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 Region.
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 16d.
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 cleaning.
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 system.
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 anywhere?
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 washer?
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 cartons.
A - At the closest point to the place of application that is practicable.
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.