Here at Lewis Bass, we have experienced engineers on our staff that have worked in a variety of industries prior to coming to the world of engineering safety consulting.
Our newest hire, Eduardo Jimenez, has over 20 years of experience as an industrial electrician in a variety of industries that has seen him working with motor controls, instrumentation, industrial automation, and power distribution systems.
Today’s story is from one of Eduardo’s past experiences working at a job site in Northern California for a company in the dairy industry that produced milk, yogurt, and cheese products.
During his time at this facility, Eduardo noticed health and safety hazards with the machinery being used for milk and yogurt production and now wishes he could have referred the company to an engineering safety consultant like Lewis Bass.
Had Lewis Bass been made aware of these safety issues at this dairy company, we would have responded with a defined safety consulting plan specifically tailored to cover workplace and facility safety in line with OSHA mandated expectations.
What is the CDFA and how does it regulate the dairy industry in California?
The MDFS (Milk and Dairy Food Safety) branch of the CDFA is the division charged with the regulation of companies with milk product plant licenses and permits in California. They do this through the use of surprise inspections of dairy companies to ensure that production is being done safely for the work involved and for the final products made.
What role does the USDA have in regulating the dairy industry in California?
Through the self-elected dairy plant survey program, dairy companies seeking the approval of the USDA accreditation for marketed product branding purposes, willfully submit to random inspections from the USDA.
These inspections occur, because, according to the guidelines of maintaining USDA accreditation, once the facility is approved “…a plant does not automatically keep its status. A plant must be inspected at least twice a year to maintain its eligibility.”
How does the FDA come into play for dairy industry regulation?
Under the Milk Safety Program, the FDA states that it performs regulation of milk products in each state:
[The FDA] Assists the State NCIMS Milk Safety Regulatory Agencies in initiating and maintaining effective programs for the prevention of milk borne diseases, a model regulation known as the “Grade ‘A’ Pasteurized Milk Ordinance” (PMO)…this model Milk Ordinance provides administrative and technical details to assist the State NCIMS Milk Safety Regulatory Agencies in obtaining satisfactory compliance with the Ordinance.
Eduardo’s Experience Working In the Dairy Industry
First, let’s start with some background on testing expectations in the dairy industry and how the regulators come into the picture from Eduardo in his own words:
In the Dairy industry, from cheese manufacturing, to yogurt and milk pasteurization, time and temperature are the most important factors in the process. Skills and experience are an essential part of the job in those industries; but also having the proper standard operating procedures and training is really important.
Having calibrations performed to guarantee the accuracy on the devices used to maintain these ideal production conditions, such as RTD’s (resistance temperature detectors) and HART (Highway Addressable Remote Transducer) devices is imperative to guarantee these consistent results.
RTD’s have to be precise, since a minor deviation could spoil a full yogurt vat and thousands of dollars in product will go down the drain. A calibrated instrument is a must. In my experience, when engineering maintains these devices, the production efficiency goes way up, and inspections with USDA, FDA or CDFA (in California) will go most of the time really smooth. This is because the Inspector sees that there is a proper maintenance program keeping the instruments in optimal condition.
Now, my stories below come from the packaging side of the production line which I was hired to maintain and keep in good order:
I was hired to trouble shoot the filler system at a company in the east bay and I discovered the following issues:
I saw a milk filling system that was custom made and was missing OSHA required door switches and safety mechanisms when the filler was operating. Luckily no one was hurt during my time there while operating this filling system, since this was clearly an unsafe usage of the equipment by bypassing safety for increased milk production.
An X-ray machine at this same facility that was used for yogurt packaging for high volume processing (250 cups per minute) was being used without a proper safety program in place to teach workers how to operate it safely. I saw workers reaching their hands into the laser system if the cups got stuck. Which they did quite often on my watch. I brought up this safety issue to the plant supervisor and he informed me that he had no plan to address the safety issues associated with the x-ray machine. This situation put workers at great risk and was the result of a lack of legally required company safety training.
Eduardo’s observations during his time working at this dairy production facility are more common than you might think.
The avenues available to address them are numerous and can start with basic staff training, followed up with a facility safety plan to minimize liability for the company, to simple EMO buttons and light curtain solutions for halting machinery prior to a worker getting a serious injury from force or prolonged radiation exposure.
Lewis Bass International Engineering Services offers this type of turn-key safety consulting and has trusted partners to help facilities come up to code for safety issues from a facility level all the way to production lines and individual machines.