U. S. Food and Drug Administration
Center for Food Safety and Applied Nutrition
FDA Prime Connection
M-I-84-8 - Recent Seminar Discussions
HHS/PHS/FDA/CFSAN/OC/DCP/MSB
200 ~C~ Street, S.W.
Washington, D.C. 20204
M-I-84-8
August 17, 1984
To : All Regional Food and Drug Directors
Attn: Regional Milk Specialists
From : Milk Safety Branch, HFF-346
Subject: Recent Seminar Discussions
Enclosed are copies of the questions and answers which were discussed at
Region VII Seminar held in March, 1984.
Copies of this memorandum are enclosed for distribution to State milk
sanitation regulatory agencies and State Milk Rating Officers in your
Region.
Robert L. Sanders
Senior Milk Sanitation Officer
______________________________________________________________
Questions and Answers From the Region VII Milk Seminar
1. Q - Who or what is debited when the DHIA tester is found in
the parlor/barn with dirty equipment?
A - Debit the firm with dirty equipment - Item 10a & 11a.
2. Q - Please discuss the problem of the underside of rubber wash
lock on the DeLaval claw being dirty.
A - DeLaval says they weren't designed to be cleaned in place.
Periodically they must be cleaned by hand. They are not
considered to be a normal milk contact surface. Debit item
10a but not 11a. This would be comparable to pulsators
and vacuum hoses on bucket milkers.
3. Q - Are the old Surge and Dari-Kool bulk tanks with the
perforated metal vent around the agitator acceptable?
A - The original tanks were not acceptable co 3A since aerosols
or water splash could pass through the perforated metal and
into the tanks. The firms developed a slinger which fitted
over the vent and covered the vent sufficiently to protedt the
milk. Should you find an unconverted tank, debit under
16d.
4.a. Q - When not being used, how should the Mueller tank washer
be stored?
A - The washer should be stored so that washing contact
surfaces are off the floor to avoid any splash from routine
cleaning.
4. Q - Should the openings on other pump type tank washers be
protected when disconnected form the tank?
A - Yes - openings into the tank washer pumps should be
protected from insects, rodents and floor splash. If hose
opening is left on the floor a solid cap should be used.
Washup epuipment should be stored as any other piece os
portable equipment or utensil and be adequately protected.
5. Q - Describe the use of exteior measuring tubs on bulk tands.
A - The 3 "A" sanitary standards require the system to be
designed so the milk after entering the measuring tube must
be discarded. It may not re-enter the Grade A system. The
tube must be designed to hand clean or CIP. If the tube
enters the top of the tank during CIP and storage then the
bottom of the tube must be protected against the entry of
insects, rodents and floor splash. Any deviation would be
debited under Item 16r.
6. Q - Please discuss item 16g - separation of product and CIP
lines. Is a valve on the suction line acceptable as a
separating device?
A - Item 16r of the PMO requires separation of the CIP system
and the milk lines during the milking operation. This can
be achieve several ways. A value by itself is not
acceptable. Removing the suction line from the wash vat is
one way. Whether it can be a pipe or a hose. Also
acceptable to break the line out in the parlor and cap. Debit
Item 16g if there is no air break between the CIP and milk
system.
7. Q- Is the Universal back-flush system acceptable?
A - This system has not yet been submitted to FDA for offical
review. We've seen only one system in out Region and it
did not appear to be acceptable. M-a-65 states that a
chemical solution cycle will be used but the system we saw
used a plain water rinse only. In addition, there were
several construction defects noted. If you see this system
installed, debit Item 9d.
8. Q - Are the mueller refigergated receivers acceptable?
A - Several models have been made. The earlier models had
only a small opening at the top - consequently the entire
interior was not visible for inspection. It is acceptable only
if the entire lid will lift off for inspection. The newer
models we've seen meet this criteria and are acceptable.
Debit Item 9b if the old models are observed.
9. Q - If dust covers and seals are required on domes, outlets, and
spray ball openings of tankers way are they not so
constructed at the factory?
A - Usually they are correct when they leave the factory. In
most cases, the spray balls are add-ons after leaving the
manufacturer and the dust covers were ommited. In any
event, dust covers are required if the spray balls terminate
outside of the tank. Debit Item 15a if missing.
10. Q - Please discuss the new Surge, DEC and Westphalia back
flush systems.
A - They are acceptable if kept clean. They must be inspected.
Debit Items 10 & 11 if found dirty. They will probably
have access to them. It is not our job to determine if the
equipment is CIP but rather - is it clean and made of
acceptable materials.
11. Q - What is the latest on the Surge plug that been "hand tooled"
at the farm? What is now acceptable?
A - The plug was designed to be a loose, sloppy fit to allow
water to drain. As the plug ages, it would swell and shut
off the water. A v-Cut would not be acceptable because of
the radii criteria. It will probably be acceptable if the cut
were made in a smooth arc instead of a V. Debit Item 9 if
you find a sharp V has been cut in the rubber plug.
12. Q - Assembly of farm pipelines - is plastic acceptable
anywhere?
A - M-b-246 is out which says plastic to metal is acceptable.
