Recalls cost money and threaten the reputation of the dairies that institute them. The best defense is to be proactive by putting programs and procedures in place to prevent cross-contact and contamination. The following “core” methods, in addition to proper education and training of personnel, will significantly reduce the probability of a recall.

Undeclared allergens and labeling

The risk of a recall for undeclared allergens or improper labeling can be reduced with a well-developed allergen control program. This includes:

• Identification of all allergens in the facility, including all ingredients and finished goods.
• A thorough review of all ingredients at receipt.
• A robust supplier approval program, including an understanding of the allergens used in the supplier’s facility.
• Stringent ingredient storage practices that provide the segregation of all allergenic ingredients and products.
• Validated and verified cleaning procedures for all equipment, including preoperational inspections.
• In-depth label review programs for the development and verification of labels at receipt.
• Package and label verifications at filling to ensure the correct packaging and labels are used.

Pathogenic contamination

The risk of pathogenic contamination can be reduced through a validated and verified equipment sanitation program, an environmental cleaning and monitoring program and a traffic and zoning program. The sanitation program includes:

• Validated sanitation standard operating procedures (SSOPs) for equipment cleaning.
• A master sanitation program.
• Verification of cleaning and sanitizing through chemical concentration checks, temperature checks, chart reviews and visual observation of the cleaning task.
• Preoperational inspections, including visual observations or other means such as swabbing.

The environmental cleaning and monitoring program includes:

• Validated SSOPs for environmental cleaning.
• An environmental monitoring program that includes scheduled swab locations and frequencies.
• Corrective actions for positive results, including cleaning, re-swabbing and vectoring procedures.
• The identification of niches and other potential microorganism harborage locations as a part of the corrective actions.

The traffic and zoning program includes:

• The control of traffic, vehicles or personnel entering the facility.
• A footwear and clothing policy designed to reduce or eliminate contamination.
• The potential for zoning plant areas to reduce the introduction of microorganisms from raw to pasteurized areas.

Foreign materials

While foreign materials are a lower threat, there still have been incidents of such recalls in dairy products. Foreign material controls include:

• Preventative maintenance programs.
• Preoperational inspections of equipment.
• Verification that sieves, screens, filters, metal detectors and X-rays are intact and operating properly.
• Good manufacturing practices.