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Dairy processing includes businesses that deal in the packaging, treating, cutting or manufacturing of dairy products, and the packing and storing of those products on the premises where they are processed.
It does not extend to dairy primary production.
Dairy products include colostrum, milk and any food that contains at least 50% milk or any substance produced from milk (by weight measurement). These include (but are not limited to):
- liquid milk products, buttermilk, concentrated buttermilk
- dairy blend
- cream, thickened cream
- butter, butter concentrate, ghee, anhydrous milk fat (butter oil)
- cheese
- yoghurt, cultured milk
- icecream, icecream mix
- casein, caseinate, whey, whey cream, concentrated whey cream
- buttermilk powder, lactose powder, milk sugar, powdered milk, skim milk powder, whey powder, milk protein powder
- other milk and concentrates.
Changes to test failure notification
A recent change to the NSW Food Regulation has introduced shorter timeframes for dairy processors to notify the Food Authority if a sample fails the microbiological and residue 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 relevant online form:
Licensing, registration
Operators in the dairy processing industry are required to:
- apply for a Food Authority licence online or download an application form (PDF), print and post it
- if producing raw milk cheese, submit your completed pro forma with the application
- prepare for regular audits.
You must not begin operations until you are informed that your licence application was successful. If the premises are found to be operating without a licence, enforcement action may be taken.
- For more see applying for a food licence
Raw milk cheese
Cheese producers wishing to produce raw milk cheese can download the Raw Milk Cheese Decision Support Tool. The tool was developed to assist cheese producers and food safety managers assess whether a particular raw milk cheese, and process, satisfies Australian regulations for safe production.
Any NSW business producing raw milk cheese must complete a production process pro forma, which is a written description of the steps used to make a particular product. The pro forma must demonstrate to the Food Authority that the production process is effective in reducing the numbers of L.monocytogenes to a safe level. The Food Authority will review the pro forma and must provide approval before manufacture can begin.
Visit our Export page for information about the Dairy Export Assurance Program that includes a free export facilitator service to dairy manufacturers.
Skills and knowledge
There are no formal qualifications required for dairy processors, 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 and facilities
Construction and layout of a food premise must be designed to minimise the opportunity for food contamination.
Dairy processing facilities must ensure their fixtures, fittings, equipment and transport vehicles are designed and constructed so they can be easily cleaned and, where necessary, sanitised.
Businesses must also ensure that the premises has 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 and 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 and sanitation
Dairy processors 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 (for example, 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 must be maintained for corrective action taken on any identified issues.
Cleaning chemicals and sanitisers must be suitable for contact with food and used in accordance with the manufacturer’s instructions.
Food safety program
Dairy processing businesses must 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.
The Food Authority's generic template can be customised to the business:
- Template for a food safety program (Word format, 56 KB)
- Guide to develop a food safety program (PDF, 226 KB)
Processing of dairy products
Clause 15 of Standard 4.2.4 specifically requires that the processing of milk and dairy products includes pasteurisation or an equivalent process to eliminate any pathogenic micro-organisms that may have been present in the incoming milk.
This control measure is also specified under clause 16 for the processing of cheese and cheese products, in addition to other control measures (such as pH, organic acid content, storage time and temperatures, water activity) that collectively provide an acceptable level of safety.
A person must not sell a dairy product for human consumption unless the product has been processed in line with these requirements.
Clause 15 and 16 do not apply to:
- a dairy primary production business for the sale of milk or cream to a dairy processing business, or
- a dairy processing business for the sale of a dairy product to another dairy processing business, or
- goats milk, but only if the milk has been produced in compliance with a food safety program (FSP) and (in the case of unpasteurised milk) the milk bears a label with a statement that complies with Clause 2 of Standard 1.2.3 - Mandatory Warning and Advisory Statements and Declarations.
For more information on the requirements, see Food Standards Australia New Zealand’s guide to Standard 4.2.4 Primary Production and Processing Standard for Dairy Products (PDF, 1MB).
Pasteuriser requirements
Equipment used for pasteurising dairy products at a processing business must comply with the requirements of the Guidelines for Food Safety: Validation and Verification of Heat Treatment Equipment and Processes.
The guidelines have been developed by the Australia New Zealand Dairy Authorities' Committee (ANZDAC).
Salmonella control
Dairy processing businesses must control Salmonella contamination in dried milk products in keeping with the Australian Manual for Control of Salmonella in the Dairy Industry published by the Australian Dairy Authorities’ Standards Committee.
Listeria control
Dairy processing businesses must control Listeria contamination in keeping with the Australian Manual for Control of Listeria in the Dairy Industry published by the Australian Dairy Authorities’ Standards Committee.
Labelling
Requirements for product labelling 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 and Food Authority factsheets see labelling
Testing & contaminants
Businesses operating in the dairy processing industry must meet the requirements outlined in the NSW Food Safety Schemes Manual.
Notification of residue detection for raw milk
Businesses receiving raw milk direct from farms need to advise the Food Authority if they detect antibiotic residue in the raw milk.
If a sample does not meet the standards set out in the Manual, the licence holder must notify the Food Authority within 24 hours by phone, and within 48 hours in writing, after becoming aware of the analysis results.
For the written notice, complete and submit the Notify a residue detection form.
Microbiological testing
The Manual details microbiological testing requirements. Importantly, you should know that:
- microbiological testing is required to confirm that processing is hygienic and sanitary and meeting the required standards
- testing must be carried out in a laboratory accredited by the National Association of Testing Authorities (NATA) or the International Laboratory Accreditation Cooperation (ILAC). Only tests for antimicrobial drug residues, pH or environmental swabbing for Listeria may be conducted in-house, without NATA accreditation, using a validated method.
- any analysis is at the licence holder’s expense
- if a microbiological sample does not meet the standards set out in the Manual, the licence holder must notify the Food Authority within 24 hours by phone, and within 48 hours in writing. You can submit the written notice using the Notify a pathogen detection form.
Inspections & audits
Dairy processors will be routinely audited by the Food Authority for compliance with regulatory 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 processing industry, you will also 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
- Standard 1.2.3 - Mandatory Warning and Advisory Statements and Declarations
- Standard 1.4.1 - Contaminants and Natural Toxicants
- Standard 1.4.2 - Maximum Residue Limits
- Standard 2.5.1 - Milk
- Standard 3.2.1 - Food Safety Programs
- Standard 3.2.2 - Food Safety Practices and General Requirements
- Standard 3.2.3 - Food Premises and Equipment
- Standard 4.2.4 - Primary Production and Processing Standard Dairy