Overview

Changes to Regulation 761 of the Milk Act in June 2023 replaced specified cleaning frequencies at dairy plants with requirements to have sanitation programs. To comply with the new regulatory requirements, dairy plants must implement a comprehensive cleaning and sanitation program based on the food safety risk of the processes and the products being manufactured. This ensures your plant’s production environment and equipment stay clean and sanitary to help consistently produce safe products.

Effective cleaning and sanitizing methods are a function of:

  • time
  • temperature
  • chemical concentration
  • mechanical action (flow rates in closed systems or brushing action in manual cleaning)

It is important to remember that the final step of the process, sanitizing, is only effective if the cleaning (washing) has effectively removed all product residues. When surfaces are cleaned effectively, the sanitizer can destroy remaining bacteria, including penetration of biofilms, to destroy bacteria that may be inside these films.

Regular monitoring, audits and continuous improvement efforts can help identify and address any potential gaps or issues and should be part of your cleaning and sanitation program.

Regulatory requirements

As outlined in sections 86-87 of Regulation 761 — Milk and Milk Products, sanitation programs must:

  • ensure that the frequency of cleaning and sanitizing takes place as often as necessary to maintain a hygienic environment and to prevent contamination of milk or milk products
  • indicate how cleaning and sanitizing are to be done to ensure it takes place in a way that maintains a hygienic environment and minimizes the risk of contamination of the milk and milk products
  • adhere to a minimum frequency of cleaning and sanitizing as outlined in the plants’ procedures

Dairy plant operators must develop written sanitation procedures that:

  • include cleaning and sanitizing requirements for rooms, facilities, equipment and utensils used in areas of the plant where milk or milk products are handled, processed or stored
  • include cleaning and sanitizing schedules
  • are implemented, monitored and updated as needed

Operators must keep records of cleaning and sanitizing activities that include:

  • the date of the activity
  • the type of activity (such as cleaning or sanitizing)
  • the person who performed the activity
  • the results of the activity (such as an abnormal event or issue and how they were addressed)

Cleaning and sanitizing records must be kept for at least one year in an accessible format.

To ensure effectiveness, OMAFRA Food Safety Inspectors will review written sanitation programs and records as part of the ministry’s routine inspection program and licensing decisions for dairy plants.

Key elements of a cleaning and sanitation program

A comprehensive cleaning and sanitation program should incorporate the following key elements.

Sanitation standard operating procedures (SSOPs)

SSOPs are detailed written descriptions of how and when to clean and sanitize specific equipment and the various environmental areas of the plant.

Each SSOP for a particular area or piece of equipment should include:

  • when and how often to clean and sanitize
  • any steps to take before cleaning, such as taking apart equipment or protecting equipment parts like electrical switches
  • pre-rinsing steps (if required)
  • description of the cleaning tools or systems to use
  • description of the cleaning and sanitizing chemicals to use and at what concentration
  • what temperature the cleaning or sanitizing solutions should be
  • the amount of time cleaning or sanitizing solutions should be in contact with the surfaces to be cleaned
  • description of any safety precautions to take (such as wearing protective gloves and goggles)
  • cleaning in place (CIP) instructions, for equipment that can be thoroughly cleaned without disassembling.
  • cleaning out of place (COP) instructions, for equipment that requires disassembly because it cannot be adequately cleaned in place.
    • Include detailed steps for disassembly and reassembly of equipment as well as detailed cleaning instructions.
    • COP cleaning can be completed manually or by using COP tanks. COP tanks are wash tanks that can circulate cleaning solutions and sanitizer at a specified temperature, chemical concentration and for the required wash time.

SSOPs should also be developed to explain:

  • methods for cleaning brooms, brushes, squeegees and any other utensils that assist with cleaning
  • procedures for removing waste debris during production, controlling pests and addressing any potential sources of contamination
  • procedures for keeping records, including what information to record and where to record it.
    • To comply with regulatory requirements, records need to include the date, activity type(s), personnel involved and results of the cleaning and sanitizing activities (including anything abnormal and how it was addressed).
    • Records must be kept for at least one year after the date created and must also be readily accessible.

When developing SSOPs, you should work closely with your plant’s chemical suppliers who can suggest appropriate chemicals and cleaning procedures depending on the types of products made and equipment being used in your plant. Suppliers can also assist in verifying that these procedures are effective.

Master sanitation schedule

A master sanitation schedule outlines the frequency of cleaning and sanitizing activities for different areas and equipment in the plant. A thorough master sanitation schedule should include planned cleaning and sanitizing of all equipment and environmental areas, including:

  • floors
  • walls
  • ceilings
  • drains
  • surfaces of equipment that moves throughout your plant, such as vehicles or carts

This schedule should be reviewed regularly and updated as needed.

Monitoring

Monitoring helps to identify any abnormal activity and ensure that the cleaning and sanitation procedures you use are keeping the environment and equipment in good sanitary condition.

Establish monitoring procedures that verify the effectiveness of any cleaning and sanitation activities. Consult with cleaning chemical manufacturers and suppliers for expertise and advice on ensuring cleaning procedures are effective.

Monitoring procedures may include:

  • visual inspections of the equipment or plant environment
  • collecting swabs and testing them for microbial residues
  • ATP (adenosine triphosphate) testing of cleaned surfaces to measure cleaning effectiveness

Gaps or issues in the sanitation program should be promptly addressed.

Employee training

Provide comprehensive training to all plant employees involved in cleaning and sanitation. This training should highlight the importance of following all SSOPs and include instruction on proper cleaning and sanitizing techniques, chemical handling and safety.

Additional resources

External courses

Several post-secondary institutions offer educational courses to assist and educate dairy food manufacturers in topics related to food safety. These institutions include:

Contact the institution directly for details.

Contact us

If you have questions about complying with sanitation program requirements, contact OMAFRA's Inspection Programs Unit, Dairy Food Safety Program by email dairyfoodsafety@ontario.ca or call 1-877-424-1300 for more information.