Dairy Product Safety From A DFA Farmer s Perspective

1. Dairy Product Safety From A DFA Farmer�sPerspective Mickey Childers, DFA I am Mickey Childers, a member of Dairy Farmers of America Corporate Board of Directors. I served on the Gulf South Division of Mid America Dairymen from 1994 to 1998 when DFA was formed. Since the inception of DFA I have served on the South East Council Board, where I was elected to the DFA Corporate Board in January of 2000. �I am Mickey Childers, a member of Dairy Farmers of America Corporate Board of Directors. I served on the Gulf South Division of Mid America Dairymen from 1994 to 1998 when DFA was formed. Since the inception of DFA I have served on the South East Council Board, where I was elected to the DFA Corporate Board in January of 2000. �

2. The task of guaranteeing the safety of our milk supply from farm to customer is a major responsibility. Our Co-OP has 14,252Member farms in 46 states with annual milk production of nearly 38 billion pounds. In addition to our member milk DFA will market approximately 12 billion pounds of other sourced milk, estimating at 2500-2600 transport loads of milk daily. This responsibility of getting milk from farm to market extends to DFA�s own 27 manufacturing plants and to its 16 joint venture manufacturing relationships and many customers. As you can imagine, this is a major undertaking � one that we take seriously. The task of guaranteeing the safety of our milk supply from farm to customer is a major responsibility. Our Co-OP has 14,252Member farms in 46 states with annual milk production of nearly 38 billion pounds. In addition to our member milk DFA will market approximately 12 billion pounds of other sourced milk, estimating at 2500-2600 transport loads of milk daily. This responsibility of getting milk from farm to market extends to DFA�s own 27 manufacturing plants and to its 16 joint venture manufacturing relationships and many customers. As you can imagine, this is a major undertaking � one that we take seriously.

3. Late in 2000, these are the images that made everyone in production agriculture and the food processing side of the business shudder and � well, worry. With the increased threats of bio-terrorism, especially the introduction of Foot and Mouth disease into Great Britain�s cattle herd and the resulting economic devastation it had on that country, caused all of us in the U.S. dairy industry to �rethink� how we do things � The event caused us to ask, how would we react to such a crisis in the U.S. milk production and processing industry. DFA joined with the National Milk Producers Federation, Dairy Management Inc. and other cooperative to discuss the issues of crisis management. And, within DFA, we began rethinking our own Crisis plans to consider the strategies and systems we would need to put in place in the event of a bio terrorist action or some other extreme crisis event that would impede the movement of milk from farm to market place. Late in 2000, these are the images that made everyone in production agriculture and the food processing side of the business shudder and � well, worry. With the increased threats of bio-terrorism, especially the introduction of Foot and Mouth disease into Great Britain�s cattle herd and the resulting economic devastation it had on that country, caused all of us in the U.S. dairy industry to �rethink� how we do things � The event caused us to ask, how would we react to such a crisis in the U.S. milk production and processing industry. DFA joined with the National Milk Producers Federation, Dairy Management Inc. and other cooperative to discuss the issues of crisis management. And, within DFA, we began rethinking our own Crisis plans to consider the strategies and systems we would need to put in place in the event of a bio terrorist action or some other extreme crisis event that would impede the movement of milk from farm to market place.

4. �Farm to Table�  Flow Chart Since DFA is a processor of dairy products, foods and ingredients as well as being a supplier of raw milk, our plans must take into consideration everything that happens between cow to processor. Since DFA is a processor of dairy products, foods and ingredients as well as being a supplier of raw milk, our plans must take into consideration everything that happens between cow to processor.

5. This map gives you a snapshot of how daunting that task can be. This map gives you a snapshot of how daunting that task can be.

6. This is a more local view of DFA�s marketing challenge in the event of a crisis in the Southeast Area.This is a more local view of DFA�s marketing challenge in the event of a crisis in the Southeast Area.

