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Dairy primary production includes businesses involved in the production of milk or colostrum, whereby the product undergoes further processing for human consumption.
This includes:
- keeping, grazing, feeding and milking of animals, and
- storing milk product on the premises at which the animals were milked.
Changes to test failure notifications
A recent change to the NSW Food Regulation has introduced shorter timeframes for retail meat premises to notify the Food Authority if a sample fails the limits outlined in the Food Safety Schemes Manual. Businesses must now notify the Food Authority by phone within 24 hours and in writing within 48 hours of becoming aware of the results. Written reports can be submitted using the online Notify a pathogen detection form.
Licensing, registration
Operators in the dairy primary production industry are required to:
- apply for a Food Authority licence online or download an application form (PDF, 172 KB), print and post it
- prepare for regular audits.
You must not commence operations until you are informed that your licence application has been processed. If the premises are found to be operating without a licence, enforcement action may be taken.
- For more see applying for a food licence
Skills & knowledge
There are no formal qualifications required for dairy farmers, however each food handler and person in control of a food business is required to have food safety skills and knowledge appropriate to their food handling activities.
The full requirements are set out in the Food Standards Code, Standard 3.2.2 - Food Safety Practices and General Requirements, clause 3 and the FSANZ guide Safe Food Australia.
Construction & facilities
Construction and layout of a food premise must be designed to minimise the opportunity for food contamination.
Dairy primary production facilities must ensure that their fixtures, fittings, equipment and transport vehicles are designed and constructed in a manner that means they can be easily cleaned and, where necessary, sanitised.
Businesses must also ensure that the premises are provided with the necessary services of water, waste disposal, light, ventilation, cleaning and personal hygiene facilities, storage space and access to toilets.
The full requirements are set out in the Food Standards Code, Chapter 3, Standard 3.2.3 - Food Premises and Equipment and the FSANZ guide Safe Food Australia.
Hygiene & handling
A food handler must take all reasonable measures not to handle food or surfaces likely to come into contact with food in a way that is likely to compromise the safety and suitability of food.
For details see the Food Standards Code, Standard 3.2.2 - Food Safety Practices and General Requirements, clause 3 and the FSANZ guide Safe Food Australia.
Cleaning & sanitation
Dairy primary producers must implement a documented cleaning schedule that identifies:
- all fixtures, fittings and equipment used in the processing of dairy products
- the frequency of cleaning
- how all fixtures, fittings and equipment are cleaned and sanitised
- how food contact surfaces and utensils are sanitised (where applicable)
- chemical usage eg. strength, contact times, temperature.
All fixtures, fittings and equipment must be adequate for the production of safe and suitable food, and fit for their intended use.
Routine internal cleaning and sanitation inspections must be undertaken, and records maintained for corrective action taken on any identified issues.
Cleaning chemicals must be suitable for contact with food and used in accordance with the manufacturer’s instructions.
Food safety controls
Dairy primary production businesses need to maintain a food safety program.
This is a tailored operating plan for the business which identifies hazards to food safety and how the business will manage them.
For a generic starting template see Food Safety Programs.
Labelling
Product labelling requirements apply, as set out in the Food Standards Code, Chapter 1, Part 1.2 - Labelling and other Information Requirements and the FSANZ labelling user guides.
For an introduction to product labelling and Food Authority factsheets see labelling.
Testing
The only testing required by dairy primary production businesses is for unpasteurised goats' milk that is being packaged at the business.
Testing requirements are outlined in the NSW Food Safety Schemes Manual.
Importantly, you should know that:
- Microbiological testing is required to confirm that processing is hygienic and sanitary and meets the required standards
- Any analysis is at the licence holder’s expense. It needs to be conducted by a laboratory accredited by the National Association of Testing Authorities (NATA) or International Laboratory Accreditation Cooperation (ILAC). Only tests for pH or environmental swabbing for Listeria may be conducted in-house, without NATA accreditation, using a validated method.
- If an analysed sample fails to meet the standards as detailed in the Manual, the licence holder must notify the Food Authority by phone within 24 hours and in writing within 48 hours of becoming aware of the sample failure using the Food Authority’s online Notify a pathogen detection form.
Inspections & audits
Dairy primary producers will be routinely inspected by the Food Authority for compliance with requirements.
Compliance or regulatory action will be taken if required.
There are fees for audits and inspections, payable by the licence holder.
For more see audits of licensed businesses
Legislation & standards
As an operator in the dairy primary production industry, you will need to meet the requirements set out in:
- Food Act 2003 (NSW)
- Food Regulation 2025 (NSW), including relevant parts of the Dairy Food Safety Scheme
- Food Standards Code, including:
- Food Standards Code 3.2.3 - Food Premises and Equipment
- Food Standards Code 3.2.2 - Food Safety Practices and general requirements - Premises and Equipment
- Standard 4.2.4 - Primary Production and Processing Standard Dairy
- AS 4674:2004 - Design, construction and fit out of food premises