Very often public opinion doubts the healthiness of the foods put on the market. Milk and its derivatives are among those most accused, probably because the regulatory framework to which this production must respond is unknown.
In particular, looking back a bit at the history of legislative evolution, we can say that 2004 marked a turning point in the system of controls on the hygiene and healthiness of milk. Previously, in fact, the control was completely delegated to the Local Health Units, which provided the licenses to produce and personally carried out all the controls required by Presidential Decree 54/97 “Regulation implementing directives 92/46 and 92/47/EEC on the production and placing on the market of milk and milk-based products”. For information purposes, raw milk samples taken from the farm were 5 per year.
With the regulatory review and the issuing of the three European regulations known as the “Hygiene Package” (Reg. 852-853-854/04) everything has changed, especially for producers, from several points of view.
While on the one hand, in fact, it has become relatively easier to start any production activity, and therefore also an agro-zootechnical company, because it is sufficient to carry out a SCIA at the municipality of membership to be on the market, on the other hand the producer, or rather the OSA (food sector operator), has become personally responsible for what he markets, and therefore is required to carry out those checks himself that were previously guaranteed by the public veterinary service.
To delve deeper into these controls, we interviewed Silvia Fiorani, a zoonomist and expert in quality control in the dairy supply chain.
So, what is a farmer obliged to do to produce milk?
«Depending on the species raised, the hygienic-sanitary parameters to be kept under control in order to market the milk have been defined.
Cattle farmers are those who have to monitor the greatest number of parameters. Every 15 days they are required to analyze the bacterial load content, once a month the somatic cells (the cells of sloughing of the udder epithelium, used as an indicator of possible inflammatory states and therefore also of well-being) and the content of aflatoxin M1, a toxin that can originate from molds present on plant-based foods. Based on the risk analysis, the possible presence of inhibitory substances that could derive from residues of pharmacological therapies or products used to sanitize the milking system or refrigerator is also analyzed.
All other species (sheep, goats and buffalo) are required to analyse the bacterial load every 15 days, while for the other parameters we rely on the so-called “risk analysis” provided for by the HACCP approach, according to which the frequency of the control will be established based on the probability that a certain risk will occur. To simplify: a farm where high-risk aflatoxin foods are not used in the ration will be able to carry out this monitoring only in the most critical periods and also every two or three months”.
How are the analysis results then managed?
«The results of the analyses must be managed by the breeder in this way. For the bacterial load, a bimonthly moving geometric average is made, which means that the data of the last 4 samples (i.e. 2 months) is used, moving forward by one each time a new sample is taken. For somatic cells, the method is similar but the moving geometric average is quarterly, i.e. on three results, moving forward each time there is new data. These results must be sent to the competent ASL on a monthly basis to demonstrate that the production process is controlled and that the parameters fall within the limits established by law».
What if some parameters do not comply with the legal limits?
«In the case of bacterial load and somatic cells, since these are parameters that are reset with the treatments carried out by the processing plants, there are times to restore the compliance conditions but it is still possible to continue producing and delivering the milk. However, with regard to aflatoxins and inhibitory substances, the situation is decidedly different.
If the aflatoxin exceeds the legal limit, the laboratory immediately notifies the farmer who is required to block the delivery and send the product to be destroyed. It will be necessary to present the disposal certificate of the non-compliant batch to the control bodies (ASL or NAS). In the meantime, a check must be carried out on the foods that may have caused the problem and the sample must be repeated after making the appropriate changes to the ration. Milk delivery can resume only when the parameters return within the legal limits.
As regards the possible presence of inhibitory substances, if traces are detected in the samples, the laboratory itself will alert the veterinary service which will block the batch and until a new sample demonstrates the resolution of the problem, the milk cannot be delivered”.
Are there any other things we should know about?
«There are still some details to know: all the analyses mentioned above are paid for by the producer (consider that aflatoxin costs a minimum of 17 euros per sample and therefore a dairy farmer spends on average, just for analyses, between 25 and 30 euros per month) and that the samples must be analysed at accredited laboratories, which are therefore part of a circuit that the various control bodies can access, therefore it is almost impossible to avoid constant and assiduous monitoring of the product.
And let’s remember that this is only the first link in the supply chain, then there is processing and marketing which must meet further requirements to satisfy the required health and hygiene guarantees”.
Sarah Fantini
Editor The Agon
