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Extension Services for Quality Milk Production
Proceedings of an International Workshop in conjunction with the East-West-Forum of the Federal Ministry for Food, Agriculture and Forestry and the "Window of German Animal Breeding" at the International Green Week
24-25 January, 1999
Session I
Milk Quality Requirements in the European Union - Trends
and Reasons
D. Goeman - Federal Ministry of Food, Agriculture and Forestry
Mr Chairman,
Ladies and Gentlemen,
Thank you very much for your kind invitation to speak to you here today.
Due to his busy schedule, Federal Minister Mr Karl-Heinz Funke, who is
currently President of the EU Council of Agriculture Ministers, has asked
me to convey his warm greetings and best wishes for a successful outcome
of this technical seminar that he considers very important.
In the interest of fair international competition, Federal Minister
Mr Funke strongly supports to strive for global harmonisation of quality
requirements and hygiene provisions not only for milk.
This is a particularly pressing matter with a view to the accession
of European countries to the Community and the closer trade relations with
the rest of Europe.
Please let me start with two short personal remarks.
First, I believe the reason why our hosts have chosen me to deliver
the introductory paper is that I will in the near future be involved in
one of the EU twinning projects in a candidate country and there try to
address on site the problems associated with today's topic.
Second, in my presentation I will therefore often try to present the
problems from the viewpoint of the applicant states. In doing this, I will
use the terms milk quality and milk hygiene largely as synonyms as this
is usually done on international level.
While these terms are not identical, their definitions are very closely
related, so I hope you may forgive me a certain lack of precision.
Speaking to you as experts who I assume largely know the EU hygiene
requirements for milk and milk products, I will spare myself the discussion
of their numerous details.
As annex to my paper, which is available to you in English and German,
you will find the major relevant provisions summarized in tables. They
are taken from the German regulations resulting from the implementation
of the EU Directives on milk hygiene.
Why has the Community adopted uniform quality and hygiene provisions
for milk?
Due to their biochemical composition milk and products derived from
milk constitute one of the most important components of human nutrition.
Unfortunately, these products are highly perishable.
When secreted from the healthy mammary gland, milk contains all components
but only very few microorganisms and usually no residues or contaminants.
The fundamental goal of all efforts is thus to maintain this high natural
quality as far as possible in the further course of marketing by careful
treatment and good hygiene practices.
In consequence, this means that all appropriate measures to ensure
the hygienic status of milk and to maintain its quality from stable to
table assume particular importance.
When the European Hygiene Directive of 1992 and its amendment of 1994
were adopted, the following primary aspects were taken into account with
a view to the internal market:
-
The overall quality and hygiene principal ensures that the consumer benefits
from careful and hygienic production and treatment of the milk by farmers,
manufacturers and retailers.
-
Full compliance with the EU Milk Hygiene Directives ensures a high level
of health protection for the consumers.
It creates mutual trust among the Member States so that the border
checks of milk products that used to be carried out, and often impeded
intra-Community trade, are no longer necessary in the EU.
-
Furthermore, the Hygiene Directive helps to reduce distortions in competition
caused by different national hygiene and quality rules in individual Member
States of the Community.
-
Imports of milk and milk products from third countries into the Community
must fulfil the same hygiene and quality requirements.
Hygiene cannot be differentiated according to origin.
In addition to these primary aspects there are further considerable
benefits:
-
compliance with the hygiene rules contributes essentially to the prevention
of epizootic diseases,
-
it enables the individual holding to make better use of the potential of
lactating animals
-
the use of processing capacities in sectors downstream to the farm is maximized.
Maintenance of the highest possible milk quality by adopting hygiene measures
is also a worthwhile objective from the view of the countries that have
supply contracts with the Community:
-
because they can make full use of the asymmetrically granted supplies under
the EC Treaty and prepare for their competitiveness after accession,
-
because after the completion of the WTO II Round they have to be competitive
both on domestic and export markets and
-
in order to achieve a higher profitability of individual establishments.
The hygiene standards laid down by the Community are equivalent to the
international notion of milk hygiene, as it has been developed on the level
of the International Dairy Federation and by Codex Alimentarius/WHO.
