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U.S. Department of Health and Human Services

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PMO 2007: Appendix P. Performance-Based Dairy Farm Inspection System

Grade "A" Pasteurized Milk Ordinance (2007 Revision)

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PREFACE

A performance-based inspection system is an option to the traditional routine inspection frequency of at least once every six (6) months on Grade "A" dairy farms. This option provides States with a choice. For some States, inspecting every farm routinely twice a year may provide effective regulatory oversight and make efficient use of inspection resources. In other States, however, an optional system, which determines routine farm inspection frequency based on producer milk quality and inspection performance may be more desirable, equally effective, and make the most efficient use of limited inspection resources. The overall inspection effort devoted to a performance-based farm inspection system may be more or less than the traditional inspection system, which requires a routine inspection at least once every six (6) months per farm.

INSPECTION INTERVAL AND CRITERIA

Dairy farms will be categorized at least every three (3) months using the previous twelve (12) month farm inspection and milk quality data. The following criteria will be used to categorize farms into four (4) inspection intervals as defined below:

MINIMUM ONE (1) YEAR INSPECTION INTERVAL (ONE (1) INSPECTION EACH TWELVE (12) MONTHS):

All criteria below must have been met for the previous twelve (12) months:

  1. No more than one (1) sample with a Standard Plate Count (SPC) >25,000, but less than 100,000;
  2. All Somatic Cell Count (SCC) samples ≤ 500,000;
  3. No cooling temperature violations;
  4. No drug residue violations;
  5. No "critical control point" violations observed during farm inspections. Critical violations are identified on the Dairy Farm Inspection Report as:
    1. 10-Cleaning and 11-Sanitization;
    2. 15(d)-Drugs properly labeled and 15(e)-Drugs properly used and stored; and
    3. 18-Cooling (Significant Violations).
  6. No violation that creates a substantial risk of adulteration or an imminent health hazard;
  7. No more than five (5) violations documented on any inspection sheet;
  8. No consecutive inspection violations on any inspection Item;
  9. No record of suspended permit, certification or license due to inspection, milk quality or drug residue deficiencies; and
  10. Bacteriologically safe water supply at the time of categorization.

NOTE: Farms in this category who are re-categorized to a six (6) month inspection interval for a single violation of one (1) milk quality parameter (SCC > 500,000 or cooling temperature violation) may be re-categorized to the one (1) year inspection interval if all ten (10) criteria listed above are met for the next six (6) months.

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MINIMUM SIX (6) MONTH INSPECTION INTERVAL (ONE (1) INSPECTION EACH SIX (6) MONTHS):

All criteria below must have been met for the previous twelve (12) months:

  1. May have more than one (1) sample with SPC >25,000;
  2. May have one (1) or more SCC sample >500,000;
  3. No more than one (1) warning letter issued due to non-compliance of two (2) out of four (4) previous official sample results for SPC and SCC;
  4. No cooling temperature violations;
  5. No drug residue violations;
  6. No "critical control point" violations observed during farm inspections. Critical violations are identified on the Dairy Farm Inspection Report as:
    1. 10-Cleaning and 11-Sanitization;
    2. 5(d)-Drugs properly labeled and 15(e)-Drugs properly used and stored; and
    3. 18-Cooling (Significant Violations).
  7. No violation that creates a substantial risk of adulteration or an imminent health hazard;
  8. No more than five (5) violations documented on any inspection sheet;
  9. No consecutive inspection violations on any inspection Item;
  10. No record of suspended permit certification or license due to inspection, milk quality or drug residue deficiencies; and
  11. Bacteriologically safe water supply at the time of categorization.

NOTE: Farms meeting the criteria for one (1) year or six (6) month inspection intervals but with less than twelve (12) months of farm inspection and milk quality history, i.e., new farms, will be assigned to a six (6) month inspection interval.

MINIMUM FOUR (4) MONTH INSPECTION INTERVAL (ONE (1) INSPECTION EACH FOUR (4) MONTHS):

Any criteria listed below, results in the farm being placed into this inspection interval for twelve (12) months from the next re-categorization:

  1. More than one (1) warning letter issued due to non-compliance of two (2) out of four (4) previous official sample results for SPC and SCC;
  2. Farm conditions that caused the Regulatory Agency to take official regulatory action, i.e., warning letter, intent to suspend, reinspection, etc.;
  3. One (1) drug residue violation;
  4. "Critical control point" violations observed during farm inspections. Critical violations are identified on the Dairy Farm Inspection Report as:
    1. 10-Cleaning and 11-Sanitization;
    2. 15(d)-Drugs properly labeled and 15(e)-Drugs properly used and stored; and
    3. 18-Cooling (Significant Violations).
  5. A violation that creates a substantial risk of adulteration or an imminent health hazard;
  6. More than five (5) violations on any inspection; and
  7. Unsafe water supply at the time of categorization.
     

MINIMUM THREE (3) MONTH INSPECTION INTERVAL (ONE (1) INSPECTION EACH THREE (3) MONTHS):

Any criteria listed below results in the farm being placed into this inspection interval for twelve (12) months from the next re-categorization:

  1. More than one (1) drug residue violation;
  2. Any farm suspended from the market by the Regulatory Agency during the previous twelve (12) month evaluation period for any reason other than drug residue violations; and
  3. More than one (1) incident where violative farm conditions or milk quality parameters resulted in the Regulatory Agency taking official regulatory action, i.e., warning letter, intent to suspend, reinspection, etc.

NOTE: The above guidelines for Grade "A" farm inspection intervals are not intended to prevent farm inspections at more frequent intervals if in the judgment of the Regulatory Agency more frequent intervals are necessary.

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