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U.S. Department of Health and Human Services


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M-I-84-8: Recent Seminar Discussions

                              200 ~C~ Street, S.W.
                              Washington, D.C. 20204
                              August 17, 1984
To   : All Regional Food and Drug Directors
       Attn: Regional Milk Specialists
From : Milk Safety Branch, HFF-346
Subject: Recent Seminar Discussions
Enclosed are copies of the questions and answers which were discussed at
Region VII Seminar held in March, 1984.
Copies of this memorandum are enclosed for distribution to State milk
sanitation regulatory agencies and State Milk Rating Officers in your
                              Robert L. Sanders
                              Senior Milk Sanitation Officer
Questions and Answers From the Region VII Milk Seminar
1.   Q -  Who or what is debited when the DHIA tester is found in
          the parlor/barn with dirty equipment?
     A -  Debit the firm with dirty equipment - Item 10a & 11a.
2.   Q -  Please discuss the problem of the underside of rubber wash
          lock on the DeLaval claw being dirty.
     A -  DeLaval says they weren't designed to be cleaned in place.
          Periodically they must be cleaned by hand.  They are not
          considered to be a normal milk contact surface.  Debit item
          10a but not 11a.  This would be comparable to pulsators
          and vacuum hoses on bucket milkers.
3.   Q -  Are the old Surge and Dari-Kool bulk tanks with the
          perforated metal vent around the agitator acceptable?
     A -  The original tanks were not acceptable co 3A since aerosols
          or water splash could pass through the perforated metal and
          into the tanks.  The firms developed a slinger which fitted
          over the vent and covered the vent sufficiently to protedt the
          milk.  Should you find an unconverted tank, debit under
4.a. Q -  When not being used, how should the Mueller tank washer
          be stored?
     A -  The washer should be stored so that washing contact
          surfaces are off the floor to avoid any splash from routine
4.   Q -  Should the openings on other pump type tank washers be
          protected when disconnected form the tank?
     A -  Yes - openings into the tank washer pumps should be
          protected from insects, rodents and floor splash.  If hose
          opening is left on the floor a solid cap should be used.
          Washup epuipment should be stored as any other piece os
          portable equipment or utensil and be adequately protected.
5.   Q -  Describe the use of exteior measuring tubs on bulk tands.
     A -  The 3 "A" sanitary standards require the system to be
          designed so the milk after entering the  measuring tube must
          be discarded.  It may not re-enter the Grade A system.  The
          tube must be designed to hand clean or CIP.  If the tube
          enters the top of the tank during CIP and storage then the
          bottom of the tube must be protected against the entry of
          insects, rodents and floor splash.  Any deviation would be
          debited under Item 16r.
6.   Q -  Please discuss item 16g - separation of product and CIP
          lines.  Is a valve on the suction line acceptable as a
          separating device?
     A -  Item 16r of the PMO requires separation of the CIP system
          and the milk lines during the milking operation.  This can
          be achieve several ways.  A value by itself is not
          acceptable.  Removing the suction line from the wash vat is
          one way.  Whether it can be a pipe or a hose.  Also
          acceptable to break the line out in the parlor and cap.  Debit
          Item 16g if there is no air break between the CIP and milk
7.   Q-   Is the Universal back-flush system acceptable?
     A -  This system has not yet been submitted to FDA for offical
          review.  We've seen only one system in out Region and it
          did not appear to be acceptable.  M-a-65 states that a
          chemical solution cycle will be used but the system we saw
          used a plain water rinse only.  In addition, there were
          several construction defects noted.  If you see this system
          installed, debit Item 9d.
8.   Q -  Are the mueller refigergated receivers acceptable?
     A -  Several models have been made.  The earlier models had
          only a small opening at the top - consequently the entire
          interior was not visible for inspection.  It is acceptable only
          if the entire lid will lift off for inspection.  The newer
          models we've seen meet this criteria and are acceptable.
          Debit Item 9b if the old models are observed.
9.   Q -  If dust covers and seals are required on domes, outlets, and
          spray ball openings of tankers way are they not so
          constructed at the factory?
     A -  Usually they are correct when they leave the factory.  In
          most cases, the spray balls are add-ons after leaving the
          manufacturer and the dust covers were ommited.  In any
          event, dust covers are required if the spray balls terminate
          outside of the tank.  Debit Item 15a if missing.
10.  Q -  Please discuss the new Surge, DEC and Westphalia back
          flush systems.
     A -  They are acceptable if kept clean.  They must be inspected.
          Debit Items 10 & 11 if found dirty.  They will probably
          have access to them.  It is not our job to determine if the
          equipment is CIP but rather - is it clean and made of
          acceptable materials.
11.  Q -  What is the latest on the Surge plug that been "hand tooled"
          at the farm?  What is now acceptable?
     A -  The plug was designed to be a loose, sloppy fit to allow
          water to drain.  As the plug ages, it would swell and shut
          off the water.  A v-Cut would not be acceptable because of
          the radii criteria.  It will probably be acceptable if the cut
          were made in a smooth arc instead of a V. Debit Item 9 if
          you find a sharp V has been cut in the rubber plug.
12.  Q -  Assembly of farm pipelines - is plastic acceptable
     A -  M-b-246 is out which says plastic to metal is acceptable.
          When using a clamp fitting, plastic to metal is acceptable.