All these efforts are undertaken with the fundamental goal to create
a basis of mutual trust on a global scale that allows the individual country
to ensure maximum health protection for its consumers without having to
resort to import restrictions.
If I put myself in the position of the applicant states and Eastern
European Countries, I see above all the need to determine the current status
of animal health and hygiene on farm level.
This includes:
-
Adequate detection of epizootics, in particular those that may be transmitted
to man through milk.
In order to achieve this, it is necessary
-
to organise efficient veterinary and food surveillance and
-
to introduce mandatory notification of diseases in dairy animals.
It is essential to ensure that own checks carried out by establishments
are closely monitored by authorities.
-
Establishment of efficient independent laboratories for the analysis of
milk on
-
plate count,
-
somatic cell count,
-
water content,
-
antibiotics,
-
residues and contaminants,
-
milk components (fat, protein, lactose etc) for quality payment, which
I will discuss later.
-
Co-operation with relevant institutions in EU Member Countries is possible
and also in the interest of the Community as
-
it allows early detection of epizootic agents and their elimination in
the initial stage,
-
it facilitates quality grading of milk and milk products in supply contracts,
-
cooperations between laboratories in the fields of education, taking over
used laboratory equipment at favourable conditions and co-ordination of
interlaboratory studies for calibration are useful.
Finally, let me point out in this respect the support provided by the Community
in the Phare programme and the twinning projects.
Measures to maintain and improve milk quality/hygiene in production
and processing of milk
-
Purposeful commitment and investments as well as co-operation between farmers,
interest groups, manufacturers and authorities are essential to the successful
adoption of measures.
-
In my opinion, the applicant states and Eastern European Countries will
not immediately be able to satisfy Western European quality and hygiene
standards. However, these have to be complied with when exporting to the
Community. As far as the domestic markets are concerned, it will be necessary
to be more generous for the time being.
-
Nevertheless, purposeful measures should be initiated as soon as possible.
-
As milk also constitutes a formidable substrate for pathogens and other
undesired microorganisms, these must be prevented from growing by cooling
the milk and applying pasteurization or other (heat) treatments that destroy
microorganisms or at least hinder their growth.
In this respect, it is essential that if possible the entire milk volume
is subjected to these measures in order to ensure the safety of public
and animal health.
-
It must be seen to the fact that programmes aiming at the eradication of
diseases and the rebuilding of dairy herds are combined in such a way that
healthy animals are not infected by diseased animals since that would wreck
the rebuilding efforts to a large extent.
-
In combination with the introduction of standards for the improvement of
milk hygiene and quality in production, treatment, processing and marketing,
a quality payment scheme on the basis of the following parameters has to
be introduced:
-
milk components,
-
maximum limits for residues and contaminants,
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maximum levels of antibiotics,
-
somatic cell counts,
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determination of water content,
-
cooling and storage of the milk on the farm to rationalize milk collection.
As a rule, it may be said that the higher the financial incentive
for production of higher quality, the faster the increase in quality on
national average is achieved, as investments to improve quality are more
profitable.
As an indirect result, all those who are not striving for quality or
are doing so with less success receive lower payments out of the remaining
means of the dairies.
Often it is this group of milk producers that can and must be aided
by providing for the involvement of veterinary services or food inspection
authorities when limits are exceeded.
For this reason, every milk producer endeavours to adapt as fast as
possible to the more favourable conditions.
-
Our experience with East Germany has shown that with the large herds it
might become necessary to allow the division of herds on the basis of milk
quality and health status of the animals.
This offers the possibility
-
to separate better cows yielding a higher milk price from the less profitable
cows with reduced milk payment,
-
to take full advantage of milk quality premiums,
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to combine treatment and culling programmes with the enlargement of the
healthy part of the herd in a sensible way.
Are the Western European hygiene and quality rules that focus on international
hygiene standards too prescriptive?
-
Everybody knows that sour milk is unsuitable for further processing.
-
Milk containing contaminants or residues affects the consumer (chlorohydrocarbons,
heavy metals, polychlorinated biphenyls and dioxins, aflatoxin and other
toxins).
Contamination of milk with these substances is either due to the application
of veterinary drugs, carry-over from feedingstuffs or environmental factors.
