Hygiene and Sanitary Obligations in On-Farm Dairy Processing
Hygiene is an essential pillar of farm dairy processing. It guarantees the food safety of products, protects the consumer, and conditions the viability of the workshop, especially when targeting demanding marketing channels (stores, canteens, restaurants…).
Controlling health risks also allows compliance with European regulatory requirements, notably those of the Hygiene Package.
Regulatory basics
Health regulations are based on the European Hygiene Package, notably: [1][2]
- Regulation EC 852/2004 on the hygiene of foodstuffs
- Regulation EC 853/2004 specific to food of animal origin
It requires producers to:
- Declare their activity to the DDPP (Cerfa 13984)
- Implement a Food Safety Plan (FSP): cleaning plan, self-checks, personnel hygiene, traceability…
- Comply with the recommendations of the Good Hygiene Practices Guide (GHPG) dedicated to farm dairy products.
There is a GHPG specific to farm dairy products, recognized by the French administration. It is not mandatory but constitutes a validated reference; following it helps prove compliance with regulations 852 and 853/2004 in case of inspection.
Three possible health statuses
Depending on your sales channel and volumes, you may fall under one of the three following regimes: [3]
| Status | Conditions | Obligations |
|---|---|---|
| Direct sale | Sale to the final consumer | Cerfa 13984 + FSP |
| Exemption from approval | < 250 L / week (volume of products processed in liquid form) or 30% of production + < 80 km | Cerfa 13982 + list of points of sale |
| EC approval | Sales beyond thresholds or to approved establishments | Cerfa 13983 + complete HACCP file (Hazard Analysis Critical Control Point) |
Premises organization
Workshops must comply with certain organization: [4]
- A forward flow (raw material → finished product)
- A clear separation between clean/dirty areas
- Washable coverings (walls, floors)
- Proper ventilation, potable water
- Dedicated areas: entrance airlock, production room, washing area, cold room, packaging area, technical room.
Personnel and equipment hygiene
Personnel hygiene is a priority in any workshop. Good practices include: [1][5]
- Mandatory training in food hygiene
- Hand washing, wearing clean clothes, gloves if necessary
- Written cleaning/disinfection plan (CDP)
- Pest control
- Maintenance of equipment (tanks, molds, churns, etc.)
Raw milk or pasteurized milk?
The choice between raw milk and pasteurized milk as a processing base has direct consequences on hygiene constraints, taste quality and regulatory obligations.
| Type | Advantages | Constraints |
|---|---|---|
| Raw milk | Natural flavors, terroir | Very strict hygiene, regular analysis, rapid processing |
| Pasteurized milk | Increased safety | Vigilance on recontamination after pasteurization |
In all cases, milk must be cooled to +4 °C within 2 hours after milking, except immediate sale. [6]
Storage and transport temperatures
| Product | Max temperature | Recommended duration |
|---|---|---|
| Raw milk | +4 °C | < 24 h before processing |
| Yogurts | +6 °C | Shelf life 8 to 21 days |
| Ice cream | -18 °C | Several months |
Transport is possible without an approved vehicle (ATP) within a radius of < 80 km without break of cold chain. Otherwise, an approved vehicle is required.[3]
Self-checks and traceability
Self-checks demonstrate sanitary control of production. This includes: [7]
- Regular milk analyses: total germs, E. coli, coagulase-positive staph, Listeria
- Archiving results, temperatures, cleanings
- Sample retention
- Mandatory labeling: product name, ingredients, allergens, expiration date, batch, producer.
Useful resources
Texts and references
Good Hygiene Practices Guide – Farm dairy products: validated reference by the administration, to follow to prove compliance with EC regulations 852/2004 and 853/2004.
Declarations and Cerfa forms
- Cerfa 13984: declaration of activity for direct sale to consumer
- Cerfa 13982: declaration of exemption from sanitary approval
- Cerfa 13983: application for sanitary approval
- Cerfa 14788: authorization for placing raw milk on the market
Hygiene and processing training
- CFPPA (Agricultural training centers): hygiene, FSP, cheese processing
- Agricultural Chambers: sanitary support, regulatory assistance
- L’Atelier Paysan: technical training, self-construction compliant with sanitary standards
Sources
- ↑ 1.0 1.1 European Commission, 2004. Regulation (EC) No 852/2004 on the hygiene of foodstuffs.
- ↑ European Commission, 2004. Regulation (EC) No 853/2004 laying down specific hygiene rules for food of animal origin.
- ↑ 3.0 3.1 Institut de l’Élevage, 2019. Processing dairy products on the farm – Method elements and technical benchmarks.
- ↑ Ministry of Agriculture and Food, 2014. Technical instruction DGAL/SDSSA/2014-823 relating to sanitary approval conditions of short-circuit establishments.
- ↑ Ministry of Agriculture and Food Sovereignty. Good Hygiene Practices Guides (GHPG).
- ↑ FAO. Milk preservation – Farm processing.
- ↑ Agricultural Chambers of Brittany & Agrobio Brittany, 2021. Web_11 – Dairy products: sanitary rules for direct sale.
Farm dairy processing, Marketing dairy products, Economics and viability of a dairy workshop
