Dairy-based Ingredients: Regulatory Aspects 377ises, surroundings, and operational ter-
ritories) in food protection- Food allergen control plan
* The manufacturer must address six
elements
— Training of processing and supervi-
sory personnel
— Segregation of food allergens during
storage and handling
— Validated cleaning procedures for
food contact equipment
— Prevention of cross - contact during
processing
— Product label review and label usage
and control
— Supplier control program for ingre-
dients and labels- Written environmental pathogen control
program for production of ready - to - eat
(RTE) foods that support growth of Listeria
monocytogenes (LM) - Written sanitation procedures
* Food processors are required to develop
and maintain written sanitation proce-
dures that defi ne the scope, sanitation
objective, management responsibility,
monitoring, corrective action, and record
keeping associated with the sanitation
procedure- Maintenance of critical records
Dairy Hazard Analysis and Critical
Control Points and Pasteurized
Milk Ordinance
Systems based on dairy hazard analysis and
critical control points (HACCP) and the
Pasteurized Milk Ordinance (PMO) address
industry requirements related to dairy food
safety. The National Conference on Interstate
Milk Shipments (NCIMS) promotes dairy
HACCP (grade A voluntary HACCP) to
enhance food safety in dairy processing
operations.
According to Howard Bauman (1974,
1995) , HACCP is a preventive system of
control based on a rational and logical process
of estimating the risk associated with produc-
ing and marketing a given food product.
Control of food processing may be obtained
and maintained through diligent, intelligent
application of the principles of hazard analy-
sis and the identifi cation of control points
that are critical to food safety (Bauman,
1974, 1995 ). According to an advisory com-
mittee on microbiological criteria, HACCP 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 to procure-
ment, handling, manufacturing, distribution,
and consumption of the fi nished product.
HACCP is a common - sense, practical, and
achievable food safety approach that industry
strives to follow, within the limitations of the
available technology to produce, transport,
procure, and prepare foods that present a
minimum level of risk from foodborne
hazards (Bauman, 1974 ).
While dairy HACCP is relatively recent
to the dairy processing industry, the PMO
has been in place since 1926. The fundamen-
tal basis of the PMO has been to encourage
uniformity and a higher level of milk sani-
tation excellence in the United States. It
encourages legal adaptation by states, coun-
ties, and municipalities to facilitate shipment
and acceptance of milk and milk products
of high sanitary quality in interstate and
intrastate commerce (FDA, 2003 ). This ordi-
nance has been widely adapted and has been
upheld by court decisions since its imple-
mentation. Key provisions underlying the
PMO and related standards are given in Table
15.4. For more detailed information, see the
PMO document at http://www.cfsan.fda.gov/ ∼ ear/
pmo03toc.html.
The unique feature of the PMO document
is its public health reason explanatory notes,
in which scientifi c rationale and practical
knowledge accumulated over many years are
presented accurately and clearly. The docu-
ment is user - friendly and serves as an excel-
lent training resource.