7. So, DFA�s focus on dairy product safety has been in three primary areas: Milk Supply (Farm) Transportation (To Processor) Plants & Products (Manufacturing) As we continue to build our crisis strategy we continue to ask ourselves: 1. As a Raw Milk Supplier: How can DFA guarantee the safety of its raw milk supply from farm to plant? 2. As a Manufacturer of Products: How does DFA DFA know if its ingredients and final products are secure? 3. What Procedures Can DFA Put into Place to Mitigate the Risk? So, DFA�s focus on dairy product safety has been in three primary areas: Milk Supply (Farm) Transportation (To Processor) Plants & Products (Manufacturing) As we continue to build our crisis strategy we continue to ask ourselves: 1. As a Raw Milk Supplier: How can DFA guarantee the safety of its raw milk supply from farm to plant? 2. As a Manufacturer of Products: How does DFA DFA know if its ingredients and final products are secure? 3. What Procedures Can DFA Put into Place to Mitigate the Risk?

8. DFA�s Goals �. DFA�s focus in product safety is prevention, preparedness and ensuring customer confidence. Our strategy is team based, because we know in a crisis it isn�t every man or woman for himself, a crisis to the food system affects everyone involved. DFA�s focus in product safety is prevention, preparedness and ensuring customer confidence. Our strategy is team based, because we know in a crisis it isn�t every man or woman for himself, a crisis to the food system affects everyone involved.

9. Primary Components of DFA�s Crisis Plan Corporate Crisis Team Structure and Notification process On Farm Recommendation Field Service Procedures Milk Tank Seal Policy Plant Procedures I only have 20 minutes � so I want to take you through some of the components of DFA�s crisis plan. Please note that this is a work in progress and that it is constantly changing. The core or DFA�s Crisis Plan Is * Corporate Crisis Team Structure and Notification process * On Farm Recommendation * Field Service Procedures * Milk Tank Seal Policy * Plant Procedures I only have 20 minutes � so I want to take you through some of the components of DFA�s crisis plan. Please note that this is a work in progress and that it is constantly changing. The core or DFA�s Crisis Plan Is * Corporate Crisis Team Structure and Notification process * On Farm Recommendation * Field Service Procedures * Milk Tank Seal Policy * Plant Procedures

10. Team Approach This is a snapshot of DFA�s Team Approach in any crisis situation involving a catastrophic event involving a herd health issue that is related to food safety. Each red circle represents DFA�s seven marketing areas. Each area team has a crisis team that includes top management and professionals in the area of milk dispatch, field and member service and marketing. In a crisis, the area team would work with the corporate team and state and federal regulators and serve as the center for member and customer communications and information flow In this scenario of DFA�s team approach in action: An incident is reported to the SE area via a member or a field representative. DFA�s SE Crisis team is notified and contacts DFA�s Corporate Crisis Team. The teams assemble. In the meantime, a lot of things happen at once � state regulatory officials are called, customers and DFA plants are contacted A communications process for messaging and media contacts is established. Industry friends are called (DMI, NMPF, others) so that messages are unified and the same. Although DFA has its own strategies in place, it is important to note that � in a catastrophic event � we would follow the state guidelines. Across DFA�s 46-state area those state guidelines and rules are vastly different. So, DFA�s crisis procedures have to differ. This is a snapshot of DFA�s Team Approach in any crisis situation involving a catastrophic event involving a herd health issue that is related to food safety. Each red circle represents DFA�s seven marketing areas. Each area team has a crisis team that includes top management and professionals in the area of milk dispatch, field and member service and marketing. In a crisis, the area team would work with the corporate team and state and federal regulators and serve as the center for member and customer communications and information flow In this scenario of DFA�s team approach in action: An incident is reported to the SE area via a member or a field representative. DFA�s SE Crisis team is notified and contacts DFA�s Corporate Crisis Team. The teams assemble. In the meantime, a lot of things happen at once � state regulatory officials are called, customers and DFA plants are contacted A communications process for messaging and media contacts is established. Industry friends are called (DMI, NMPF, others) so that messages are unified and the same. Although DFA has its own strategies in place, it is important to note that � in a catastrophic event � we would follow the state guidelines. Across DFA�s 46-state area those state guidelines and rules are vastly different. So, DFA�s crisis procedures have to differ.

11. On Farm Strategies  Now I�d like to focus on those four core areas of DFA�s crisis plan starting with the supply side of our business.Now I�d like to focus on those four core areas of DFA�s crisis plan starting with the supply side of our business.