Persistent contaminants involve the risk of accumulation in the food chain,
which is particularly dangerous to breast-fed infants.
-
The addition of water to milk leads to increased costs of transport and
processing (e.g. drying), results in a higher risk of infection by the
added water and in general borders on fraud in the legal sense.
This problem can only be solved by spot checks on water content and
payment on the basis of milk components.
-
A high plate count in milk affects flavour and taste even if the count
of raw milk may be reduced by heat treatment.
Destruction of the microorganisms, however, does not mean that the
enzymes and toxins already produced are also eliminated by heat.
In this context it has to be critically pointed out that many dairies
use raw milk with a higher plate count for the manufacture of heat-treated
products assuming that the application of high temperature short time pasteurization
would ensure complete destruction of the micro-organisms. They are, however,
neglecting the fact that the enzymes and toxins that have already been
produced and survive heat treatment cause early spoilage especially in
milk products that are normally characterized by longer shelf-life.
It is therefore recommended to use in the manufacture of heat-treated
milk only raw materials with the lowest possible plate count that has undergone
careful and hygienic treatment.
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Milk with high somatic cell count is an indicator for mastitis, which has
severe economic implications for the milk producer.
The milk is no longer marketable.
Other animals are easily infected.
Treatment and decrease in milk volume etc. cause considerable losses per
animal (300 to 400 DM with mastitis).
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Milk containing inhibitors, especially antibiotics, must not be put on
the market as foodstuff for reasons of health protection (Regulation 2377/90/EEC
on maximum residue levels).
Even small amounts of such milk affect processing of large milk volumes
in the dairy.
Above all, milk containing antibiotics can no longer be used for the
manufacture of products that involve the addition of cultures in the dairy
(fermented milk, cheese etc.).
Time and again milk with antibiotics is detected. This gives rise to
the concern that it might enter the drinking milk sector and have negative
effects on the consumer.
For this reason, it must be withdrawn from the market.
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The production of wholesome and top quality milk is a prerequisite for
medium-term economic success.
-
Utmost care on the farm level, however, is futile if cold storage during
transport and rapid hygienic and careful processing in the dairy is not
ensured.
Conclusion
Ladies and Gentlemen, I am fully aware of the fact that I have said
too little about the requirements dairies have to meet. I am often told
that lack of high quality raw milk constitutes the main impediment to investments
from Western dairy companies and causes some frustration.
The subject of milk processing will certainly be discussed in the following
presentation by Mr. Birker.
For the future, a trend towards comprehensive simplification of the
Community's rules on milk quality and hygiene begins to emerge.
In this context it will be necessary to follow the progress of standardisation
on international level by IDF, FAO/WHO and GATT/WTO.
It is my wishful dream that we might as soon as possible succeed in
developing a simplified certificate for the import and export of milk that
would replace the large number of bilateral equivalence agreements on the
trade in dairy products.
As far as milk components and for instance potential standardisation
not only of milk fat but also of milk protein are concerned, we need in
the long run a legal framework that accommodates the technological potential
in milk processing.
Last but not least, the issue of hormones and genetically engineered
enzymes will keep us all busy in the future.
Scope of German specific milk hygiene rules by implementation
of Council Directives 92/46/EEC and 94/71/EC
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Laying down of health rules for obtaining, treating, producing and placing
on the market of
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raw and certified milk,
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heat-treated drinking milk,
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industrial milk,
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milk-based products (e.g. dairy products, cheese, butter) and foodstuffs
of which milk constitutes a major part (ice cream)
-
As a rule these provisions also cover milk from other animals than cows.
-
The provisions also apply
-
to wholesalers,
-
retailers, restaurants and catering establishments provided they also produce
edible ice.
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The provisions do not apply to establishments using milk or milk-based
products for the manufacture of foodstuffs that are not covered by the
Scope as described above (delicatessen industry, bakeries etc.). In those
cases general food law is applicable.
