Tomorrows dairy industry and its food safety challenge

R Archer
Institute of Food, Nutrition and Human Health, Massey University, Private Bag 11 222, Palmerston North

Events of the last year have demonstrated how vulnerable the New Zealand dairy industry and the formulated
products industry are to food safety lapses. Whether real or suspected, such lapses allow regulators abroad to stop
imports of our products for purely food safety reasons or for broader motives.
Many countries today declare food security as a high national priority. Food safety is a mere component of food
security. Having a strong domestic dairy and nutritionals industry may well be judged a better route to food
security than importing perfect product from half a world away, especially from companies that may sometimes
decline to supply less favoured customers if there is a supply shortage.
With New Zealands dairy industry now so demonstrably vulnerable to food safety lapses, what is to be done? In
this short article, based closely on one I published in Food New Zealand last October (Archer 2013) I examine the
issue and express some opinions.

The rising threat

Modern dairy farming strives to produce milk of high quality but farming practices evolve, sometimes bringing
with them unforeseen and adverse quality consequences to milk itself. For example, for much of the last century,
cattle have been grazed mainly on pasture, with supplementary feed such as baled hay and grass silage used in
the winter. However, it is now common practice for farmers to store plastic encased balage. This is an anaerobic
environment in which spore-forming, heat-stable bacteria can grow. If such bacteria enter milk, they will be
transported to a processing plant and can gain entry, surviving most heat treatments. They may then be able to
colonise within foulant films that can build up on milk-contact surfaces and ultimately contaminate product.
Many dairy farmers now use palm kernel expeller (PKE) as supplemental feed. Imports in 2012 reached 1.4
million tonnes. A waste product (and treated as such) of the palm oil business, made in the tropics and stored in
big piles unprotected from wildlife, PKE too might be a great haven for spore-forming bacteria or toxin-producing
moulds. The dairy industry claims that the threat to milk from such feed is negligible, but common sense requires
the most vigilant certification and testing.
Increased use of feeding pads and housing systems may provide more opportunity than in the past for disease
organisms to pass between animals in a herd.
After lengthy research, dicyandiamide (DCD) was added to farm fertiliser to reduce nitrate leaching into waterways.
Despite received wisdom that DCD would not enter milk, it was detected at very low concentrations in some milk
powders.
The lesson? Never assume that some new way of doing things on the farm will have no effect on milk. That will
require demonstration. Analytical detection methods are now so senstive that even vanishingly minute amounts
of chemicals can be detected. It is of little comfort to consumers, increasingly wary of official reassurances, that
the concentration of such a chemical is well under some prescribed limit. Dairy companies cannot assume that
the development and approval processes for new agricultural chemicals will ensure zero contaminants in milk.

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Tomorrows dairy industry and its food safety challenge

