Food Safety Plan Guidance: Dairy Based Products

Dairy products currently fall under the regulatory rules of the United States Food and Drug Administration’s Food Safety Modernization Act Preventive Controls for Human Food. This plan guidance page will walk through the basics of developing a food safety plan for dairy products.

Types of Companies this Guidance is Intended For

  • Restaurants that retail products
  • Food manufacturers

Types of Food Products this Guidance is Intended For

  • Butter (salted and unsalted)
  • Cheese products
  • Cream cheese
  • Custard products
  • Dairy-based desserts
  • Dry Milk Products
  • Eggs
  • Ice cream
  • Milk (pasteurized and raw)
  • Sour cream
  • Whey
  • Yogurt

Example Process Flow

The process flow of a food safety plan (HACCP or Preventive Controls) is the center of a food product’s food safety story. It tells how a company makes it’s products and also what hazards and controls are associated with each step. Here’s an example process flow for butter:

Example Hazards

Most dairy products contain biological food safety hazards. Here are a list of a few per type of dairy product:

Butter – salted

  • Low risk – Little to no hazards

Butter – unsalted

  • Psychotrophs — Listeria monocytogenes

Eggs

  • Enterobacteriacae — Salmonella
  • Enterobacteriacae
  • Chemical residues
  • Allergens

Ice cream

  • Biological — Psychotrophs — Listeria monocytogenes

Milk (pasteurised)

  • Psychotrophs — Listeria monocytogenes
  • Allergens

Cheese

  • Allergens
  • Psychotrophs — Listeria monocytogenes

Associated Components of the Food Safety Plan

The following associated food safety components are recommended to achieve compliance with the Food Safety Modernization Act.

Good Manufacturing Practices and Other Prerequisite Programs

The Food Safety Plan (HACCP or Preventive Controls) is not a stand alone program, but rather part of a larger food safety system. The foundational programs that are part of the food safety system are frequently termed prerequisite programs. The term was coined to indicate that they should be in place before HACCP based systems are implemented in order to effectively manage risk from foodborne hazards. The Current Good Manufacturing Practice (GMP) regulations address requirements for many prerequisite programs. The regulation (117 Subpart B) that outlines the conditions and practices the regulated food industry must follow for processing safe food under sanitary conditions, including personnel, plant and grounds, sanitary operations, sanitary facilities and controls, equipment and utensils, processes and controls, warehousing and distribution, and defect action levels considerations. Elements of GMPs that are not covered in the Food Safety Plan are still required by regulations.

Standard Operating Procedures (SOPs)

SOPs are related to both GMPs and Controls of Hazards in the Food Safety Plan. SOPs define the specific steps of how GMPs and Controls of Hazards mitigate food safety hazards and define a repeatable process.

Here is a list of suggested SOPs:

  • Cleaning and Sanitizing Food Contact Surfaces
  • Storing and Using Poisonous or Toxic Chemicals
  • Preventing Cross-Contamination During Storage and Preparation
  • Receiving Deliveries
  • Cleaning Building and Facility
  • Allergen Control Program
  • Washing Hands – To prevent foodborne illness by contaminated hands
  • Employee Illness Program
  • Using Suitable Utensils When Handling Ready-to-Eat Foods

Supply Chain

The safety of your product depends on much more than just what you control within your own facility. Use of an ingredient that has a history of association with a specific hazard may require a supply chain program as a control within your food safety program. Companies may have extensive supplier programs that encompass much more than food safety elements to manage their supplier expectations and performance.

Here is a list of suggested documents to obtain from your supply chain:

  • Food Safety HACCP or Preventive Controls Plan for each product
  • Food Defense/Business Continuity Plan
  • Validation of each product and/or process and Ready-To-Eat statements (if applicable)
  • Certificates of Analysis (COA)
  • Third Party Audit Certificate, Report & Corrective Actions
  • Product Specification
  • 100g Nutritional Information
  • Allergen Grid / Statement
  • SDS / MSDS Statement
  • GMO / Non-GMO Statement
  • Country of Origin
  • Kosher Certificate (Provide Yearly when due)
  • Halal Certificate (If Applicable)

Records / Logs

Monitoring records and logs must include the actual values or observation that document the actual implementation of a Food Safety Plan . For example, if a temperature is being measured, the actual temperature must be recorded rather than a checkmark indicating that the temperature complied with the critical limit. To comply with regulations, information must be recorded at the time it is observed.

Here are suggested record and log types to use with most dairy products:

  • Customer Complaints
  • Corrective Action Forms
  • Employee Training
  • Food Safety Quarterly Audit
  • Food Safety Checklist
  • Raw Materials Log
  • Worker Illness Log
  • Finished Product Identification Plan

Recall Plan

According to the Food Safety Modernization Act, Preventive Controls for Human Food regulation requires the development of a written Recall Plan when a hazard analysis identifies a hazard requiring a preventive control. All dairy based products have a process control. Recalls are actions taken by an establishment to remove an adulterated, misbranded or violative product from the market. In other words, a product for which FDA or a state could take legal action against the company would be subject to recall.

Validation / Verification

Verification is an important component of supply chain, sanitation, allergen and process preventive controls. It confirms that the Food Safety Plan is operating as intended. Validation confirms the effectiveness of the Food Safety Plan in controlling food safety hazards. The purpose of verification is to provide a level of confidence that the Food Safety Plan is 1) based on solid scientific principles that are adequate to control the hazards associated with the product and process, and 2) that the plan is being followed correctly every day of operation.

Laboratory testing is suggested for dairy hazards:

  • Listeria
  • Bacteria — Staphylococcus aureus

Recomnended ConnectFood Package For Dairy Based Plans

Software Package Type

Premium for GMPs, SOP templates, Recall Plan, and the six records. A minimum of one month subscription is required.

Expert Services (optional)

Review Existing Plans to have a ConnectFood Expert partner review and ‘sign off’ on your plan and Review Standard Operating Procedures to review allergen and sanitation procedures.

Get Started With Your Dairy Based Food Safety Plan Today!

Save time by registering for an account with ConnectFood and loading one of the dairy food safety plan templates. With the Premium package, you will have all of components (SOPs, Records, GMPs, and more) accessible with a few clicks to give you a comprehensive and compliant food safety plan. If you ever have need additional assistance with writing or get a review of your plan, ConnectFood On-Demand Expert Services is always available.