Requirements for the collection of raw milk at farm level
and delivery to treatment and/or processing establishments in Germany by
implementation of Council Directives 92/46/EEC and 94/71/EC
1. Raw cow's milk must
1.1 meet the following requirements for the manufacture of heat-treated
drinking milk, fermented milk, yoghurt, kefir, cream and milk blends:
Plate count at 30 °C/ml |
£ 100 000 (1) |
Somatic cell count/ml |
£ 400 000 (2) |
1.2 meet the following additional requirements for the manufacture of
raw milk products:
a) Staphylococcus aureus (ml) n3) = 5 m4) = 500
M5) = 2000 c6) = 2
b) Salmonella (ml) n3)=5 m4)=0 M5)=0
c6)=0c) other pathogens and their toxins must not be present
at levels that may affect the health of the consumers.
1.3 meet the following requirements for the manufacture of other milk-based
products:
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until 31.12.1997 (7)
|
from 01.01.1998
|
Plate count at 30 °C/ml |
£ 400 000 (1)
|
£ 100 000 (1)
|
Somatic cell count/ml |
£ 500 000 (2)
|
£ 400 000 (2)
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(1) Geometric mean over a period of two months with at least two
samples a month.
(2) Geometric mean over a period of three months with at least one
sample a month.
(3) n = number of samples;
(4) m = threshold value; result is considered satisfactory if individual
samples do not exceed this value;
(5) M = maximum value; result is considered unsatisfactory if sample
values are exceeding this value;
(6) c = number of samples between m and M; result is considered
satisfactory if other samples < m.
(7) Transitional rule that, however, required separate collection
and delivery of raw milk and therefore expired on 31 .12. 1997.
Own checks and records in Germany by implementation of Council
Directives 92/46/EEC and 94/71/EC
(1) Anyone producing or treating milk or milk-based products in
treatment or processing establishments must:
1. by means of own-checks
a) identify the critical points on the basis of the process used,
b) lay down and apply methods for monitoring and checking of such critical
points as appropriate for the amount of milk processed and milk-based products
manufactured
c) monitor the checking result in order to check compliance with the
relevant standards and
d) draw up a plan for cleaning and disinfection of working areas, equipment
and instruments and check the results of the cleaning and disinfection
methods applied
2. keep records of the measures applied and the results of the checks
in compliance with 1. and produce them at the request of the competent
authority.
(2) The records shall in particular be kept in chronological order for
two years. This period shall be reduced to three months after use-by or
minimum durability date for milk-based products that cannot be stored at
ambient temperatures.
(3) For the purpose of these own checks processing establishments must
either have their own laboratory or have the checks carried out by a registered
laboratory.
Requirements for milk-based products in Germany by implementation
of Council Directives 92/46/EEC and 94/71/EC
Table 1: Microbiological standards for certain milk-based products
on removal from the treatment and/or processing establishment
| Type of standard |
Standard |
Measures at the establishment |
|
|
1.- Pathogenic micro-organisms such as
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Listeria monocytogenes
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Salmonella spp.
2. Other pathogens and their toxins must not be present in quantities such
as to affect human health |
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Foodstuffs are excluded from placing on the market
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Sampling plans to be drawn up on the basis of product type and risk analysis
|
|
|
Micro-organisms indicating poor hygiene
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Staphylococcus aureus
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Escherichia coli
|
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Application of a Hazard Analysis and Critical Control Point System,
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information of competent authority (veterinary officials, food surveillance).
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In certain cases subsequent investigations,
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possibly withdrawal of the product from the market.
