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Products sampling & testing
All products manufactured at the site must meet the microbiological limits for food specified by the Food Standards Code, importing country requirements (where applicable) and in accordance with the company’s approved arrangement.
The documented product sampling program must:
- Ensure every product type (e.g., yogurt, cheese) is sampled at a minimum of 5 sub-samples per fortnight.
- Identify the minimum testing requirements as per the Food Standards Code, state requirements and any internal risk assessments.
- Define the limits that must be achieved, and the corrective action taken should the limits be exceeded (include notification to regulatory authority).
- Identify any specific importing country requirements that are over and above the standard testing requirements.
- Define the Australian standard test method used.
- Define when product must be tested in a NATA accredited laboratory.
- Provide details of training required for staff to take samples and approve results.
- Be linked to internal audit, corrective actions, and management review systems.
- Must identify when composite sampling is done (only acceptable for qualitative or presence/absence testing).
- Must ensure all samples are taken from finished product that has completed its manufacturing process.
For the relevant legislative references in the Export Control (Milk and Milk Products) Rules 2021, please refer to the department’s, Approved Arrangement Checklist.
Any dairy products manufactured at your establishment for export must meet the microbiological limits for food specified by the Food Standards Code and in accordance with the company’s approved arrangement.
Your establishment must have a documented product sampling and testing program. Sampling and testing must include every different batch of finished product manufactured in your facility, for example, all types of milk, cheeses, and yogurts. Batch of finished product can be defined as any lot of products made usually within 24 hours under the same process conditions with the same raw materials.
Each export product type must be sampled on a fortnightly basis, with a minimum of 5 sub-samples taken from a single batch of each finished product type.
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:
- the NATA logo, accredited number
- test method used (must be linked to the AS test method where the country of destination has no specific requirements to be met)
- the manufacturer and the establishment number
- a full description of the product and its unique identifier (e.g., production date and or batch code of the product) and
- 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.
How much do you know about Product Testing?
Take this short assessment to find out.
Li is the laboratory technician at a dairy premises and is in charge of product sampling and testing this week. He has been fully trained to sample and test product for the local markets and has done so successfully in the past. Li is aware that his manager had just updated the site sampling and testing procedures to include the export requirements, but has not been briefed and trained on the new procedure. Upon inspecting the production schedule, Li notices that there is an export product scheduled to be manufactured later this week. Whilst reading the product description, Li notices that the export product pack size is similar to their current domestic product but the overall palletising format and labelling has changed. His company has not exported any products before and Li had not conducted sampling for export products in the past.
As the responsible person for site’s sampling and testing this week, what actions should Li take to ensure export compliance with regards to the product sampling and testing requirements?
Click all that apply.