DAIRY INSPECTIONS: THE IMPORTANCE OF TRAINING
James Allyn, Bureau of Regulatory Services
The Connecticut Department of Agriculture (DoAg)’s dairy unit inspects and regulates dairy products from “the cow to the consumer” to ensure compliance with both state and federal laws and regulations. Included in this broad regulatory oversight are dairy farms, milk processing plants, yogurt manufacturers, cheese manufacturers, and bulk milk tankers (trucks).
Connecticut's dairy inspection program enforces not only the provisions of the state’s laws and regulations but also those of the U.S. Food and Drug Administration (FDA)’s Pasteurized Milk Ordinance (PMO). Compliance with the provisions of the PMO is an essential requirement for the sale of Connecticut’s dairy products in other states.
Connecticut is a member of the National Conference of Interstate Milk Shippers (NCIMS), a cooperative program between FDA’s Milk Safety Division and all states including Puerto Rico.
The standards applied in Connecticut follow national standards that allow milk and milk products to move without restriction in interstate commerce. FDA milk safety specialists routinely audit state dairy product safety programs to ensure that those programs are successfully upholding the standards set forth in the PMO.
DoAg’s dairy unit staff undergo continual training by FDA’s Milk Safety Division. This keeps them up to date with the rapidly advancing technology seen in many of the state’s dairy production and processing systems so that they can properly inspect and enforce Grade A dairy regulations.
In addition to identifying problems or violations that affect milk quality and safety and issuing enforcement actions, DoAg’s inspectors have an equally important responsibility to provide technical assistance when needed to help dairy facilities comply with state and federal regulations. Continual training is essential in serving this role.
FDA’s Milk Safety Division training programs are designed to standardize the dairy programs for all the states. This helps to ensure all Grade A dairy farms and processing plants are held accountable to the same standards and allows for interstate commerce. Connecticut’s dairy inspectors receive training by attending several FDA courses:
- The FD 375 Dairy Farm Sanitation and Inspection
course is one week of training. This course covers all aspects of conducting
dairy farm inspections, from understanding approved water systems to equipment
design and construction requirements. All the various types of milk systems
must meet the requirements in the PMO.
- The most recent technology within dairy
production is Robotic Milking Systems/Automated Milking Installations (AMI).
DoAg has sent staff for AMI training to understand how they operate and what is
required to meet the requirements of the PMO and state regulations.
- The FD 371 Milk Pasteurization Controls
and Tests course helps develop the understanding and skills necessary to
evaluate basic and complex pasteurization systems. Participants use pasteurizer
controllers, instrumentation, and perform hands-on practical sessions for
testing various parts of a pasteurizer. Whenever possible, a processing plant
field trip is integrated into the training to demonstrate product flow and
- The FD 372 Milk Plant Sanitation and
Inspection course helps participants gain knowledge and skills necessary to
evaluate and inspect the sanitary status of milk plants using the applicable
sections of the current edition of the PMO, 3A Sanitary Standards, and other
applicable guidelines. Classroom discussions, exercises, audiovisuals and milk
plant field trips help provide the participant with information regarding
inspection techniques, equipment and process control, identifying chemical,
biological and physical hazards, current quality assurance concepts, and milk
processing sanitary procedures.
- The FD 577 Special Problems in Milk
Protection course discusses current changes to the PMO and how they affect
regulating Grade A dairy farms and processing facilities. State Rating Officers
(SRO) are required to attend every three years. This course helps standardize
DoAg staff with their colleagues from other states as well as FDA Milk
- The FD 578 Advanced Milk Processing course discusses many key topics related to aseptic systems, Extended Shelf Life (ESL), and Higher Heat Shorter Time (HHST) systems. It also discusses computer controls, packaging and filling technology, and advanced Clean-In-Place (CIP) systems.
Connecticut’s dairy inspectors also receive training by attending Regional FDA Seminars, which are held every two years.
With the recent passage of the Food Safety Modernization Act (FSMA), DoAg’s dairy inspectors have begun training for FSMA based inspections. Recently, they attended a Preventative Controls Qualified Individual (PCQI) course jointly offered by the University of Connecticut and the University of Rhode Island to become qualified for FSMA based inspections. The three day course covered all aspects of developing a food-safety plan.
Dairy inspectors also have training in radiological sampling. This is part of a federal program directed by the U.S. Department of Homeland Security to have staff trained for any type of radiological event. DoAg works directly with the Connecticut Department of Emergency Services and Public Protection’s Division of Emergency Management and Homeland Security.
Radiological sampling involves the sampling of dairy products as well as other agriculture products after some type of a radiological event. Every six years the federal government evaluates DoAg staff for proficiency in taking various agricultural product samples.