|
|
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Guiding levels for indicator organisms:
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If values are exceeded proper functioning of
the establishment is to be checked. |
Table 2: Grading of farm milk (German Milk Quality
Ordinance) based on the requirements for treatment and processing (German
Milk Ordinance)
| Grade |
01.01.1994
|
01.01.1998
|
| Plate count/ml 1 |
£ 100000
|
|
|
£ 100000
|
|
| 2 |
|
£ 400000
|
|
|
> 100000
|
| 3 |
|
|
> 400000
|
-----------
|
----------
|
| Somatic cell count/ml |
£ 400000
|
£ 500000
|
> 500000
|
£ 400000
|
> 400000
|
| Utilization of farm milk |
-
drinking milk
-
fresh milk products
|
-
other milk-based products
|
non-food |
-
drinking milk
-
milk-based products
|
non-food |
Notes:
£ less than or equal to grade = geometric
mean over a period of 2 months with at least 2 samples a month
> more than somatic cell count = geometric mean over a period of 3
months with at least 1 sample a month
Requirements for drinking milk by implementation of Council
Directives 92/46/EEC and 94/71/EC
Table 3: Specific requirements for pasteurized drinking milk
in Germany
| pathogens in 25 ml |
n = 5 |
c = 0 |
m = 0 |
M = 0 |
| coliforms (per ml) |
n = 5 |
c = 1 |
m = 0 |
M = 5 |
| plate count at 30 °C (per ml) |
|
|
£ 30000 |
|
Table 4: Specific requirements for:
UHT and sterilized drinking milk must satisfy the following requirements
in spot checks at the treatment and/or processing establishment:
| plate count at 30 °C (per 0.1 ml) |
£ 10 |
| sensory evaluation |
no remarkable deviations |
| chemical and physical examination |
no remarkable changes |
Table 5: General requirements for heat-treated drinking milk (cow’s
milk) in spot checks at the treatment and/or processing establishment:
| freezing point1) |
£ -0.520 °C |
| specific weight at 20 °C |
minimum 1028 g/l |
| protein (percentage total nitrogen content of
milk multiplied by 6.38) |
minimum 28 g/kg |
| fat-free dry matter |
minimum 8.50 % |
1) Freezing point higher than - 0.520 °C
is acceptable provided that the determination of freezing point does not
reveal any extraneous water.
Table 6: Mean biological value of dietary proteins
| dietary protein |
biological value
|
| whole egg
cow’s milk
casein
lactalbumin
beef
potato
peanut
wheat flour |
100
92
73
104
78
69
60
45
|
Source: H.D. Böhm/W. Heeschen: Das neue Milch-Hygienerecht
’95, p. 12.
Table 7: Diseases transmissible to man through milk major source
of infection man dairy animal environment
| Disease |
major source of infection
|
| |
man
|
dairy animal
|
environment
|
| BACTERIA |
|
|
|
| anthrax *) |
|
X |
X |
| botulism toxin |
|
|
X |
| brucellosis |
|
X |
|
| cholera |
X |
|
|
| pathogenic E. coli |
X |
X |
|
| infection with Clostridium perfringens |
|
|
X |
| diphtheria |
X |
|
|
enteritis *) (non-specific disorders, caused by large
numbers of destroyed or viable coli, Proteus, Pseudomonas or Cl. welchii
cells etc.) |
|
|
X |
| leptospirosis *) |
|
X |
|
| listeriosis *) |
|
X |
|
| paratyphoidfever |
X |
X |
|
| salmonellosis (other than typhoid and paratyphoid fever) |
X |
X |
|
| shigellosis |
X |
|
|
| gastro-enteritis due to Staphylococcus enterotoxin |
X |
X |
|
| infections with Streptococcus |
X |
X |
|
| tuberculosis |
X |
|
|
| typhoid fever |
X |
|
|
| VIRUSES |
|
|
|
| adenoviruses *) |
X |
|
|
| enteroviruses (incl. poliovirus and coxcackievirus) |
X |
|
|
| virus causing foot-and-mouth disease |
|
X |
|
| hepatitis A virus *) |
X |
|
|
| virus of tick-borne encephalitis |
|
X |
|
| RICKETTSIAE |
|
|
|
| Q fever |
|
X |
|
| PROTOZOA |
|
|
|
| amoeba *) |
X |
|
|
| Toxoplasma *) |
X |
|
X |
*)Transmission through milk is not always proven but epidemiologically
probable or suspected.
Source: H. D. Böhm/W. Heeschen: Das neue Milchrecht
'95, p. 16.
Chart 1: Probability of false evaluations depending on the chosen
limit
Source: H.D. Böhm/W. Heeschen: Das neue Milchrecht
’95, p. 33
Chart 2: Growth rates of micro-organisms with different
optimum temperatures
Source: H.D. Böhm/W. Heeschen: Das neue Milchrecht
’95, p. 25
Chart 3: Residues and contaminants in milk and milk products
Source: H.D. Böhm/W. Heeschen: Das neue Milchrecht ’95, p. 40
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