When using a clamp fitting, plastic to metal is acceptable.
When using a clamp fitting, plastic results in a warped
connection and will leak. There's supposed to be new
clamp coming out that won't distort the connection but as tit
is now - a plasti to plastic fitting is not acceptable.
13. QQ - What materials are acceptable for the full line on a tank
washer?
A - Since the lines must carry soaps, sanitizers, and chemicals
the rigid PVC water lines and copper lines would not be
acceptable since they would react with the solutions used.
Use any material which is acceptable as a milk line.
14. Q - Dater blocks on single-service paper container have a
coolant running through them. Is this acceptable?
A - They are water cooled and this causes sweating. The
Condensate coan then drip into the open carton - this is not
acceptable. If use without a coolant - the heat causes the
plastic to bild up and this can drop into the open carton.
This is likewise unacceptable. If the dater is located after
the carton is closed - there is no problem other than the
mechanical problem of bringing the carotn to a dead stop so
the carton can be dated. On solution we have seen is to
instsll a little runway on the carry off chain that lets the
carton stop and be dated befor the next carton pushes it onto
the chain.
15. Q - Dater blocks on single-service paper containers have a
coolant running through them. Is this acceptable?
A - They are water cooled and this causes seating. The
condensate can then drip into the open carton - this is not
acceptable. If used without a coolant - the heat causes the
plastic to build up and this can drop into the open carton.
This is likewise unacceptable. if the dater is located after
the carton is closed - there is no problem other than the
mechanical problem of bringing the carton to a dead stop so
the carton can be dated. One solution we have seen is to
install a little runway on the carry-off chain that lets the
carton stop and be dated before the next carton pushes it
onto the chain.
16. Q - Can a fan blow air out of a milk room into a parlor that has
louvers which close tight when the fan is off?
A - The answer is still "yes" as long as the louvers are tight.
Experience has shown, however, that many times something
has bumped or damaged the louevers in some way so that
we end up with a debit of Item 5 Misc. b.
17. Q - On FDA Form 2359i under "Approved Water Laboratory
and Date," what is the limit on the date"
A - There is none.
18. Q - There are two new single-service filter sock dispensers on
the market. Both are stainless steel boxis about six inches
high and 1-1/2 or 2 inches wide. One is about 3 inches
long and designed to dispense filters form a plastic bag
while the other is six or eight inches long and designed to
dispense filters from a normal box. Are they acceptable?
A - The ones described have not been reviewed. M-b-126
approved on using the same model number but is described
round filters not socks - I have seen on of each in this
region and both were unacceptable. This could have beeen
the way they were used not designed. I have asked Region
V to look at them for us.
19. Q - Please discuss the Diessel - D.S.M. Air eliminator made by
Accurate Metering Systems and used with a Siemens meter
for measuring milk.
A - There's and M-b-140 out on it and also a 3A symbol on it.
It's an old unit buy it's acceptable.
20. Q - Does the PMO require a recording chart on buttermilk or
yogurt vat?
A - If you're vat pasteurizing - yes. If just holding it and
adding heat after pasteurizing in an HTST unit - NO. It's
just part of the processing.
21. Q - Recently we've seen the use of acid sanitizers on the farms -
specifically MANDATE. Is this product acceptable? Can
we use pH test papers to determine its strength?
A - Yes, Madate is acceptable. A tiration kit is available to
accurately test the strength of MANDATE solution. If one
is certain that MANDATE is the solution being tested, we
have no objections to the use of pH test papers to determine
its strength. They are acceptable if they will make the
distinction between a pH above 4.0 and one 4.0 and below.
22. Q - Where dose the filter need to be located on a packaging
machine that uses hot air (22 -500F) to blow into the
cartons.
A - At the closest point to the place of application that is
practicable.
23. Q - What is requirement for licensing a wash station?
A - No requirement in PMO that a wash station have a permit.
Consiquently the situation exists where er fo not have
authority to inspect wash station. Criteria are set up in
PMO but no means to enforce.
24. Q - On some farms we have observed milk cans and/or bulk
tands in a room adjoining the milk room. The milk is
usually milk for hog feeding or colostrum milk. Is there
any problem with this practice?
A - There is no problem a long as the door is shut and that milk
isn't being sold as Grad A. That's no considered part of the
Grade A operation. Debit 6b if there is not complete
separation of the operation.
25. Q - What about Insectaway paint?
A - They now have EPA approval. O.K. as long as used
according to the label. It's not approved is the farmer
mixes the paint with the little bottles of mix. It all comes
down to use according to label dirctions.
The followint items were submitted but not discussed during the seminar.
Proposed answers are submitted for the first two questions.
26. Q - Are vacuum breakers required at hose station?
A - NO, unless the hose end is below the flood level of a vessel
so as to constituted a submerged inlet.
27. Q - If an approved vacuum breaker is installed on the main
water line at the highest point of elevation of the system, is
it necessary to have other vacumm breakers throughout the
distribution system if a cross-connection is evident?
A - Yes. The main vacuum breaker would protect the water
supply but would not necessarily protect component parts on
the distribution system.
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