12. DFA Farm Realities Dairy farms are exposed Each operation is different Securing milk parlors is not practical for haulers, inspectors, etc. Often located in isolated areas The unmistakable reality in the food safety issue is that dairy farm are exposed. It would be impossible to put rules in place for on-farm security measures because all farms are physically different. They are �exposed� for a variety of reasons that you and I know: Dairy farms are exposed Each operation is different Securing milk parlors is not practical for haulers, inspectors, etc. Often located in isolated areas The unmistakable reality in the food safety issue is that dairy farm are exposed. It would be impossible to put rules in place for on-farm security measures because all farms are physically different. They are �exposed� for a variety of reasons that you and I know: Dairy farms are exposed Each operation is different Securing milk parlors is not practical for haulers, inspectors, etc. Often located in isolated areas

13. On Farm Control Steps Maintain a healthy, closed herd Do not purchase animals from foreign country Do not purchase replacement animals from domestic sources without determining health status Do not allow visitors on farm if they have been outside the continental U.S. in the past two weeks. DFA has encouraged its members to be pro-active. DFA has endorsed the recommended procedures issued by the National Milk Producers Federation for establishing on-farm security measures. These measures are guidelines that must be adjusted to each person�s farm. And here they are: Maintain a healthy, closed herd Do not purchase animals from foreign country Do not purchase replacement animals from domestic sources without determining health status Do not allow visitors on farm if they have been outside the continental U.S. in the past two weeks. DFA has encouraged its members to be pro-active. DFA has endorsed the recommended procedures issued by the National Milk Producers Federation for establishing on-farm security measures. These measures are guidelines that must be adjusted to each person�s farm. And here they are: Maintain a healthy, closed herd Do not purchase animals from foreign country Do not purchase replacement animals from domestic sources without determining health status Do not allow visitors on farm if they have been outside the continental U.S. in the past two weeks.

14. 5. Visitors should wear: Clean clothing Disposable outer coveralls (cloth or Tyvex) Disposable plastic footwear coverings 6. Develop, implement a quarantine program for all newly purchased animals before introducing or exposing them to any animals in herd On Farm Control � in a Crisis NMPF and DFA recommends that this is a good prevention measure that should be implemented now. However, in a crisis situation, wearing plastic boots of this nature would be a must for DFA�s field staff and others who travel from farm to farm. 5. Visitors should wear: Clean clothing Disposable outer coveralls (cloth or Tyvex) Disposable plastic footwear coverings 6. Producers should develop, implement a quarantine program for all newly purchased animals before introducing or exposing them to any animals in herd NMPF and DFA recommends that this is a good prevention measure that should be implemented now. However, in a crisis situation, wearing plastic boots of this nature would be a must for DFA�s field staff and others who travel from farm to farm. 5. Visitors should wear: Clean clothing Disposable outer coveralls (cloth or Tyvex) Disposable plastic footwear coverings 6. Producers should develop, implement a quarantine program for all newly purchased animals before introducing or exposing them to any animals in herd

15. 7. Clean, disinfect, maintain all livestock treatment and handling equipment in a sanitary condition 8. Restrict unauthorized visitors and vehicles from entering any animal production related area. Non Farm Vehicles should be confined away from animal production areas to avoid spread of disease All visitors should sign in/out and be escorted On Farm Control Steps 7. Clean, disinfect, maintain all livestock treatment and handling equipment in a sanitary condition 8. Restrict unauthorized visitors and vehicles from entering any animal production related area. Non Farm Vehicles should be confined away from animal production areas to avoid spread of disease All visitors should sign in/out and be escorted 7. Clean, disinfect, maintain all livestock treatment and handling equipment in a sanitary condition 8. Restrict unauthorized visitors and vehicles from entering any animal production related area. Non Farm Vehicles should be confined away from animal production areas to avoid spread of disease All visitors should sign in/out and be escorted

16. 9. Implement precautions to assure compliance with the FDA Ruminant Feed Ban. 10. Implement an active fly, rodent and bird control program. 9. Implement precautions to assure compliance with the FDA Ruminant Feed Ban. 10. Implement an active fly, rodent and bird control program. 9. Implement precautions to assure compliance with the FDA Ruminant Feed Ban. 10. Implement an active fly, rodent and bird control program.

