Protection, segregation, waste and other products

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Is there a documented system in place that ensures that hazardous materials (e.g. hazardous substances, chemicals, inedible product, allergens, waste and non-conforming product) are adequately stored and identified so as to prevent cross contamination?

Procedures for the identification and controls of hazardous materials must be in place.

Where applicable, are there procedures in place to ensure products are not contaminated through the use of:

  • Steam
  • Compressed air, and
  • Other gasses

Are there documented procedures in place to manage other products that are being manufactured or stored at the establishment that may not be export eligible, or have the potential for cross contamination, such as:

  • Domestic milk and milk products?
  • Animal food (stock food)?
  • Manufacturing grade milk and milk products?
  • Products not fit for human consumption?
  • Products other than milk and milk products?

Your procedures to manage these products must ensure that they are identified, stored and labelled correctly. Assessment of potential risks needs to be considered and documented.

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 hazardous material which is present within your establishment must be segregated and stored appropriately to ensure it does not pose a risk of any contamination to your product.

Your procedure needs to clearly describe how hazardous materials, including any hazardous substances, chemicals, inedible product, allergens, waste and non-conforming products are adequately stored and how you identify them to prevent cross contamination.  

Allergens need to be identified in your Approved Arrangement and procedures outlining how you manage them.  This will include risk assessments undertaken.  All allergens must be clearly labelled,  segregated and controlled.

Inedible product and non-conforming product must be controlled, identified and segregated from food and ingredients to prevent cross contamination.

You will need to define how any chemicals at your site are to be stored.  This will include how you will segregate them so they do not pose a risk to your product and also how they are to be clearly identified and controlled.  For example, are they kept in a locked cage? Do you limit access of hazardous chemical storage areas to authorised personnel?

Your establishment must have a system that effectively disposes of, or treats all sewage and waste.  Your system must prevent sewage or waste polluting your water supply or contaminating your milk product.

You must ensure that waste or non-conforming products are controlled during all stages of manufacturing.  Any waste discharge must be contained and directed to the drainage system. If they cannot be removed from the manufacturing area immediately, they must be clearly identified and all relevant personnel must be made aware of them, so they can be adequately controlled. Any waste, inedible material or hazardous substances at your establishment are to be segregated and identified. They should be stored away from any food material.

Packaging should be well sealed so there is no potential for leaks or spills that can contaminate other products or food contact surfaces and ensure it cannot be contaminated by any pests or animals.

Some areas for consideration when documenting and reviewing this element includes; 

  • Do you have a procedure which outlines how allergens are assessed and handled on site (if applicable)?
  • Has your site assessed raw materials to determine if any allergens are present?  This should include all ingredients including processing aids.  Information from Approved suppliers and product specifications may assist with this.
  • If allergens are present, how are they to be labelled and controlled throughout all areas of the site, including receival, storage and dispatch?  
  • Where applicable, do your staff use dedicated equipment and clothing or PPE when handling hazardous substances (such as allergens), to reduce the risk of cross-contamination? Are all staff aware of the handling requirements?
  • If applicable, do you make sure any cleaning equipment used for allergenic material is effectively cleaned by a validated method?   This should be checked frequently to ensure it does not pose a risk.
  • Have you considered good storage practices as part of this element, such as the storage of hazardous materials on a lowest shelf so that there is a reduced risk of the hazardous materials leaking or dripping onto products stored below?

Your Approved Arrangement must ensure that milk or milk products that are not fit for human consumption do not become a source of contamination for prescribed milk or milk products or their ingredients.

If your product is manufacturing grade and is export eligible and can be exported, a documented system must be in place to ensure that it is appropriately identified.

Manufacturing grade milk and milk products that are not fit for human consumption must be identified clearly and kept separately to ensure that they are not a contamination risk to your prescribed milk and milk products.

If an export permit for the prescribed milk or milk products is revoked or the holder of the Approved Arrangement for operations to prepare milk and milk products is given direction under the Act that the milk products are not fit for export as food, they must be labelled accordingly and segregated so they do not pose a contamination risk.  They must not be loaded for export.

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Self Assessment

How much do you know about Protection, segregation, waste and other products?

Take this short assessment to find out.

Question 1

Rochelle is working at a cheese cutting and value adding production line as a production operator. It has been a busy shift and the waste product in her area has built up. The waste container is close to the packaging area away from her station. She does not want to slow production down, so she decides to use an additional unmarked container temporarily as a waste bin.

Could the temporary waste bin become a food safety issue for the manufactured dairy products?

Question 2

Lashan is working in a dairy establishment as a laboratory assistant in the flavour innovations department. He has just received a new ingredient he is going to incorporate into a new dairy dessert. The new ingredient is composed of an allergenic material.

As the ingredient is only for Research and Development purposes, Lashan does not believe he needs to do anything different from other new ingredients. Is he correct?