          When using a clamp fitting, plastic results in a warped
          connection and will leak.  There's supposed to be new
          clamp coming out that won't distort the connection but as tit
          is now - a plasti to plastic fitting is not acceptable.
13.  QQ - What materials are acceptable for the full line on a tank
     A -  Since the lines must carry soaps, sanitizers, and chemicals
          the rigid PVC water lines and copper lines would not be
          acceptable since they would react with the solutions used.
          Use any material which is acceptable as a milk line.
14.  Q -  Dater blocks on single-service paper container have a
          coolant running through them.  Is this acceptable?
     A -  They are water cooled and this causes sweating.  The
          Condensate coan then drip into the open carton - this is not
          acceptable.  If use without a coolant - the heat causes the
          plastic to bild up and this can drop into the open carton.
          This is likewise unacceptable.  If the dater is located after
          the carton is closed - there is no problem other than the
          mechanical problem of bringing the carotn to a dead stop so
          the carton can be dated.  On solution we have seen is to
          instsll a little runway on the carry off chain that lets the
          carton stop and be dated befor the next carton pushes it onto
          the chain.
15.  Q -  Dater blocks on single-service paper containers have a
          coolant running through them.  Is this acceptable?
     A -  They are water cooled and this causes seating.  The
          condensate can then drip into the open carton - this is not
          acceptable.  If used without a coolant - the heat causes the
          plastic to build up and this can drop into the open carton.
          This is likewise unacceptable.  if the dater is located after
          the carton is closed - there is no problem other than the
          mechanical problem of bringing the carton to a dead stop so
          the carton can be dated.  One solution we have seen is to
          install a little runway on the carry-off chain that lets the
          carton stop and be dated before the next carton pushes it
          onto the chain.
16.  Q -  Can a fan blow air out of a milk room into a parlor that has
          louvers which close tight when the fan is off?
     A -  The answer is still "yes" as long as the louvers are tight.
          Experience has shown, however, that many times something
          has bumped or damaged the louevers in some way so that
          we end up with a debit of Item 5 Misc. b.
17.  Q -  On FDA Form 2359i under "Approved Water Laboratory
          and Date," what is the limit on the date"
     A -  There is none.
18.  Q -  There are two new single-service filter sock dispensers on
          the market.  Both are stainless steel boxis about six inches
          high and 1-1/2 or 2 inches wide.  One is about 3 inches
          long and designed to dispense filters form a plastic bag
          while the other is six or eight inches long and designed to
          dispense filters from a normal box.  Are they acceptable?
     A -  The ones described have not been reviewed.  M-b-126
          approved on using the same model number but is described
          round filters not socks - I have seen on of each in this
          region and both were unacceptable.   This could have beeen
          the way they were used not designed.  I have asked Region
          V to look at them for us.
19.  Q -  Please discuss the Diessel - D.S.M. Air eliminator made by
          Accurate Metering Systems and used with a Siemens meter
          for measuring milk.
     A -  There's and M-b-140 out on it and also a 3A symbol on it.
          It's an old unit buy it's acceptable.
20.  Q -  Does the PMO require a recording chart on buttermilk or
          yogurt vat?
     A -  If you're vat pasteurizing - yes.  If just holding it and
          adding heat after pasteurizing in an HTST unit - NO.  It's
          just part of the processing.
21.  Q -  Recently we've seen the use of acid sanitizers on the farms -
           specifically MANDATE.  Is this product acceptable?  Can
          we use pH test papers to determine its strength?
     A -  Yes, Madate is acceptable.  A tiration kit is available to
          accurately test the strength of MANDATE solution.  If one
          is certain that MANDATE is the solution being tested, we
          have no objections to the use of pH test papers to determine
          its strength.  They are acceptable if they will make the
          distinction between a pH above 4.0 and one 4.0 and below.
22.  Q -  Where dose the filter need to be located on a packaging
          machine that uses hot air (22 -500F) to blow into the
     A -  At the closest point to the place of application that is
23.  Q -  What is requirement for licensing a wash station?
     A -   No requirement in PMO that a wash station have a permit.
          Consiquently the situation exists where er fo not have
          authority to inspect wash station.  Criteria are set up in
          PMO but no means to enforce.
24.  Q -  On some farms we have observed milk cans and/or bulk
          tands in a room adjoining the milk room.  The milk is
          usually milk for hog feeding or colostrum milk.  Is there
          any problem with this practice?
     A -  There is no problem a long as the door is shut and that milk
          isn't being sold as Grad A. That's no considered part of the
          Grade A operation.  Debit 6b if there is not complete
          separation of the operation.
25.  Q -  What about Insectaway paint?
     A -  They now have EPA approval.  O.K. as long as used
          according to the label.  It's not approved is the farmer
          mixes the paint with the little bottles of mix.  It all comes
          down to use according to label dirctions.
The followint items were submitted but not discussed during the seminar.
Proposed answers are submitted for the first two questions.
26.  Q -  Are vacuum breakers required at hose station?
     A -  NO, unless the hose end is below the flood level of a vessel
          so as to constituted a submerged inlet.
27.  Q -  If an approved vacuum breaker is installed on the main
          water line at the highest point of elevation of the system, is
          it necessary to have other vacumm breakers throughout the
          distribution system if a cross-connection is evident?
     A -  Yes.  The main vacuum breaker would protect the water
          supply but would not necessarily protect component parts on
          the distribution system.