Public Health and the Dairy Industry

Public HealthRisk Management

Introduction

Public Health and the Dairy Industry

Whilst most of the key public health outcomes relevant to the dairy industry are achieved through food safety regulation and related programs, it is important to consider the dairy industry’s contribution to zoonotic disease management and the dairy contribution to nutritional public health benefits. This risk management framework focuses on these issues.

Dairy products are an important component of a healthy diet and the dairy industry is proud to contribute to public health from the nutritional perspective. The industry has a strategic priority[i] to “proactively promote and protect dairy’s value and integrity” which incorporates programs to enhance the acceptance and uptake of dairy foods by consumers, as well as to manage the risks to public health that are inherent along the dairy supply chain (Dairy Australia). Much of the public health debate in the dairy industry centres on the consumption of unpasteurised milk (refer to the section below regarding “Dairy Product Related Food Borne Illness”).

Australia has a comprehensive range of public health risk management arrangements to protect the health of the general public. These are augmented by specific statutory requirements and targeted programs to address particular risks within industries. Each State has some form of dairy regulatory legislation or scheme that supplements the Australia New Zealand Food Standards Code (Food Standards Code). These regulatory arrangements, along with the Food Standards Code and guidelines and manuals, help to assure a safe supply of milk and milk products in Australia. Additionally, the Export Control Orders help to assure the safe supply of food to the international markets.

The risks posed to public health from dairy cattle zoonoses are small and are generally confined to people working in the industry in close contact with cattle on farms. For example, on average, 5% of dairy workers in Queensland’s Atherton Tablelands are diagnosed with leptospirosis every year (Source: Queensland Health Leptospirosis Guidelines). Dairy farmers have a responsibility to ensure that workers know about zoonoses such as leptospirosis, and how to reduce the risk of contracting such diseases. “Leptospirosisis a disease caused by the spirochaete, Leptospira spp, and is characterised by fever and myalgia in humans. Transmission can occur through urine contaminated water and hay being ingested, inhaled or absorbed through the skin and eyes. People at risk from leptospirosis include abattoir workers, dairy farmers, cattle farmers, veterinarians, piggery workers, cane farmers, and banana growers. Nationally, 176 notifications of leptospirosis were received during 2004 where at least 6% of cases are known to have occurred in dairy industry workers”. (Source: “National Farm Injury Data Centre 2006. Occupational Health & Safety Risk in the Australian Dairy Industry. The Facts, 2006. Australian Centre for Agricultural Health and Safety”: Moree).

It is estimated that the Australian dairy industry involves around 100,000 people through farming(9,266 farms employing about 50,000 people), services to farming (an estimated10,000 people), manufacturing (estimated at up to 30,000 people), transport andresearch activities. Over half (52%) of Australia’s dairy farm businesses rely solelyon family labour (Dairy Australia, 2005).

Australia has a very safe supply of milk and dairy products based upon existing standards in the Australia New Zealand Food Standards Code and Australia’s ‘paddock to plate’ approach to food safety regulation[ii]. The Australia New Zealand Food Standards Code requires that all milk for human consumption in Australia must be either pasteurised or treated by an equivalent heat treatment system to ensure public health and safety. As a result, the risk to the general public from milk-borne zoonotic agents is effectively eliminated. The focus of attention is on protecting the health of the people who work and live on the estimated 7,500 dairy farms around the country.

The Food Standards Code specifies controls to manage potential microbiological hazards in dairy products, which include food-borne zoonotic disease agents. The National Dairy Standard 4.2.4specifically 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. Specifically, Standard 4.2.4 requires milk to be heat treated to the equivalent of 72°C for 15 seconds or more if the milk solids content is greater than normal milk. Milk must be cooled after the heat treatment to minimise the growth of pathogenic micro-organisms. Cheese can be made from milk with a lower heat treatment but must be held for 90 days or more. Regulators and industry have prepared guidelines for the validation and verification of heat treatment equipment and processes.

The risk management systems in place to address the risks to public health posed by diseases that can be passed from animals to humans (zoonoses) are covered in this document. The risk management systems for other risks to public health, including food safety, occupational health and safety, animal health, and biosecurity are the focus of separate related documents within the Risk Visualisation Tool.

