Elements of an Approved Arrangement

The following links may assist you in determining the minimum acceptable detected pathogen levels for your dairy products.

• Microbiological limits for food – as per the legislation.
• Microbiological limits for food - as per the Food Standards Code.
• Department’s Microbiological testing requirements for export dairy products.

Once your microbiological acceptance limits have been established, they must be clearly documented in your procedures. When you send samples to a laboratory for pathogen testing, it is essential that you request the right tests. This means that if you are required to test for a particular species of pathogen (e.g. Listeria monocytogenes), you must request this from the laboratory and the laboratory must report their results against the defined pathogen species, not a generic pathogen (e.g. Listeria spp).

For some tests where you are seeking to confirm the presence or absence of a microorganism (i.e. qualitative tests), it is acceptable to combine your 5 sub-samples into one larger composite sample for analysis. On the other hand, if you are testing to determine the number or concentration of microorganisms in a sample (I.e. quantitative testing), you must have each sub-sample analysed individually.

If you have any failed pathogen results from finished product testing, you must activate your documented product recall and pathogen clearance programs to implement appropriate corrective actions. You must also notify your relevant state food safety authority, and the department of the failed pathogen result as soon as possible (and no later than within 24 hours of receiving the result).

Training records for staff conducting any sampling or testing must be available and ensure personnel are suitably qualified. For example, if microbiological testing is conducted, is the sample taken using aseptic techniques? Has the sampler been given adequate training? Is there a record to show evidence of the training and competency assessment?

If your product is being manufactured for a specific overseas market, any importing country requirements must be met. For example, if an importing country requires additional microbiological testing, then these tests must be carried out with acceptable results to ensure your product complies with importing country requirements.

Some customers or importing countries may require that certain tests be conducted by a NATA accredited (or equivalent) laboratory. You must ensure your documented procedures identify these requirements. The laboratory must be accredited to perform the specific test that you require.

For additional information on importing countries and their specific requirement, refer to the Importing Country Requirements section of the Dairy Export Registration Manual, and the Department’s Manual of Importing Country Requirements.

You should consider the following when documenting your sampling and testing procedures:

• Do your documented procedures clearly define sampling and testing requirements including any additional testing for export products?
• Is it clear how many samples for each product need to be tested and where samples are taken from?
• When reviewing your records, is it clear what has been tested, how often and the limits?
• Is the frequency of testing in line with requirements?
• Are the acceptable limits for pathogens in line with requirements?
• Did your product pass the designated test? How have you investigated the cause of any failures? Was appropriate corrective action taken? Who was notified? Were all actions documented? Where did you record it?
• Are responsible staff trained in proper procedures?
• Who is authorised to conduct the tests? Do you need to use a NATA accredited laboratory?
• Who is authorised to review and approve the results?
• Are your test results clearly cross referenced to the appropriate AS method used?
• Are results being accurately reported and recorded? (for example, Listeria monocytogenes, not Listeria species, as this is the species defined by the Food Standards Code)

NATA certificates of analysis must clearly identify:

1. the NATA logo, accredited number
2. test method used (must be linked to the AS test method where the country of destination has no specific requirements to be met)
3. the manufacturer and the establishment number
4. a full description of the product and its unique identifier (e.g., production date and or batch code of the product) and
5. if product has passed or failed against each specific test.

You may need to include where the test results are provided to the Department, as part of your export permit application.

For further guidance on how to manage any pathogens detected in your dairy products or in your dairy processing environment, please refer to Dairy Food Safety Victoria’s, Dairy Pathogen Manual.