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Construction of premises
Construction of the premises and equipment must facilitate the preparation of milk and milk products for export as food fit for human consumption and be fit for the purpose for which they are used. The structure of the premises must be sound and must exclude the entry of dirt, dust, fumes and other contaminants. The premises must not permit the entry of pests. The immediate surrounds must ensure adequate drainage to minimise the risk of dust, pests or contaminants entering food handling areas. Fixtures, fittings and equipment must be constructed so that contamination of product does not occur. Floors, walls and ceilings must be smooth and impervious. Any food contact surfaces and storage devices must be designed so they can be effectively cleaned and sanitised.
For the relevant legislative references in the Export Control (Milk and Milk Products) Rules 2021, please refer to the department’s, Approved Arrangement Checklist.
The intention of this element is to ensure that the construction and layout of your premises is fit for its purpose and will not pose a contamination risk to your manufactured products. Your site layout must be designed to exclude the entry of any pests, dirt, dust, debris, fumes or other possible contaminants from the surrounding environment.
Your site’s immediate surrounds must have adequate drainage to prevent flooding and pooling of water, which can create a contamination risk and also attract pests.
If premises are designed poorly and are difficult to clean, they are more likely to harbour food borne pathogens which could become a risk to food safety. Food contact surfaces, fixtures, fittings, and equipment must be suitable for their use and must not pose a contamination risk to the food being prepared and must be able to be easily dismantled if required, cleaned and sanitised. They must be made from smooth and impervious materials free from pits, cracks and crevices to prevent unnecessary food build up and harbourage sites for pathogens.
The following points should be considered in your food safety plan.
- Is the building of sound construction, designed to prevent entry of dirt, dust and other contaminants?
- Is the location of the site exposed to any seasonal hazards? What mitigation techniques does the site have in place to ensure the food products are safe from such hazards?
- Are surrounding areas free from debris and are gardens/lawns maintained?
- Could activities conducted in your neighbouring facility or vacant land become a source of contamination?
- Are the sewerage and waste disposal systems effective and appropriately located? Are they far enough away from your premises so they do not pose a risk?
- Does the design of your doors to external areas prevent contaminants and pests from entering? If you have double entry, rapid roller or strip doors, are they maintained and effective? Are they left open for extended periods?
- Are your floors smooth and impervious, with no chips, cracks or peeling material that could create harbourage sites for pathogens?
- Do you conduct high risk dairy process activities in segregated manufacturing areas to help minimise risk of cross contamination?
- Does the transfer of any ingredients, product, equipment or finished goods between areas pose a risk?
- Have you considered the workflow of your staff? Are they managed to prevent cross-contamination between different areas and your products?
- Does the use of shared equipment between areas pose a risk?
- Are your production room walls and floors lightly coloured to allow you to easily assess their cleanliness visually?
- Are your equipment and utensils designed and constructed so that they can be adequately cleaned and sanitised? Are they inspected to ensure they are fit for purpose?
- Are rubbish bins stored away from production, kept covered and regularly emptied? Lids should be designed to be kept closed when not in use to prevent harbourage of pests.
- Do you conduct regular inspections of your site including the external surrounds and are records kept? This check can be completed as part of your internal audit or Good Manufacturing Practices (GMP) audit program.
More guidance information is also available on Food standards code standard 3.2.3 - Food Premises and Equipment. Dairy Food Safety Victoria (DFSV) have developed a guideline document for dairy manufacturers on Hygienic Design, which is another useful resource for dairy establishments seeking to understand the requirements.
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Marisol is considering purchasing a large volume of dairy product through a well-known local dairy supplier. Her employer is seeking the highest food safety and quality standards and is delighted to be considering the local dairy business.
As part of their approval process, Marisol has decided to visit the site in person to conduct a quick review of the site operations and to meet the potential new supplier. The dairy supplier has agreed to meet Marisol and provide a tour of the facility.
As Marisol pulls into the site, she notices that the raw material storage area is covered by a corrugated sheet roof, and she can see light from outside coming through the gaps between the roof and the walls.
She is welcomed by the site quality manager, who asks her to walk through the milk receival area to a change room where she is asked to put on protective clothing and together, they cross to the opposite end of the production room to wash their hands.
Marisol notices a very shiny polished concrete floor in the production room. Upon closer inspection, the floor has a lot of cracks and chips, especially around equipment with small pools of water sighted on the floor.
She also notices the side roller door has been left opened. The quality manager explains that it is due to the unpredictable hot weather on the day. As Marisol watches on, several flies buzz by.
Marisol is not convinced the products manufactured on this site will meet her company’s expectations and their customer’s requirements.
Whilst on site, what hazards has Marisol noticed to form her first impressions of the local dairy facility?
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