Companies will have to increase their active participation in the interface between farm practices and milk quality.
And they need to be scanning for new threats looming in future.
As the threat posed by the raw material has increased, so too has the threat posed from within dairy product
processing. Twenty years ago bacteria were considered planktonic free floating. They came in with milk and
we either killed or removed them, or they were in the finished product. Now we realise the size of the hazard
posed by biofilms consortia of bacteria that cluster on process surfaces and grow, later to shed into the product.
If the biofilm sheds bacterial spores, these are unlikely to be killed downstream. In dairy processes, the major
heat treatment is usually early. Most surfaces do not provide favourable growth conditions for pathogens. Instead
spoilage organisms grow. However, some process surfaces in dairy plants are at or near 37oC for extended periods.
While pathogen growth is of more obvious concern, growth of non-pathogenic spoilage bacteria can have serious
economic consequences in downgraded or rejected products, or in spoilage effects that may show up in market as
flavour defects and shortened shelf lives of formulated dairy products.
Over the past 30 years our dairy processes have changed dramatically. Plants are fewer and transport distances for
raw milk longer. We once used mainly volume techniques cheese in vats, butter in churns and casein in silos.
Even our evaporators were based on thermal recompression with large temperature driving forces and relatively
little tube area. Modern evaporators are based on mechanical vapour recompression with huge product contact
surface areas, operating for long hours very efficiently. We have ultrafiltration plants with large membrane areas.
Most modern products incorporate some permeate or retentate, and some products see three membrane plants in
series. We use increasing amounts of ion exchange resin for specialised products. These are all area-dominant
processes providing vast amounts of surface for biofilms to grow and therefore surface areas that must be cleaned
thoroughly. These plants are run for as long as is practicable. Run times are in fact limited by accumulation of a
combination of organic boundary layers and microbes on process surfaces.
At the same time as our dairy processes get more area-based, they get larger, more computer-controlled and
increasingly complex. Gone are the days when operators interacted manually with process and product. Dairy
factories are massive, operated by a small staff over long shifts, typically 12 hours. Operators do not see the
product. They must discern the health of the plant and product from control screens. Some processes have the
combined lifes work of generations of dairy scientists and engineers embedded within them. Plants may have
many thousands of instruments, sensors, input/output signals and tags. Staff turnover and work rotation also mean
that few individuals will have a comprehensive understanding of such plants. Companies have, therefore, become
highly dependent on excellence in process and systems design before the plant is built, to a degree unparalleled in
the industrys history.
What happens then if pathogens enter these highly engineered systems? What happens if it is a bacterial strain or
species not reported previously? New pathogenic strains of old organisms are indeed arising every few years
and challenging the worlds food safety regimes. Pathogens able to colonise the human colon can evolve in other
animal hosts (for example, birds, pigs or cattle). And international air travel is predicted to continue its dramatic
growth. Aeroplanes can carry humans and their associated microflora (bacteria) around the world in a day.
Increasingly, our dairy products are more complex and incorporate ingredients from other sources, which add
further potential sources of contamination and complicate trace-back.
In summary, many forces are combining to raise the chances of a dangerous organism appearing in New Zealand
export dairy products. Increasingly, the industry needs to prepare itself for new and unknown threats.

The rising consequence

The New Zealand dairy industry is a large scale commodity producer but it also manufactures high value ingredients.
Each of these product classes has its own risks. Commodity sales are in the thousands of tonnes per year to single
customers. A single container could contain dairy products of sales value up to $100,000. There is far too much
value in either the large volume sale or the high value shipment to lose through quality defects. Increasingly, New
Zealand makes infant and follow-on formulas. These products may comprise a babys entire diet. Such sensitive
foods must be free from quality defects maintaining customer confidence is paramount.

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For some New Zealand ingredient products such as lactoferrin, the addition rate in a formulated food can be very
small. Hence, a large volume of a consumer product would be affected if such an ingredient were found to be
contaminated. Potential claims against the ingredient manufacturer could be huge. Insurers are generally loathe
to provide cover for products that could potentially be contaminated with pathogenic bacteria. Manufacturers
increasingly must self-insure, which could be hugely damaging to a small company not able to absorb a very
large claim. In all of these domains of dairy trade, reputational risks are becoming larger. Any such smear quickly
stains all New Zealand dairy companies, our down-stream formulated products industry, the Ministry for Primary
Industry (MPI) and New Zealand itself.
The New Zealand dairy industry is increasingly exposed to food safety risks in another manner as well. It is clearly
the big boy on the global traded dairy products scene and can be the natural foe of local dairy farmers. Foreign
governments would find internal political pressures harder to resist if product imported from New Zealand were
at all suspect.