The Dairy Risk Profile

As part of the Food Standards Australia New Zealand (FSANZ) standard development framework for Proposal P296, the National Dairy Primary Production and Processing Standard (later to be gazetted as Standard 4.2.4 of the Food Standards Code), a scientific assessment “A Risk Profile of Dairy Products in Australia”(the Dairy Risk Profile), was undertaken within the context of the national food safety regulatory framework (refer to Dairy Food Safety Risk Management Systems document for details of the national regulatory system). The Risk Profile examined both microbiological and chemical risks for the dairy sector.

“With regard to microbiological hazards, the Risk Profile considered the:

• Identification and description of microorganisms that may be associated with dairy products including key attributes of each organism and its public health impact;

• Examination of epidemiological data (domestic and international) related to the consumption of dairy products;

• Examination of prevalence and concentration data on potential hazards from products along the entire dairy food chain; and

• Description of the dairy production, processing, distribution and consumption chain and current knowledge of the impact of each of these on public health and safety risks.

The examination of chemical hazards considered:

• Agricultural and veterinary chemicals used in primary production;

• Environmental contaminants, including heavy metals, organic contaminants and micronutrients;

• Natural chemicals found in plants, fungi or bacteria associated with plants;

• Food processing by-products;

• Food additives, processing aids and those chemicals that may migrate from packaging.”

Dairy Risk Profile Key Findings

The FSANZ Risk Profile determined that “the current management practices in place within the Australian dairy industry support the production of dairy products with a high standard of public health and safety. The key findings include:

• Consumption of dairy products is rarely linked to food-borne illness in Australia.

• A wide range of microbiological hazards may be associated with raw milk and dairy products, but these do not represent a problem under current management practices which:

- control animal health;

- ensure adherence to good milking practices;

- require effective heat treatment e.g. pasteurisation; and

- have controls to prevent post-pasteurisation contamination in the dairy processing environment.

• There are minimal public health and safety concerns regarding the use or presence of chemicals in dairy products due to the extensive regulatory and non-regulatory measures in place along the dairy industry primary production chain.

• Extensive monitoring of chemical residues in milk over many years has demonstrated a high level of compliance with the regulations.”

The outcomes of the Risk Profile demonstrate that the existing regulatory arrangements and industry initiatives that have been implemented are effective in protecting the public health and safety of consumers. The FSANZ Risk Profile concluded that “the factors along the Australian dairy supply chain that have the most significant impact on the safety of processed dairy products are:

• the quality of raw materials;
• correct formulation;
• effective processing (pasteurisation in particular);
• the prevention of recontamination of a product; and
• Maintenance of temperature control during distribution, retail sale and storage of the product in the home.”

Dairy Product Related Food Borne Illnesses

Food borne illnesses related to food-handlers is discussed in more detail in the Retail / Markets risk management section. The following is an extract from the Draft Assessment Report for Proposal P296, Primary Production and Processing Standards for Dairy, conducted by Food Standards Australia New Zealand in 2006:

“In Australia, illness from dairy products is generally rare. For example, between 1995 and 2004, there were only eleven reported outbreaks directly attributed to dairy products, eight of which were associated with consumption of unpasteurised milk. In other Australian outbreaks, dairy products were an ingredient of the responsible food vehicle identified as the source of infection. However, dairy products are a component of many foods and it is often difficult to attribute the cause of an outbreak to a particular food ingredient. Microbiological survey data for pasteurised dairy products in Australia show a very low incidence of hazards of public health significance in these products. While commercial dairy products have rarely been identified as sources of food-borne illness in Australia, there have been a number of reports of outbreaks associated with consumption of dairy products internationally. Unpasteurised dairy products are the most common cause of these dairy-associated outbreaks of illness.”

What is Public Health?

In 1920 CEA Winslow classically defined public health as "the science and art of preventing disease, prolonging life and promoting health through the organized efforts and informed choices of society, organizations, public and private, communities and individuals"[iii]. Public health is concerned with threats to the physical and mental health of populations, which arise from many different aspects of living.The term “public health” is often used synonymously with the term “population health”, butpublic health does not focus on the public health care system alone. Public Health comprises many fields of endeavour.

Under the Australian Constitution (Section 51) States and Territories are responsible for public health, including food safety and standards. The Commonwealth, States and Territories of Australia, together with New Zealand, have come together to create a structure to regulate the food supply. This partnership continues to provide an overarching framework and legal obligations for food businesses to produce food that is safe and suitable for human consumption.

