the areas are revitalized.
• All confinement pens will be kept clean and scraped to avoid muddy areas or waste build up.

HERD HEALTH HUSBANDRY

• A designated person must have overall responsibility for the herd. This person must be able to manage the herd and associated dairy farm activities.
• The designated person has a duty to ensure that all staff with responsibility for cows have knowledge of and assure the five freedoms of animal welfare. The five freedoms are:

==> Freedom from hunger, thirst and malnutrition
==> Freedom from discomfort
==> Freedom from pain injury and disease
==> Freedom from fear or distress
==> Freedom to express most normal patterns of behaviour

PERMANENT IDENTIFICATION OF STOCK

GOOD PRACTICE

1. Permanently identify all stock
2. Purchased stock should be identified as they arrive on the property. Check withholding periods to be observed following any chemical treatments. Check disease status.
3. Permanently identify all calves at birth.
4. Maintain a register of all individual stock ID numbers
5. Record all details on purchased stock and their grazing, disease and chemical treatment history.
6. A Vendor Declaration form should accompany stock purchased. This should state the animals are TB free and all other required state or Federal veterinary requirements.
7. The purchased stock are free from residues and withholding periods of veterinary chemicals have been observed.

Water

1. Organic Pastures encourages the efficient use of water. Understanding the water needs of soils or pastures, and controlling how much water, where and when it is applied, are fundamental principles of good management.

Best Management Principles are:

• Understand water storage (holding ) capacity of the soil in the root zone of plants.
• Know how much water you apply.
• Match the application rate to the rate at which water is absorbed
• Understand when to irrigate by measuring soil moisture .
• Apply water evenly with well maintained and designed irrigation equipment.
• For flood irrigation, laser level bays and adopt an automated system.
• Where possible incorporate weather forecasts into irrigation decisions.
• Establish drains that collect runoff and re-use the water.

SALINITY

The effects of salinity are far-reaching. Not only does it lead to a reduction in the productivity capacity of affected land, but also to degradation of the environment and wildlife habitats, loss of water quality for household supplies and damage to household equipment.

MANAGING SALINITY

The main salinity control options for farmers focus on lowering the watertable. This is achieved by using water productively where it falls. No one option is sufficient - rather a carefully planned and integrated management approach that considers all of the issues in the local catchment is needed.

Salinity control options include:
• Property management plans
• Monitoring soil and water salinity
• Planting deep rooted, high water using trees and plants
• Planting salt tolerant species
• Fencing out livestock
• Removing sub-surface water
• Monitoring watertables
• Improving irrigation technology
• Irrigation scheduling
• Drainage reuse systems
• Laser grading of irrigation bays
• Quicker watering

EFFLUENT DISPOSAL

No solid or liquid waste from any intensive animal industry or milking shed operation shall be disposed of (irrigated or spread) in the following locations:

• All on farm wastes will be disposed of on the farm through the flood irrigation system as allowed by law.

• All waste milk will be managed through irrigation systems.

FEED AND CALVING PADS

• Feed and calving pads must be constructed of materials that do not adversely affect the herd animals. (Note: some saw dusts are very good at breeding mastitis pathogens).
• If animals are to be held for an extended period, sufficient space needs to allowed for cows to lie down on feed and calving pads. A separate loafing area may need to be constructed as concrete is not a suitable material for cows to lie on.
• Adequate drainage is required for both pads and loafing areas. This is important for animal welfare and to avoid mastitis infection.
• Shade may be required in hot conditions with sprinkler systems to cool the animals.
• Calves are to be managed and cared for with special attention to their needs.
• Bedding must be changed regularly to reduce moisture and assure clean environment.
• Hutches shall be moved frequently to new areas to allow sun shine to kill pathogens and dry the hutch areas.
• All hay storage areas shall be dry and clean. No moldy hay shall be fed to cows.