17. Park away from the barn. Disposable coveralls, boots. Stay away from other livestock. Observe farm security measures. Report in at the house. Wash, disinfect any equipment used on the farm prior to leaving the premises. Follow DFA Crisis Team, State Regulatory directives DFA has emergency field staff procedures in place. In the event of an emergency, these are some of the procedures they would follow. � Park away from the dairy facility when on the farm. Wear disposable coveralls (Cloth or Tyvex) and disposable boots. If non-disposable boots or shoes are worn thoroughly wash and disinfect with EPA approved disfectants such as VirkonS or Oxonia Active-Oxycept 333. Household vinegar or Acetic Acid at 4-7% in absence of organic matter will effectively inactivate viruses or bacteria. Stay away from other livestock species while on the dairy facility. Observe security measures in place on the farm and follow them. Report in at the house or call before arrival. Thoroughly wash and disinfect any equipment used on the farm prior to leaving the premises. Follow Crisis Team and State Regulatory directives. � . DFA has emergency field staff procedures in place. In the event of an emergency, these are some of the procedures they would follow. � Park away from the dairy facility when on the farm. Wear disposable coveralls (Cloth or Tyvex) and disposable boots. If non-disposable boots or shoes are worn thoroughly wash and disinfect with EPA approved disfectants such as VirkonS or Oxonia Active-Oxycept 333. Household vinegar or Acetic Acid at 4-7% in absence of organic matter will effectively inactivate viruses or bacteria. Stay away from other livestock species while on the dairy facility. Observe security measures in place on the farm and follow them. Report in at the house or call before arrival. Thoroughly wash and disinfect any equipment used on the farm prior to leaving the premises. Follow Crisis Team and State Regulatory directives. � .

18. Transportation Strategies Transportation of the milk from farm to processor or customer presents other challengesTransportation of the milk from farm to processor or customer presents other challenges

19. Of course, no one can forget these images. DFA created its milk tank seal policy following the 911 tragedy and the anthrax scare. DFA worked with customers to develop milk tank seal program to prevent contamination of milk once it is in the tanker. Of course, no one can forget these images. DFA created its milk tank seal policy following the 911 tragedy and the anthrax scare. DFA worked with customers to develop milk tank seal program to prevent contamination of milk once it is in the tanker.

20. The purpose of our milk tank policy is to better assure our customers and the consuming public that milk offered for sale is as safe as possible. Policies were established by DFA to institute tanker security Wash tickets or manifests should have the seal numbers corresponding to the load of milk Know the source of raw milk Haulers sign in with load every day. To verify chain -of-custody of raw milk The purpose of our milk tank policy is to better assure our customers and the consuming public that milk offered for sale is as safe as possible. Policies were established by DFA to institute tanker security Wash tickets or manifests should have the seal numbers corresponding to the load of milk Know the source of raw milk Haulers sign in with load every day. To verify chain -of-custody of raw milk

22. Sealing Raw Milk Tankers After washing, ensure openings sealed Seal record (on wash tag, manifest, etc.) Wash tags (required by PMO) Driver verifies seals before milk collection Missing/broken seals�notify plant or Co-op At 1st pick-up, break seals and record Openings remain sealed when driver not present Last pickup, attach numbered seal, and record At plant, compare seal to seal log If numbers match, unload milk If no match, or seal broken, investigate Multiple pickups, same procedure Our customers have supported DFA�s leadership efforts in this category in helping assure product safety. Basically, these 12 steps show how the Milk Tank Seal Policy works. 1. After washing, ensure openings sealed 2. Seal record (on wash tag, manifest, etc.) 3. Wash tags (required by PMO) 4. Driver verifies seals before milk collection 5. Missing/broken seals�notify plant or Co-op 6. At 1st pick-up, break seals and record 7. Openings remain sealed when driver not present 8. Last pickup, attach numbered seal, and record 9. At plant, compare seal to seal log 10. If numbers match, unload milk 11. If no match, or seal broken, investigate 12. Multiple pickups, same procedure Our customers have supported DFA�s leadership efforts in this category in helping assure product safety. Basically, these 12 steps show how the Milk Tank Seal Policy works. 1. After washing, ensure openings sealed 2. Seal record (on wash tag, manifest, etc.) 3. Wash tags (required by PMO) 4. Driver verifies seals before milk collection 5. Missing/broken seals�notify plant or Co-op 6. At 1st pick-up, break seals and record 7. Openings remain sealed when driver not present 8. Last pickup, attach numbered seal, and record 9. At plant, compare seal to seal log 10. If numbers match, unload milk 11. If no match, or seal broken, investigate 12. Multiple pickups, same procedure