Industry changes bearing on food safety

New Zealands dairy industry is one of the worlds most advanced in process technology and know-how. For 75
years, plant managers have completed specialised university courses. For 40 years its best and brightest have had a
specialist fifth year of university education. How well is it currently placed to spot food safety challenges coming
over the radar and to deal with them?
The industry has in place a risk management-based food safety approach. It has good laboratories. It does good
environmental monitoring. It has met and dealt with challenges from pathogens such as Salmonella and Listeria
problems with these organisms are now rare. The industry understands CIP (clean-in-place) and critical control
points and swabs. The product safety culture is strong. All this has meant that most plants have a superb food safety
record and New Zealand at large has built an enviable reputation for safe product.
But the product safety culture is geared to historic challenges and to steady-state operation. Systems are immediately
challenged when something goes wrong or changes. On-going vigilance has an on-going cost and must suffer the
same cost scrutiny as all aspects of the operation. The current product safety system understandably has the ethos
of the dairy industry rather than an industry tuned to the demands of infant formula. The industry tends currently
to regard a product as perfect if it meets specification it is unreasonable of a customer to object to a defect not
mentioned in the specification.
The industry has also recently changed its approach to manager development. It has moved from the universitybased diploma education, with its emphasis on preparing the mind to solve unknown problems in an uncertain
future, to a more compact and targeted training course with emphasis on codified learning for known situations.
This may appear a subtle and philosophic difference but it reveals a key aspect of modern thinking: excellence and
efficiency today outrank preparedness for threat or opportunity in future.
Overall, the picture is of a highly competent industry, but one which can expect new and different threats in future
that it may not yet be fully prepared for, philosophically or systemically.

The food safety system of today

There is a good deal to commend the food safety system that New Zealand has built. The risk-based approach is
immensely powerful. The multi-tiered system of companies, verifiers, auditors and regulator has much to commend
it. Companies, well run, are much more able to find and fix the myriad of small food safety issues that can arise,
than is a visiting food safety policeman. A sound, risk-based food safety culture instilled in all employees, designed
into plant and coupled with the necessary knowledge, systems and support is the right way to go.
There is always a place for finished product testing both for process control and for regulatory assurance purposes.
But this ambulance at the bottom of the cliff approach should be limited. The major resource is best placed in
prospective positions, not retrospective. This does put us at odds with some overseas jurisdictions where there is
not the trust and culture for a devolved system and where the police approach is essential.

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The mainstay of our system now is HACCP (Hazard Analysis and Critical Control Points). Process steps are
prioritised for their ability to control hazards and the critical steps are monitored very closely. This is a powerful
but limited tool. Furthermore, HACCP hails from the days when bacteria were viewed as individual and planktonic
rather than sections of sticky biofilm sloughing off some elastomer surface in the warm section of the heat exchanger.
At the point of design, most modern dairy plant probably undergoes a HAZOP (hazard and operability) analysis,
where risks are systematically approached line by line and designed out as far as is practical. But HAZOP is not
tuned to food safety issues and probably never involves a microbiologist. In the New Zealand dairy context, there
may not even be a dairy company representative present during the HAZOP stage of process design. Our usual
practice of turn-key contracts for capital plant can isolate the client company food safety stakeholders from the
designers. This is not a fundamental problem the petrochemical industry integrates its staff into the engineering
company precisely for safety and operability reasons to very good effect. The sharing of legal liability between
engineering supply company and client process operating company is no simpler than in the dairy industry but the
chemical industry achieves this routinely.
The regulator is a key component of our food safety system. The Ministry of Primary Industries (MPI) has its own
challenges. MAF had become a de facto brand long-standing and well-understood, for example, by China
Inspection and Quarantine Services (CIQ), representing an unimpeachable stamp of safety. For MPI to mean in
some overseas eyes what MAF once did will need special effort and the passage of time. MPI may be compelled on
occasion to mandate final product testing regimes that make little sense in the food safety system, simply because
they must give assuredness in a manner that some jurisdictions best understand.
A looming challenge to consumer confidence in New Zealand milk products is paradoxically the rising demand for
raw milk sales. Almost inevitably there will be illness as a result, albeit rarely. When this strikes, it will be another
smear on New Zealand dairy product safety.

How do other industries address safety challenges?

