The standards in the Australia New Zealand Food Standards Code (FSC) are legislative instruments developed by Food Standards Australia New Zealand (FSANZ).

The FSC lists requirements and permissions for foods such as approved additives and ingredients, limits on chemical residues in food, labelling (including nutrition and health claims), and microbiological criteria. The FSC also describes food safety requirements which cover food safety programs, food safety practices and requirements for premises and equipment, and establishes comprehensive primary production and processing standards.

The standard development process undertaken by FSANZ is science-based, using the best available scientific data and the risk analysis process. The interpretation and enforcement of the FSC is the responsibility of state and territory departments and food agencies. In Victoria this is done through the Food Act, which requires food businesses, including dairy manufacturers and dairy distributors, to comply. It is a condition of the dairy industry licence for dairy farmers and dairy carriers that they also comply with the Food Standards Code including 4.2.4 Primary Production and Processing Standard for dairy foods.

Licensees seeking advice on compliance with the FSC may discuss the matter with their DFSV food safety manager and/or the DFSV science team. However, licensees are also encouraged to engage a legal expert or consultant for compliance advice.

The most complete and up-to-date collection of Commonwealth legislation, including food standards, may be found on the Australian Government ComLaw website or via the FSANZ website.

Details of recent changes to the FSC will be updated in Standards updates.

Dairy foods should not contain microorganisms (or their toxins) at levels that pose an unacceptable risk to public health.

In the dairy industry, end-product testing is generally used as a verification tool to check and provide assurances that the manufacturer’s approved HACCP-based food safety program is working effectively for the batch being evaluated.

Regular testing of finished products enables manufacturers to:

• provide increased assurance that their products meet safety requirements
• meet specific regulatory and customer requirements e.g. Food Standards Code, export requirements, and retail standards.

The Australia New Zealand Food Standards Code sets microbiological criteria and guideline levels for milk and milk products. The dairy chapter of FSANZ’s Compendium of microbiological criteria for food (March 2022) provides best practice guidance on the use of process hygiene and microbiological guideline criteria for verification of a range microbiological controls for the major dairy product categories.

While many of the pathogens we encounter in dairy products have a faecal origin, one major pathogen, Listeria monocytogenes, is recognised as an environmental contaminant. Food contamination involving L. monocytogenes can often be traced to poor sanitation practices and a lack of environmental monitoring.

For this reason, DFSV recommends that premises manufacturing ready-to-eat dairy products able to support the growth of L. monocytogenes implement thorough environmental monitoring programs to detect when and where Listeria may have become entrenched in their environment. It should be noted that finished product testing is not as sensitive to detecting potential contamination as environmental monitoring.

Typically, wet and cold environments provide niches that may harbor Listeria and provide a potential source of product contamination. Listeria can grow in cold environments (>4ºC).

An effective Listeria environmental monitoring program should be based on a zone approach, with swabs taken from food contact surfaces and adjacent areas. Microbiologists skilled in Listeria detection should be consulted to advise on developing a series of regular monitoring points – to provide confidence that Listeria will be detected if it has invaded the processing area.

A focus of swabbing should be on those hard to reach and clean areas, such as hidden surfaces and welding joints, rather than wasting time swabbing smooth surfaces. Listeria is a persistent organism and it finds refuge in unusual places, such as hollow conveyor rollers and ladder rungs, wall cavities and chiller insulation. Listeria is not likely to become entrenched in dry environments, but operations or equipment that are normally wet are vulnerable.

A detection of Listeria spp. should result in more thorough cleaning and sanitising of an area and follow-up testing. If retesting yields negative findings, then return to normal monitoring of that area. Positive retests suggest Listeria may have found a harborage point, requiring more thorough testing and elimination.

For more information on environmental monitoring programs, consult the following:

Grocery Manufacturers Association (2014). Listeria monocytogenes Guidance on Environmental Monitoring and Corrective Actions in At-risk Foods

Talk with your consulting laboratory and your DFSV food safety manager.