Australia’s health system is world class, supporting universal and affordable access to high quality medical, pharmaceutical and hospital services, while helping people to stay healthy through health promotion and disease prevention activities. The Australian Government has a vision to achieve “better health and active ageing for all Australians”[iv] and maintaining and improving public health is a high priority for Federal, State and Territory and Local Governments, as well as the community at large. The Australian Government has limited involvement in public health issues, with the States taking a major responsibility for the management of public health andcommunicable diseases.

Public Health Legislation

In October 1996, Australian Health Ministers agreed to the implementation of the National Public Health Partnership (NPHP) as a working arrangement to plan and co-ordinate public health activities, to provide a more strategic approach to public health activities and implement new national initiatives. One of the key priorities of the NPHP is the review of the public health legislative and regulatory framework.Public health law comprises many issues, including the “core” public health legislation relating to food, drugs, poisons, therapeutics, tobacco and radiation. There are many other pieces of legislation that have a significant impact on public health, such as the Commonwealth Trade Practices Act which includes provisions relating to product safety, liability for defective products, and occupational health and safety. Commonwealth public health legislation does provide the basis for determinants of health and disease.

The aim of public health legislation is to protect and promote the health of the public. State Public Health legislation provides the basic safeguards necessary to protect public health through cooperation between Governments, local governments, health care providers, industries and the community.This is achieved by:

preventing, controlling and reducing risks to public health

providing for the identification of, and response to, notifiable conditions

defining obligations on persons and particular health care facilities involved in the provision of declared health services to minimise infection risks

providing for the notification by doctors and registered nurses of child abuse and neglect, and protecting children who have been harmed or are at risk of harm when they present at health service facilities

collecting and managing particular health information, and establishing mechanisms for health information held by Government to be accessed for appropriate research

inquiring into serious public health matters

responding to public health emergencies

providing for compliance with public health legislation to be monitored and enforced.

Risk Management in the Dairy Industry

Based upon risk management and supported by science, the Australian dairy industry has developed quality management systems that underpin the regulatory requirements. The Australian dairy industry works collaboratively with government regulatory agencies and service suppliers to ensure a preventative approach to manage risks across the integrated supply chain. The industry approach is outcome focused, science based, non-prescriptive and proportionate to risk.

The Australian Dairy industry risk management system is an overarching through-chain framework across the integrated risk management systems, including animal health, animal welfare, biosecurity, food safety, public health, environment and occupational health and safety. The objective is to provide a comprehensive and industry-wide approach to address issues that may affect the reputation and future viability of the Australian dairy industry(Dairy Australia).

The Australian dairy industry works in a co-regulatory partnership approach to identify any emerging issues and hazards that may represent a risk to or adversely affect the dairy industry and dairy product safety. Through strong international linkages, this ensures the Australian industry is aware of potential issues in other countries and actions being taken by various agencies and scientific researchers to investigate measures to correct or manage the issue. Proactive and reactive measures are undertaken to ensure industry risk management plans remain appropriate for the risk.

The Australian Dairy industry works collaboratively with government regulatory agencies and service suppliers to ensure a preventative approach to risk management across the integrated supply chain or value chain. The Dairy industry has introduced systems that manage the risks associated with dairy production, processing and distribution from pre-farm to the consumer. Thisthrough-chain approach incorporates all six sectors, including Pre-Farm, On Farm, Transport, Manufacture / Processing, Distribution and Retail.

The Australian dairy industry has developed quality management systems that underpin the regulatory requirements to control and mange identified risks. The various “controls” across the dairy risk management framework have been categorised into the following broad groupings:

Regulatory Systems,

National and International Standards,

Traceability and Verification Systems,

Market Forces, and

Industry and Commercial Programs.

The Dairy Supply Chain

The typical dairy supply chain is characterised by milk being produced at the dairy farm then being sold and transported to the manufacturer of milk products. The milk is then distributed as drinking milk or other milk products through distributors and retailers to the end consumers. However, there are many exceptions to this basic process where the dairy farmers process their own milk or manufacturers produce the milk at their own dairy farm. The distribution structure also varies depending on the size and scale of the operation.

Food Security / Bioterrorism

Food security and bioterrorism preparedness and planning is co-ordinated at an across government level through the Commonwealth Department of Agriculture (DoA), the Department of Health and Ageing, and State and Territory Departments of Premier and Cabinet through the inter-government “Trusted Information Sharing Network” Project.