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The legal aspects of purchasing bulk milk

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					                                                DAIRY




The legal aspects of
purchasing bulk milk
  Compiled by the Dairy Standard Agency


Official requirements, food legislation and          Management commitment
effective control are the responsibility of the      As food safety is not a negotiable issue, managers
respective government institutions. Yet it is a      and businesses owners have a responsibility to
reality that food hygiene legislation can never      identify, evaluate and control threats that may
be detailed enough to cover all the specifics of     impact on food safety. This implies that they
an operation.                                        must be knowledgeable about legislation which,
                                                     among others, governs food safety and quality
At the same time, external official food control     related issues.
cannot cover the complete process of food
handling and processing. It is logical, therefore,   In terms of food safety (microbiologically) and
that the main responsibility for food safety rests   quality standards, milk destined for human
with food operators, who personally control and      consumption must comply with the following
apply food safety management programmes.             health legislation:
    The modern food chain has become                     R
                                                     •	 	 egulation R1555 of 21 November 1997 –
increasingly long and is often complex. This             Regulations relating to milk and dairy products
includes bulk milk, which is a daily commodity in        in the Foodstuffs, Cosmetics and Disinfectants
our diverse retail and catering market. As fresh         Act, 1972 (Act 54 of 1972).
milk is considered to be a highly perishable             R
                                                     •	 	 egulation R2581 of 20 November 1987
product, mishandling thereof poses a great risk.         – Regulations relating to dairy products and
The result is a list of principles which should be       imitation dairy products, Agricultural Product
constantly reviewed.                                     Standards Act, 1990 (Act 119 of 1990).


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                                                  DAIRY


TABLE 1: Standards applicable to                          Often plastic containers are also not manu-
the purchase and sale of bulk milk                     factured from food-graded material, which poses
                                                       a direct threat to the content. Milk in containers
                   Food Safety                         such as these or even packed in inner-liners, may
 E.coli                               Negative         easily be subjected to post-pasteurisation contam-
                                                       ination, rendering the milk quality inferior.
 Coliform bacteria cfu/ml              10/ml
                                                          The temperature of received milk should not
 Total plate count (TPC) cfu/ml     <50 000/ml         be higher than 4°C – this a legal requirement. A
 Inhibitory substances                Negative         code of practice must therefore be implemented
 Phosphatase                                           and maintained, so as to ensure that milk
                                      Negative         deliveries and storage practices are well-
 (adequate pasteurisation)
                                                       controlled.
                  Food Quality
 Added water                             0%            Know your stuff
 Butterfat full-cream                  ≥3,3%           Knowledge of legal standards and product
                                                       specifications is vital. Provision must be made
 Protein                               ≥3,0%
                                                       for all recipients and handlers of raw materials,
 Solids non-fat                       8,4-9,4%         to ensure that the specifications and rejection
                                                       protocol of products are well understood.
Supplier quality assurance                                 Control over the receiving of goods is
Buyers should not buy any milk from suppliers/         considered to be the first line of defence, and
retailers of which the company’s commitment            rules pertaining to food safety in this regard,
to food safety is not known. The promise of            must be followed to the letter.
saving a few rand, may end up being a costly               It is advisable that role players in the hospital-
affair which reflects badly on your business           ity and catering industry consider the testing of
and commitment to food safety. Request your            milk, in order to verify compliance to mandatory
supplier to supply you with certificates of            standards. It is, however, strongly recommended
analyses at appropriate frequencies, in order          that only reliable laboratory facilities be used in
to verify the quality of the bulk milk. Table 1        the process, as unreliable test results are of no
contains the standards to which bulk milk should       worth.
adhere when purchased.
    Although the sale of unpasteurised milk is         Follow up and record
permitted in certain municipal districts, caterers     The implementation of corrective actions is of
are strongly discouraged from purchasing raw           utmost importance to reduce the risks of reoc-
milk from suppliers. Unfortunately raw (and            curring non-conformances. Corrective actions
especially untested) milk is often associated with     must be swift and must followed up to verify the
foodborne diseases.                                    effectiveness thereof.
                                                           Maintaining records as part of a food safety
Proper packaging                                       management programme, has been the saving
Packaging plays a very important role in               grace of many food establishments at times of
preserving milk (protecting it from the environment)   trouble and disputes. The value of keeping and
during handling and storage. Be very cautious          maintaining records as a management tool in
when buying milk packed in reusable containers         terms of food safety is of great value and evidently
which cannot be effectively cleaned and                forms part of a company’s code of ethics as well
sanitised.                                             as commitment to food safety. M&J


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