MILKING

Location

• The OPDC Mobile Milk Barn shall be moved weekly to reduce manure accumulation and wet conditions and pasture degradation.
• The dairy shall be ideally sited to minimise the risk of flooding, objectionable smells, smoke, dust and other contaminants.
• Only activities relating to the handling of milk and milking equipment may be carried out in the dairy.

Access and milk collection
• Farm animals shall not have access to the tanker road and tanker roads shall not be used for the holding of animals.
• Equipment that has any moving belts, pulleys or shafts should be covered with safety guards. If these are removed for maintenance they must be replaced before use.
• The dairy shall be sited separately from contamination sources e.g. animal housing, dung heaps, slurry pits, silage pits, feed and grain stores, diesel stores etc.. It must be well managed and kept clean and tidy, free of rubbish and generally in a good state of repair.
• Due care must be taken to avoid contamination of milk by chemicals, inappropriate feeding, unhygienic practices or foreign bodies. Cleaning chemicals should be stored in a separate room away from milking areas if possible.
• Measures must be taken to minimise the entry of birds and vermin and to control flies.
• The dairy should have adequate ventilation and be designed for ease of cleaning with walls being smooth, impervious, sound and well maintained. This includes:

==> ceilings and walls intact and free of flaking, paint, dust and cobwebs.
==> lighting in the milk room with a switch easily accessible to the tanker driver.
==> a sound floor that allows free draining of liquids and easy disposal of waste.
==> preferably suitable hand washing facilities including hot and cold running water and paper towels for drying.
==> suitable vat washing facilities so tanks are kept clean both internally and externally.
• No smoking in the dairy during milking.
• Protective clothing used at milking times should be clean and used only for milking.
• Milking must be carried out hygienically. The milker must wash hands immediately before milking and as often as necessary during milking.
• A water hose must be available for the personal hygiene of the milking operator and the washing down of soiled cows, equipment and standings
• The pit and milking area must have good drainage to allow ready cleaning.
• Water supplied to the parlour should be of sufficient quantity and of drinking water standard.
• External surfaces of pipe work, sight glasses, clusters and jetters must be kept clean.
• There must be appropriate procedures in place for the cleaning of milk pipelines, clusters, sight glasses and jetters. Cleaning must take place after each milking.
• Milking machines should be regularly serviced and tested at least annually by a qualified person.
• Liners should be regularly inspected and, as a minimum, replaced at the intervals recommended by the supplier.
• Persons with infectious diseases or undressed wounds, may be liable to contaminate raw milk. They must not handle raw milk.
• The water heater should be regularly maintained and suitable for the purpose. It must be able to deliver water to wash the plant with minimum 185 degrees F.
• Cows udders should be clean and dry before milking.
• Teats will be pre dipped with iodine, stripped and then cleaned with separate dry cloths.
• At least 30 seconds will be allowed for teat stimulation for milk let down.
• Milk parlour standing areas will be kept clean by washing down prior to machines being placed on cows.
• Udders will be kept dry and no wash water shall be applied to udders except when udders are exceptionally soiled. In these cases they are to be dried thoroughly prior to machine application.
• Cloths shall be single use and kept in dry clean area.
• Milk from the first 8 milkings after calving must be withheld from the tank and used as colostrum.
• Cows whose milk is unfit for human consumption, must be clearly identified and must be milked last or with a separate bucket system and that milk discarded.

MILKING PARLOR

• The same structural and cleanliness standards for walls, ceilings, drainage, ventilation and lighting apply to the milking parlour as for the creamery.
• The milk barn must have non slip floors and be designed and constructed to minimise risk of injury to cows and ease of cow flow with comfortable positioning.
• The milk barn shall have sufficient lighting to allow for easy identification of animals and good visibility during milking. The dairy should be designed to enhance free and contented cow flow.
• Collection yards should be regularly cleaned and kept free from any accumulations of muck or slurry.
• Parlour railings and feeders should be sound and in a good state of repair,
• The parlour must be separate from contamination sources.
• All CIP and chiller milk temps shall be recorded on recording chart recorders.