The food industry is not the only one to face safety challenges. The chemical process industry, including
petrochemicals, faced up to their safety challenges after a series of disasters in the 1970s. The result is a widely
understood series of systematic tools for application during design as well as later in a plants life. Some of the
tools are probabilistic (e.g. risk of an event, number of casualties), some are determinative (how much radiation
from an explosion), and some are non-quantitative (e.g. logic sequence leading to an event). There are now at least
62 published and accepted versions of the various tools (Tixier et al. 2002). Many are forms of HAZOP or HAZAN
(Hazard analysis). These systematic processes are all predictive they force people to look forward and imagine
all potentially dangerous scenarios, evaluate their severity and prescribe corrective actions. The chemical industry
is not perfect, but considering its scale, incidents are relatively few.
The pharmaceutical industry has the ability to harm a great many people since it deals with such potent materials. It
presents very real hazards to its own workers, to neighbours of its process plants and to end consumers. As a result
it has a safety culture and a broadly understood set of methodologies of the first order. The industry is served by a
whole branch of engineering called process validation engineering. Its job it is to see that each item in a production
system is designed for purpose, purchased from accredited suppliers, installed in accord with instructions and
performs to specification. These systems are part prediction, part audit and verification, and part measurement and
validation. The pharmaceutical industry is not perfect either, but incidents are scarce indeed.

Is the New Zealand dairy industry capable of step change

improvements?
The dairy industry has had some notable successes and some areas of poor performance, and there is a link
between them.
Over the past 40 years, the standard of environmental performance by the factory sites has improved dramatically
through continuous effort led by a few key people. Energy performance, waste minimisation, emissions are all at
world best levels. This has been achieved in part by re-casting the problem from environmental to one of losses

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and lost profits.

Over the past 10 years, Fonterra has done a great job in improving worker safety. This took sustained effort over
a long time and strong leadership.
Over much of the last 40 years, the industry also made great strides in food safety, controlling issues such as
Salmonella and Listeria, and reducing foreign matter contamination.
The industry still has a long way to go in on-farm environmental performance, despite some good work and some
standout properties. Very few New Zealanders would consider average farm environmental performance adequate.
A major reason for this modest performance is that no-one has yet successfully cast the problem as an opportunity.
If someone could demonstrate a use for the riparian margin giving higher returns than rotational grazing then this
problem would start to turn around quickly.
I conclude that the industry has shown in the past that it can make the level of improvement required where one or
more leader can, over a sustained period, recast the problem as a dollar-earning opportunity and drive the change.

What must the NZ industry do?

Overall, I concede that the New Zealand dairy industry food safety systems, supported by the verification and
official assurance system, have done exceptionally well up to today. But it is far short of what is required to
prevent a train crash in the future. Standard dairy levels of food safety will not be enough to stop our companies
facing a series of new food-safety centered trade impediments. Standard dairy levels are even further short of
what is needed to make infant formula or ingredients for infant formula. Infant and growing up products need
pharmaceutical standard facilities and ethos if our industry is to thrive.
The route forward is clear though. Most of the techniques exist in other industries already. They may warrant
adaptation. There is probably room for a hybrid HAZOP-HACCP-validation protocol to be developed, especially
for high end dairy application, and institutionalised. This would help ensure that plant is designed with product
safety foremost in mind.
Above all, there is an immediate need for a change of approach from reactive to proactive. The industry needs to
return to preparing its managers for new problems bursting upon them. The companies need at least some people
scanning the horizon for new food safety hazards coming from milk, packaging, and supply chain. The directors
need to refine their judgement about the scale of consequence that awaits the companies if they continue the
current course. Companies may well survive hitting a few rocks but each one takes out a few knots until the ship is
left wallowing. I assert that the New Zealand dairy industry needs a comprehensive leap up in food safety culture
and system and that the time is now. The threat is clear. The models are available. Is the leadership ready?

Reference
Archer RH. Food safety for the New Zealand dairy industry - where to now? Food New Zealand October/
November, 20-24, 2013
Tixier J, Dusserre G, Salvi O, Gaston D. Review of 62 risk analysis methodologies of industrial plants. Journal
of Loss Prevention in the Process Industries 15, 291303, 2002

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