23. This shows the record keeping processThis shows the record keeping process

24. This shows the Seal ProcessThis shows the Seal Process

25. As with on farm regulations, DFA follows state and federal regulations � and sometimes requirements are different by region. For instance, the state of Georgia requires locked refrigerators for milk samples. DFA�s Southeast Area also requires picture I.d.s for contract couriers.As with on farm regulations, DFA follows state and federal regulations � and sometimes requirements are different by region. For instance, the state of Georgia requires locked refrigerators for milk samples. DFA�s Southeast Area also requires picture I.d.s for contract couriers.

26. StrategyPlants & Products DFA�s Dairy Product Safety Plans go beyond what I�m presenting today. I just want to hit you with some of the obvious highlights.DFA�s Dairy Product Safety Plans go beyond what I�m presenting today. I just want to hit you with some of the obvious highlights.

27. Identifying Food Risks Raw Supply Ingredients Finished Products Facility Design/Entry points, Security Personnel Focus on Process, Guidelines & Observation Each DFA plant has crisis plans for anything from accidents to product recalls to what to do in a tornado drill. However, DFA plants are constantly looking at areas where we can do a better job. Currently our plants are finalizing a special audit regarding this issue of food safety and security. Basically the audit looks at each plant to: Identify the highest risk areas Raw Milk Supply Ingredients Finished Dairy Products Review each facility for design,entry points, & security issues Review our Personnel policies Review our systems and processes Each DFA plant has crisis plans for anything from accidents to product recalls to what to do in a tornado drill. However, DFA plants are constantly looking at areas where we can do a better job. Currently our plants are finalizing a special audit regarding this issue of food safety and security. Basically the audit looks at each plant to: Identify the highest risk areas Raw Milk Supply Ingredients Finished Dairy Products Review each facility for design,entry points, & security issues Review our Personnel policies Review our systems and processes

28. Guests Entering a Facility How do they enter your facility? Improve Security Measures Report to a main entrance Sign in a log book Issue guest badges upon reviewing picture identification Provide copy of visitor rules Special clothing may be required. One of the most critical elements in improving plant security that we have in force is our Visitor policy. During the anthrax scare DFA�s plants stopped all plant tours. DFA has a visitor policy in place that includes: sign in and sign out procedures that are logged, issue guest badges, and require an employee to accompany that person through the plant. Some locations may require visitors to wear special clothing. Plant tours still are not as frequent, food areas are carefully monitored. Employees are urged to be alert and report anybody or anything out of place. One of the most critical elements in improving plant security that we have in force is our Visitor policy. During the anthrax scare DFA�s plants stopped all plant tours. DFA has a visitor policy in place that includes: sign in and sign out procedures that are logged, issue guest badges, and require an employee to accompany that person through the plant. Some locations may require visitors to wear special clothing. Plant tours still are not as frequent, food areas are carefully monitored. Employees are urged to be alert and report anybody or anything out of place.

29. DFA�s safety procedures include security measures for entry points into the plants as well as a review of access to chemical storage. This is an ongoing challenge since every plant�s structure and function is different. So, as in on the farm, procedures have to be adjusted to suit the plant. DFA plants continue to audit this area of security. Considerations are: How can we Eliminate Opportunity for Forced Entry? Who is coming and going and should they be there? What are the best Security measures for cleaning materials, raw ingredients and finished products? What is the status of locks and security on Gates, fences, or doors? DFA�s safety procedures include security measures for entry points into the plants as well as a review of access to chemical storage. This is an ongoing challenge since every plant�s structure and function is different. So, as in on the farm, procedures have to be adjusted to suit the plant. DFA plants continue to audit this area of security. Considerations are: How can we Eliminate Opportunity for Forced Entry? Who is coming and going and should they be there? What are the best Security measures for cleaning materials, raw ingredients and finished products? What is the status of locks and security on Gates, fences, or doors?