MILK COOLING AND REFRIGERATION

Cooling Units – Silo Tanks

• Milk immediately after leaving the cow shall be chilled to less than 40 degrees F within 1 minute and kept at or below that temperature and until delivered to the final consumer or retailer storage area.
• Silo room doors shall be of standard door height with steps and hand rails are to be provided where appropriate to allow safe access.
• Tank rooms are not to be used for the storage of colostrum in drums. Any colostrum in holding tanks should be clearly labelled and separate from raw milk.
• The top of tanks must be clear of any items and are not to be used as a storage place.
• Tank lids are to be closed.
• All stainless steel is to be kept clean and polished inside and outside.
• All the necessary signage to meet the confined spaces legislation must be displayed.
• Wash cycles need to be performed within a half hour time frame.
• Ideally a sampling cock will be present in the manhole door to allow access for sampling. This sample cock must be readily cleaned.

ON FARM CREAMERY

Actions

• All cleaning is documented clearly on a recording chart. Regular inspections of the milk contact surfaces should be carried out to check thoroughness of cleaning.
• Plants should be cleaned after each processing step. All milk detergent residue and sanitiser should be removed except for designated food contact surface sanitisers.
• All plant surfaces shall be checked using ATP systems or visual methods to assure cleanliness.

Recommended CIP – COP Cleaning Procedure

1. Rinse with cold/warm water (20-40 deg F ) plus a rinse aid if required

2. Hot Water (80-85 deg) plus an acid detergent

3. Rinse with hot water (80-90 deg) OR/ Rinse with cold/warm water (20-40 deg) plus a sanitiser

Safety

• Use a separate cup to measure out each product as the products may react with each other and result in them being neutralised or lead to injury.
• Carefully follow label directions for all cleaning chemicals.
• Note carefully whether chemicals are to be added to water or water to chemicals.
• Do not mix chemicals unless following label directions.
• Storage of these chemicals must be in a separate lockable area.
• All processing surfaces will be cleaned and routinely tested using ATP
• Drains, and floors will be tested for listeria routinely.

CHEMICALS

All cleaning, disinfecting and vermin control products must be suitable for the food industry and be used in such a way that they do not contaminate the milk. All chemicals must be NOP compliant and no use of QUAT Ammonias allowed.

HAZARDOUS SUBSTANCES

Farmers have a responsibility to ensure that their work activities do not put at risk the health of others such as family and the public.

STORAGE AND DISTRIBUTION

OPDC operates delivery trucks and those trucks must be safe, clean well maintained, cold and reliable.

• Plastic cases will be sampled for listeria.
• Returned dairy products will be counted and disposed of according to appropriate end use.
• All trucks when returning from delivery will be washed out and cleaned.
• All plastic cases will be unloaded and washed and set to dry for use in the creamery.
• Trucks will be checked for maintenance before allowed to return to service.
• All class 2 trucks will be weighed prior to release to the road to assure legal weight limits are met.
• All loads will be secured for weight and balance prior to departure.
• All available plastic cases will be gathered when out on routes.
• All truck drivers will report any mechanical issues to management for repair.
• If cold chain is not kept at less than 40 degrees F contact management immediately.
• Prior to release to the road all drivers will complete the pre-trip check list to assure safety.
• Drivers to assure that all paperwork is included on the truck prior to leaving creamery or on route.

About the Author...

A Super Hero and one of many who have realised their true calling as saviors of humanity, healers of our connection with Nature and creators of Heaven on Earth. The Nourisher's gift is the re-spiritualisation of the 'process of recreation' we call eating. Mother of three Super Heroes in training and wife to her God incarnate, The Nourisher hails from the place of feminine healing, Byron Bay, Australia. She gathers together Life Creators from all over the globe at NourishedMagazine.com.au