Dairy Establishment Inspection Manual – Chapter 5 - Program Design and Application

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The program is designed to:

  • emphasize health and safety and
  • be simple, and effective in meeting program goals

5.1 Health and Safety Category

A health and safety category is a group of tasks that are related by their influence on health and safety. Tasks are preassigned into health and safety categories. This has been done by evaluating the tasks' risk in usual situations, according to the health and safety category definitions.

There are four Health and Safety categories. In descending order of importance they are:

Category 1

These are tasks that are absolutely essential to ensure the health and safety of the end product. Examples include specific sections of the pasteurization system, thermal process system, aseptic system and the formulation of process cheeses.

Category 2

These are tasks that come in direct contact with the pasteurized product and therefore may affect safety, such as post pasteurization equipment, steam, air, and personnel. Tasks such as the interwiring of the booster pump and current operational records are included. Tasks such as these, do not come in direct contact with the product but nonetheless have an impact on product safety.

Category 3

These are tasks that may contribute to finished product quality but not necessarily to the safety. Examples include pre-pasteurization equipment and some control programs and historical records.

Category 4

Tasks such as building structures, conveying equipment and waste disposal are included in this category. They are evaluated because of their indirect effect on product quality and they indicate the general condition of the plant environment.

To emphasize health and safety concerns, refer to Section 5.5 - Inspection Results and Evaluation for explanation.

5.2 Task Rating

Tasks will either be rated:

  • satisfactory, or
  • not satisfactory

at the time of their inspection, according to the task guidelines and other reference documents.

The inspector must evaluate each applicable task in its:

  • operating condition, and
  • dismantled condition.

If either of these conditions is unacceptable the task will be evaluated not satisfactory.

For example, a vacuum breaker in very good mechanical and sanitary condition, but not functional during processing would be rated not satisfactory.

Even if the task conditions are corrected, the initial findings must be recorded to reflect conditions at the time of inspection.

The task assessment must be done independently from the task's health and safety category.

To make a decision on the rating, use the task criteria and explanation as a guideline, then:

  • ask questions
  • consider task's intent
  • consider plant's "attitude"

5.3 Inspected Comments

Each task rated not satisfactory requires an explanation of its deficiency. The inspector must indicate deficiencies:

  • from a pre-coded listing, or if necessary,
  • in his/her own words, or
  • by a combination of both above.

These deficiencies must indicate all the unacceptable conditions observed.

5.4 Due Dates

To pinpoint the urgency of the action to be done, pre-assigned due dates are established by category for all tasks rated not satisfactory. These due dates will coincide with the task's health and safety category and serve as guidelines for correction and will be calculated from the end date of the inspection. The health and safety categories for a specific task cannot be changed by the inspector. The preassigned due dates are:

  • Category 1: action to be completed within 10 days
  • Category 2: action to be completed within 30 days
  • Category 3: action to be completed within 180 days
  • Category 4: action to be completed within 365 days

Category 1 and Category 2 tasks have a shorter due date for correction because of their importance. Category 3 tasks have an intermediate due date for correction. Category 4 tasks have a longer due date for correction as these tasks may not pose a health and safety risk, but are essential in order to meet registration requirements. Although these due dates are pre-assigned, the inspector has the ability to modify them if the observed task conditions are more or less severe within a health and safety category.

When a task is rated not satisfactory and judged to be a critical problem (any Health and Safety Category), the due date indicated must be within the specified number of days for that category. Tasks will only be judged critical if they are serious enough to consider plant suspension or similar action because the safety of the product is at high risk.

5.5 Inspection Results and Evaluation

5.5.1 Overall Summary

To summarize the inspection results according to health and safety concerns, the inspection report will group the task evaluations by Health and Safety Category both for individual inspection areas and all areas combined.

For example (all inspection areas):

Example - inspection results according to health and safety concerns
Health and Safety Satisfactory Task Ratio %
Category 1 6/7 86
Category 2 60/90 67
Category 3 57/74 77
Category 4 34/45 76

This summary will quickly establish the risks present in the plant. Tasks in Category 1 that are not satisfactory may have a direct impact on the safety of the finished product. The possibility of risk may increase if Category 2 and 3 tasks are poorly controlled.

Thus, the interrelationship of the tasks in the four categories helps to provide an assessment of the plant's capability to produce safe products under sanitary conditions.

For example, in a pasteurized cheese plant, if the tasks in all 4 categories are well controlled except those in Category 3, we would expect the overall risk to the plant to be minimized. A well controlled pasteurization step (Category 1 tasks) and satisfactory post pasteurization tasks would reduce the impact of the hazards present prior to pasteurization (Category 3 tasks).

Realistically, the ratings can only be interpreted when the complete results are studied and analyzed.

An overall rating of acceptable or unacceptable will be given to the inspection based on the rating in the specific health and safety category tasks. An unacceptable rating will be given to a plant that receives an overall rating of less than 100% in Category 1 tasks, or less than 75% in Category 2 tasks or less than 60% in Category 3 tasks or less than 50% in Category 4 tasks.

5.5.2 Health and Safety Rating Report

The Health and Safety Rating Report produced will list in descending order of priority, all non satisfactory tasks requiring action. Tasks will be listed by health and safety category and specify:

  • Where it was inspected (e.g. cheese cutting room)
  • The task's name
  • What the condition is that requires action (inspected comments)
  • An action due date.

This report will easily identify where action needs to be taken first. Industry will be able to prioritize and substantiate all actions required. Government will be able to focus resources towards higher risk plants.

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