30. Insider compromise is an area of concern for all processing plants. DFA�s audit process is examining this area carefully. Background checks on employees -- Conduct work reference checks provided by third party companies Observation of employees at work -- Provide supervision/monitoring in critical control areas; Hire outside security service, if appropriate Develop (HACCP) hazard analysis of critical control points -- Understand and identify where these points are and how to control them Awareness -- What are the best Security measures for cleaning materials, dairy ingredients; and what is the status of locks and security on Gates, fences, or doors. Insider compromise is an area of concern for all processing plants. DFA�s audit process is examining this area carefully. Background checks on employees -- Conduct work reference checks provided by third party companies Observation of employees at work -- Provide supervision/monitoring in critical control areas; Hire outside security service, if appropriate Develop (HACCP) hazard analysis of critical control points -- Understand and identify where these points are and how to control them Awareness -- What are the best Security measures for cleaning materials, dairy ingredients; and what is the status of locks and security on Gates, fences, or doors.

31. Checklist 2000-02 Developed an Area-Wide Crisis Response Team Endorsed On-Farm Recommendations Implemented new Crisis Strategies for Field Staff Implemented an official DFA Policy & Procedures for Milk Tank Seals Made changes in plant security, warehousing, and employee procedures Developed a risk audit process for identifying areas of vulnerability In summary: DFA�s plan for Crisis is never-ending. I think the point is, here, is that everyone was rocked by the past three events. We take food safety seriously. These are some of the steps we�ve taken recently to ensure product safety from farm to market. Developed an Area-Wide Crisis Response Team Endorsed On-Farm Recommendations Implemented new Crisis Strategies for Field Staff Implemented an official DFA Policy & Procedures for Milk Tank Seals Made changes in plant security, warehousing, and employee procedures Developed a risk audit process for identifying areas of vulnerability In summary: DFA�s plan for Crisis is never-ending. I think the point is, here, is that everyone was rocked by the past three events. We take food safety seriously. These are some of the steps we�ve taken recently to ensure product safety from farm to market. Developed an Area-Wide Crisis Response Team Endorsed On-Farm Recommendations Implemented new Crisis Strategies for Field Staff Implemented an official DFA Policy & Procedures for Milk Tank Seals Made changes in plant security, warehousing, and employee procedures Developed a risk audit process for identifying areas of vulnerability

32. DFA�s Daily Common Sense Policy Be alert to daily activity. If unusual, check it out. Establish procedures and enforce them. Make note of unusual people and/or activity. That said, we know that this has to be an industry wide effort � because a crisis in the food community is a national issue that would affect everyone from farmer to processor to food retailer to restaurant owner to tourism income. DFA�s Plant and On Farm Policy for Dairy Product Safety is built around Prevention. Whether it is farm or plant � Be Pro-active! Know Your Facility or Your Farm! Know Your Employees, Haulers, Suppliers, Vendors! Control Your Visitors! Train And Educate Staff! Know Your Transportation System! Review Your Security Systems That said, we know that this has to be an industry wide effort � because a crisis in the food community is a national issue that would affect everyone from farmer to processor to food retailer to restaurant owner to tourism income. DFA�s Plant and On Farm Policy for Dairy Product Safety is built around Prevention. Whether it is farm or plant � Be Pro-active! Know Your Facility or Your Farm! Know Your Employees, Haulers, Suppliers, Vendors! Control Your Visitors! Train And Educate Staff! Know Your Transportation System! Review Your Security Systems

33. Unity is at the core of our policy � because we know what is at risk and what we are all trying to protect One Voice. One Message. One Cohesive Strategy. Unity is at the core of our policy � because we know what is at risk and what we are all trying to protect One Voice. One Message. One Cohesive Strategy.